Connecticut Regional Haze 

State Implementation Plan November 2009 

ATTACHMENT I 

Comments from Federal Land Managers and EPA (with responses):

 

 Including comments on the August 27, 2009 Public Hearing
Attachment I 

- Forest Service Comments on MANE-VU 2018 Modeling Draft Report and BenMAP 

Draft Report 

- Department of Agriculture/Forest Service Comments on SIP Preparation 

- Fish and Wildlife Comments on SIP Preparation 

EPA comments



-CT RH SIP comments - 020409



-CT-BART(05-22-08)





FLM comments



-CT DOI RH SIP Comments



-CT Prelim DOI Comments



-Draft Comments for CT BART


-FS correspondence (2)



-Enc 1 Tech Comments CT RH SIP (3)



-Enc 2 10-13-06 Ltr (2)





EPA/FLM consultation notes



-FLMconsultation031809v2



Description of EPA Comments on Draft CTRHSIP

Description of Federal Land Manager Comments on Draft CTRHSIP

Description of Federal Land Manager Comments on Draft CTRHSIPNPSFWS

Comments received on the August 27, 2009 Public Hearing

-Chuck Carlin Comments

-EPA Comments

-Federal Land Manager Comments #1

-Federal Land Manager Comments #2 
From: Angela King [aking@marama.org] 

Sent: Wednesday, January 30, 2008 10:10 AM 

To: Bodnarik, Andy; Underhill, Jeff; Martone, Charles H 

Subject: FW: Opportunity to Comment on the MANE-VU 2018 Modeling Draft 

Report and the BenMAP Draft Report 

From Charles Sams of the Forest Service 

-----Original Message----- 

From: Charles E Sams [mailto:csams@fs.fed.us] 

Sent: Wednesday, December 26, 2007 1:22 PM 

To: Angela King 

Subject: Re: Opportunity to Comment on the MANE-VU 2018 Modeling Draft Report and the 

BenMAP Draft Report 

Angela, 

I found MANE-VU's "Modeling for Reasonable Progress" draft document to be informative and 

well organized. The distribution of SO2 emissions provided in Figure 1-5 was particularly 

interesting in light of MANE-VU's promotion of the S1 and S2 BOTW strategies. In Figure 1-5, 

the I-95 corridor stands out as one of the nation's dominant SO2 source regions during CY2002. It 

would be informative and perhaps helpful for the advancement of the S1 and S2 strategies to 

include within Section 5.1, in close proximity to the other figures in Section 5.1, another figure 

comparing the aerial 

reductions of SO2 associated with those strategies. I may choose to make 

further comments before January 9. 

Thanks, 

Chuck 

Chuck Sams 

Air Quality Program Manager 

USDA Forest Service, Regions 8 and 9 

626 E. Wisconsin Ave. 

Milwaukee, WI 53202 

414-297-3529, FAX-414-944-3964 

csams@fs.fed.us 

www.fs.fed.us/air 

 "Angela King" 

 <aking@marama.org 

 > To "'Angela King'" <aking@marama.org> 

 12/12/2007 12:09 cc 

 PM 

 Subject 

 Opportunity to Comment on the 

 MANE-VU 2018 Modeling Draft Report 

 and the BenMAP Draft Report 

 

 Opportunity To Comment 
 

 MANE-VU 

 (Mid-Atlantic/Northeast Visibility Union) 

 December 12, 2007 

 

MANE-VU members, other states, and stakeholders are invited to comment on two draft reports. 

MANE-VU is charged with coordinating regional haze planning in the Mid-Atlantic and 

Northeastern United States. The documents listed below will assist in this process. Please see 

below for brief descriptions and links to more information. 

 . MANE-VU Modeling for Reasonable Progress Goals: Model 

 Performance Evaluation, Pollution Apportionment, and Control 

 Measure Benefits 

 . Public Health Benefits of Reducing Ground-level Ozone 

 and Fine Particle Matter in the Northeast U.S.: A Benefits Mapping 

 and Analysis Program (BenMAP) Study 

The comment period will be open through January 9, 2008. Comments and questions should be 

sent via email to Angela King of MARAMA at aking@marama.org. 

MANE-VU Modeling for Reasonable Progress Goals Draft Report 

The main purpose of this report is to assist states in developing effective solutions to regional 

visibility and fine particle problems and comply with requirements under the Regional Haze Rule. 

Northeast States for Coordinated Air Use Management (NESCAUM) conducted regional air 

quality simulations for calendar year 2002 and several future periods. This work was directed at 

satisfying a number of compliances goals under the Haze State Implementation Plan (SIP), 

including a contribution assessment, a pollution apportionment for 2018, and the evaluation of 

visibility benefits of control measures being considered for achieving reasonable progress goals 

and establishing a long-term emission management strategy for MANE-VU Class I areas. 

This report describes efforts that form the foundation upon which MANE-VU states will base their 

haze SIP submissions. After the MANE-VU regional planning organization (RPO) considers the 

results provided here and consults with neighboring states and federal land managers, we 

anticipate that a final model simulation will be conducted to serve as a basis for calculating final 

reasonable progress goals. 

Results show that sulfate aerosol, the dominant contributor to visibility impairment in the 

Northeast's Class I areas on the 20 percent worst visibility days, has significant contributions from 

states throughout the eastern U.S. These contributions are projected to continue in future years 

from all three of the eastern RPOs. 

An assessment of potential control measures that would address this future contribution has 

identified a number of promising strategies that would yield significant visibility benefits. These 

measures include the adoption of low sulfur heating oil, implementation of Best Available Retrofit 

Technology (BART) requirements, and additional electric generating unit 
(EGU) controls on select sources. The combined benefits of adopting all of these programs could 

lead to an additional benefit of between 0.38 and 1.1 deciviews at MANE-VU Class I areas on the 

20 percent worst visibility days by 2018. 

The draft document is available at: 

http://filesharing.nescaum.org/download.php?file=31Modeling%20for%20Reasonab 

le%20Progress%2012.10.07.doc 

Public Health Benefits of Reducing Ground-level Ozone and Fine Particle Matter in the Northeast 

U.S. Draft Report 

NESCAUM used the U.S. Environmental Protection Agency's (EPA's) Environmental Benefits 

Modeling and Analysis Program (BenMAP) to determine the magnitude and value of avoided 

adverse health endpoints in the northeast U.S. associated with various emission control programs 

in 2018. Future year air quality associated with implementation of various control strategies was 

simulated using two air quality modeling platforms, the Community Multi-scale Air Quality 

modeling system (CMAQ) and the California Photochemical Grid Model (CALGRID). 

NESCAUM examined the public health and monetary benefits of several potential emission 

control programs under consideration by the Ozone Transport Commission (OTC) and MANEVU states. These programs include an EGU control strategy for nitrogen oxides (NOX) and sulfur 

dioxide (SO2) that increase the stringency of the current Clean Air Interstate Rule 

(CAIR) and SO2 emissions control strategies that would complement existing regulations to 

further reduce fine particle concentrations and improve visibility under the Regional Haze Rule. In 

addition, NESCAUM examined the benefits of achieving several different levels of the National 

Ambient Air Quality Standard (NAAQS) for 8-hour average ozone concentrations (NAAQS 

rollback). 

The draft document is available at: 

http://filesharing.nescaum.org/download.php?file=366BenMAP_report_draft%20fi 

nal%2011.16.07.pdf 

The Process 

Comments will be reviewed and may result in changes to the draft documents. After reviewing 

comments, MANE-VU will post a summary response to those comments received by January 9, 

2008. Comments received after that date will be considered as time permits. 

Please send comments and questions to Angela King at aking@marama.org by January 9, 2008. 














\"if.D ST"Il'

.. 

C1 

1-", V

"'t PAO"i

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 1

1 CONGRESS STREET, SUITE 1 1 00

BOSTON, MASSACHUSETTS 02114-2023

April 3 , 2009

David Wackter

Connecticut Departent of Environmental Protection

79 Elm Street

Harford, CT 06106-5127

Dear Mr. Wackter:

On February 4 2009, we received your draft Regional Haze SIP. EP A staffhave

reviewed this draft and you wil find our comments in the Enclosure.

If you have any questions on these comments, please contact Ane McWiliams at (617)

918- 1697.

Sincerely,

,, . 

Ane Arold, Manager "

Air Quality Plannng Unit

Enclosure

cc: Wendy Jacobs (CTDEP)

Toll Free. 1-888-372-7341

Internet Address (URL) . http://www.epa.gov/region1

Recycled/Recyclable. Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% postconsumer)
Enclosure

EP A Comments on Connecticut'

February 4, 2009 Draft Regional Haze SIP

Chapter 1: The Regional Haze Issue

1) Paragraph four on page I- I should be revised as follows:

The Regional Haze Rule calls for each state to establish reasonable progress

goals for visibility improvement and to formulate a long-term strategy for meeting

these goals.

2) On page 1- , Connecticut states

, 

On the worst 20 percent days, visibility impairment

in Northeast and Mid-Atlantic Class I areas ranges from about 25 to 30 dv (deciviews).

This statement is inconsistent with the data presented later in Table 4.2 in Section 4.

The table lists the baseline 20% worst visibility for MANE- VU Class I areas as 21.7 to

29.0 dv. In addition, in the page 1-5 discussion, it would be helpful to include the

visibility range in miles in order to give the reader a better frame of reference.

3) Paragraph four on page 1-6 should be revised as follows:

.. . about half of the worst visibility days in the New Hampshire Class I Areas

occur in the summer when meteorological conditions are more conducive to the

formation of sulfate from S02 and to the oxidation of organic aerosols. In

addition, winter and summer transport patterns are different, possibly leading to

different contributions from up'vVind source regions. " S a result Ihe remaining

worst visibility days are divided nearly equally among spring, winter and fall. 

addition, winter and summer transport patterns are different, possibly leading to

different contributions from upwind source regions

Chapter 6: Emissions Inventories

4) Table 6.1 indicates that EGU Point S02 emissions were 2,438 tons in 2002. Table 6.2

indicates that EGU Point S02 emissions in 2018 are expected be 6 697 tons. Connecticut

should explain why S02 emissions are expected to increase so significantly.

Chapter 8: Sources

5) The reference cited for Figure 8. 11 appears inaccurate. Please correct this reference.

6) In the second paragraph of Section 8. , Connecticut states

, 

Most states in the region

showed declines in annual S02 emissions through 2002 compared with those previous

inventories." Connecticut should include the data that support this statement, refer to

another document that contains the supporting data, or remove the statement.
Chapter 9: Best Available Retrofit Technology (BART)

7) In Section 9. , Connecticut should include a discussion of the available controls for

each source category and the determination of the BART control level benchmark.

8) In Section 9. , Connecticut states

, 

During the last few years Connecticut has

developed additional regulatory measures aimed at reducing emissions of S02 and NOx

from a large universe of in-state sources." Connecticut should include more information

regarding the universe of sources impacted by these additional regulatory measures.

Specifically, Connecticut should emphasize the number and size of non-BART sources

that are subject to these measures.

Chapter II: Long-term Strategy

9) In the second paragraph Section 11.4. , Connecticut discusses possible logistical

issues that may impact implementation of the low-sulfur oil strategy in the northern New

England states. It is not clear why this discussion is included in Connecticut' s SIP. The

DEP should either explain how this might be relevant to Connecticut's ability to enact the

MANE- VU low sulfllr fuel oil strategy, or delete the discussion.

10) In the third paragraph of Section 11.4.2, Connecticut states that DEP wil review the

details of the low-sulfur fuel oil strategy in five years

, 

to ascertain that requiring the use

of low-sulfur fuel remains viable for implementation by 2018." This appears inconsistent

with the MANE- VU "Ask" for the other zone which calls for #2 distilate oil to be

reduced to 0.05 percent (500 ppm) sulfu, by weight, by no later than 2014.

11) In Section 11. , EP A recommends that Connecticut include a table of any verified

source retirements or replacements, rather than referring the reader to the attachments.

12) The Section 11. 9 discussion on Connecticut's share of emission reducti'ons currently

focuses on S02 reductions. Connecticut should also summarize any additional programs

the state plans to implement that will lead to visibility improvements. For example, does

Connecticut plan to adopt a rule for outdoor wood boilers, as has been done by several

New England states?

13) Section 11. 11 discusses enforceability of emission limitations. In order to ensure

federal enforceability, Connecticut should submit to EP A as a SIP revision any

regulations that the state considers part of its Regional Haze SIP. Also, section 11.

includes the statement

, 

CTDEP wil incorporate existing PM controls at the BARTeligible units into Title V permit renewals for BART purposes. " This wil not necessarily

make BART federally enforceable unless the underlying requirement is federally

enforceable.











Connecticut 

Draft Regional Haze SIP Revision 

Preliminary Department of the Interior (DOI) Comments 

March 16, 2009

GENERAL ISSUES 

Issues of concern are: 

- No analysis available for the “full” adoption of the MANE-VU Ask. The draft SIP is 

contradictory in that earlier on CT fully adopts the MANE-VU Ask as a part of its 

long term strategy, however, throughout the document the State only commits to 

pursuing aspects of the Ask to determine if they are reasonable to adopt by 2018. 

- State-specific program for BART equivalency (please see attached document) 

GENERAL COMMENTS BY FLM TOPICS 

Area of Influence 

Section 2.0 Areas Contributing to Regional Haze – The State needs to include a summary 

of the Contribution Assessment. The draft SIP states that CT emissions have measurable 

impacts on Class I areas, but provides no details or comparison to other states in the 

region. 

At a minimum, the State should include a discussion on the three criteria used by MANEVU to determine consultation. This would at least provide context to what CT states as 

their contribution. In addition, the draft SIP should provide percent contributions of 

neighboring states to better understand the magnitude of the State’s contributions. 

Regional Haze Planning and Consultation 

In Section 3.2.2, Connecticut agrees with the MANE-VU Ask and commits to pursuing 

emission reductions consistent with the Ask. However, in Section 3.2.2.2, Connecticut 

does not address all elements of the Ask, instead saying it will review the viability of the 

remainder of the Ask in the 2013 review. It is inconsistent language to conclude the State 

will pursue emission reductions consistent with the Ask but at the same time say it will 

continue to review the viability of certain measures of the Ask over the next five years. 

In Section 3.2.3, Connecticut implies that addressing inconsistencies with emission 

inventories, both within MANE-VU and out, “caused” most States to miss the 2007 

statutory submittal to EPA. This statement should be considered for accuracy and 

removed. 

In Section 3.2.5, please include February 4, 2009 as the date of submission to FLMs. 
Monitoring Strategy 

In Section 5.0 Air Monitoring Strategy, Connecticut should include language that 

commits the State to continuing support of the IMPROVE network. 

In Section 5.3, the statement is incorrect. Moosehorn Wilderness and Roosevelt 

Campobello International Park also share a monitoring site. 

Emission Inventories 

Section 6.0 is dedicated to the emission inventory development by MANE-VU and used 

by Connecticut. For comparison of Table 6.1 and 6.2, please include an explanation as to 

why NH3 emissions go up in projected 2018 inventory (Best and Final inventory). 

Reasonable Progress Goals and Long Term Strategy 

Section 11.2 – Technical Basis for Strategy Development – CT references technical 

reports that were used to determine the level of emission reduction required by CT to 

achieve reasonable progress goals in Class I areas affected by CT emissions. However, 

there is no statement or summary information identifying what the necessary reduction 

levels actually were. 

Section 11.5 Source Retirement and Replacement Schedule – Please include Table B-5 

from Attachment N in the text. As written, the draft SIP provides no information on 

source retirement in CT. 

Section 11.9 Connecticut’s Share of Emissions Reductions – Please include what strategy 

is used to get the predicted 2018 results. 

Section 11.12 Prevention of Significant Deterioration – The State makes a clear link 

between its regional haze program and the importance of the PSD program in helping to 

meet the goals of that program. 

Fire 

The State concludes that there is no information suggesting smoke emissions will 

increase over the next decade (Section 11.7). Will the State track such emissions to 

determine if this assumption is correct? 

The draft SIP states CTDEP has a smoke management program. Please include a brief 

summary of what that program entails. It is unclear why CTDEP has a smoke 

management program since the draft SIP already concludes that wood smoke is only a 

fraction of fine particle mass. Attachment FF is listed as Connecticut Smoke 

Management Documentation. 
Comments/Issues Regarding the Best Available Retrofit Technology 

(BART) Provisions of the Connecticut Regional Haze SIP 

The Connecticut Department of Environmental Protection (CDEP) has done a 

commendable job in the overall level of control required of its BART-eligible sources 

(e.g., 0.3 percent sulfur fuel-oil). It stands out among all the states in the region in this 

regard. The comments presented below center on the lack of a certain rigor in the BART 

determination process, and the need to perform source-by-source BART determinations. 

The EPA and MANE-VU ‘benchmarks’ used by CDEP as described in Section 9.2.3 as 

being BART are not necessarily BART. Since the overall level of control among 

Connecticut BART sources is significant, source-by-source BART determinations may 

conclude that additional controls are not cost-effective and the existing proposed controls 

are BART. Nevertheless, these BART determinations should be performed as an integral 

part of the demonstration of the “alternative measure” for BART as proposed by CDEP. 

40 CFR 51.308 (e) (2) (i) (C) requires that a “determination of BART for each source” be 

performed. Approval by EPA of an “alternative method” may relieve the State from 

requiring installation of BART on certain sources, but it does not relieve the State from 

performing source-by-source BART determinations in developing a demonstration that 

justifies using an “alternative method”. 

In attempting to comply with the 40 CFR 51.308 (e) (2) requirement that the State submit 

an “implementation plan” for the proposed “alternative measure”, CDEP made an 

assumption that the EPA BART Guidelines1

 set SO2 BART for oil-fired boilers as 

burning a 1.0 percent sulfur fuel-oil. CDEP then used this definition as a de facto 

standard to show that a requirement of 0.3 percent sulfur fuel-oil resulted in “greater 

reasonable progress” and the ability to use an “alternative measure” for BART. The 

assumption that SO2 BART is the use of 1.0 percent sulfur fuel-oil is not correct. 

The EPA BART Guidelines state that you should “evaluate limiting the sulfur content of 

the fuel-oil burned to 1 percent or less by weight”, but this is not to be interpreted that the 

use of 1 percent fuel-oil is considered to be BART for oil-fired boilers. It is only a

presumptive BART alternative that should be considered. In the EPA BART Guidelines 

where the process for the analysis of control options for sources subject to BART is 

described, it is stated that, “Best Available Retrofit Technology (BART) means an 

emission limitation based on the degree of reduction achievable through the application 

of the best system of continuous emission reduction for each pollutant which is emitted 

by . . . [a BART-eligible source]. The emission limitation must be established, on a caseby-case basis, taking into consideration the technology available, the costs of compliance 

. . . and the degree of improvement in visibility which may reasonably be anticipated to 

result from the use of such technology.”2 For this reason additional feasible control 

1

 See 40 CFR Part 51, Appendix Y. The U.S. Environmental Protection Agency finalized it’s BART 

Guidelines on June 15, 2005, and published the preamble and final rule text in the Federal Register on 

July 6, 2005. The rulemaking action added Appendix Y to Part 51, titled “Guidelines for BART 

Determinations Under the Regional Haze Rule.” See Section IV.E.4.

2

 Ibid, See Section IV.A.
alternatives should have been considered for each source in order to determine BART. 

Then, greater reasonable progress could be determined by comparing the BART for all 

BART-eligible sources against the across-the-board 0.3 percent sulfur in fuel-oil 

requirement. 

Examples of additional control alternatives to be considered for SO2 BART for each 

emission unit include the applicability of using progressively lower sulfur oils below 0.3 

percent sulfur content (e.g., #2 distillate oils of 0.0015%, 0.05% sulfur content). The 

associated costs should be examined for each alternative. This would show a cost 

gradient as the sulfur in oil decreases and selection of BART would be based on the 

alternative presenting the most control where the cost remains reasonable. Dispersion 

modeling for a unit should also determine visibility impacts of that given unit on Class I 

areas for each viable fuel-oil alternative. In addition, the costs and visibility impacts of 

wet or dry flue gas desulphurization (FGD) techniques should be considered. Retrofit 

FGD systems can result in 90% - 95% reductions. FGD is a well-demonstrated 

technology on oil-fired utility units in some other countries (e.g., Japan, South Korea and 

Cyprus). 

The full five-factor SO2 BART determinations described above should be performed for 

the facilities at Middleton Power Units 3 and 4, Montville Power Unit 6, PSEG 

Bridgeport Harbor Station Unit 3, and PSEG New Haven Harbor Station Unit 1. 

Once again CDEP is commended for its past efforts in implementing the ozone 

reasonably available control technology (RACT) provisions in the 1990s and NOx Budget 

Program for the NOx SIP Call to significantly reduce NOx emission limits. Using the 

same line of reasoning as discussed above for SO2, it is incumbent on CDEP to use a 

baseline emissions year (presumably 2001) and examine NOx BART control alternatives 

for each BART-eligible source. 

Even though the EPA BART Guidelines state that combustion control is “generally 

highly cost-effective and should be considered”3

 in a BART determination for oil-fired 

boilers, combustion controls are not a de facto BART standard. Alternative NOx controls 

to achieve BART should be considered at each BART-eligible source to complete the full 

five-factor analysis. Oil-fired utility boilers have a variety of combustion controls 

available, such as, low excess air, low NOx burners, over-fired air, flue gas recirculation 

and optimum staged combustion. Also, post-combustion alternatives such as Selective 

Non-Catalytic Reduction (SNCR) and Selective Catalytic Reduction (SCR) should be 

considered at facilities where they do not currently exist. 

3

 Ibid, See Section IV.E.5. 
Regarding particulate matter (PM) controls at BART-eligible facilities, Table 9-16 

presents cost ranges for installing electrostatic precipitators (ESP) on sources not 

currently controlled for PM. More documentation of these costs is necessary as provided 

in the EPA BART Guidelines which state, “The basis for equipment cost estimates also 

should be documented, either with data supplied by an equipment vendor (i.e., budget 

estimates or bids) or by a referenced source (such as the OAQPS Control Cost 

Manual...).4

 In order to maintain and improve consistency, cost estimates should be 

based on the OAQPS Control Cost Manual, where possible. The Control Cost Manual 

addresses most control technologies in sufficient detail for a BART analysis.”5

 Of course, 

the astronomical costs per ton ($64,000 at a minimum) of emissions reduced according to 

the amounts presented would make such and installation uneconomical. 

For the ESPs currently operating CDEP should analyze cost-effective ESP upgrade 

alternatives as per the EPA BART Guidelines, “. . . for retrofitting existing sources in 

addressing BART, you should consider ways to improve the performance of existing 

control devices, particularly when a control device is not achieving the level of control 

that other similar sources are achieving in practice with the same device. For example, 

you should consider requiring those sources with electrostatic precipitators (ESPs) 

performing below currently achievable levels to improve their performance.”6

CDEP determined that two BART-eligible facilities (Norwalk Power Unit 2 and 

Cascades Boxboard Group) had a de minimis impact of less than 0.1 deciview on the 

nearest Class I area, so as to not be subject to BART. The NESCAUM exemption 

modeling that documents these conclusions should be included in the SIP as an appendix. 

4

 U. S. Environmental Protection Agency, Office of Air Quality Planning and Standards, OAQPS Control 

Cost Manual, Fifth Edition, February 1996, EPA 453/B-96-001. 

 

5

 See 40 CFR Part 51, Appendix Y. The U.S. Environmental Protection Agency finalized it’s BART 

Guidelines on June 15, 2005, and published the preamble and final rule text in the Federal Register on 

July 6, 2005. The rulemaking action added Appendix Y to Part 51, titled “Guidelines for BART 

Determinations Under the Regional Haze Rule.” See Section IV.D.4.Step 4.a.5.

6

 Ibid, See Section IV.D.3.Step 3.4.
United States 

Department of 

Agriculture

Forest 

Service 

Eastern Region 626 E. Wisconsin 

Suite 800 

Milwaukee, WI 53202

 Caring for the Land and Serving People Printed on Recycled Paper 

File Code: 2580 

Date: April 8, 2009 

 

Ms. Anne Gobin 

Chief, Bureau of Air Management 

Connecticut Department of Environmental Protection 

79 Elm Street 

Hartford, CT 06106 

Dear Ms. Gobin: 

This letter is in response to the Connecticut Draft Regional Haze State Implementation Plan 

(SIP) dated February 4, 2009, which was submitted to the Federal Land Managers for review. 

Since you represent the responsible agency, we are providing our technical review comments 

(Enclosure 1) to you which focus on the eight content areas outlined in our October 13, 2006, 

letter to you (Enclosure 2). 

We now have a new Air Resource Management Team available to work with you and your staff 

on all air resource issues that are of concern to the Forest Service’s Eastern Region. Please add 

the Air Resources Specialist for Connecticut, Ralph Perron, rperron@fs.fed.us (802) 222-1444 to 

your Federal Land Manager list. Consultation and collaboration with our Agency, as required in 

the Code of Federal Regulations (CFR), can be maintained through Mr. Perron. 

We look forward to working with you to improve air quality values, including progress towards 

the visibility goal set by Congress for our Class I areas. In spite of our legal involvement in this 

process, please be aware that only the United States Environmental Protection Agency can make 

a determination about the document's completeness and provide final approval. 

We would appreciate a response regarding our comments per Section 51.308(i)(3) of the CFR. 

Please contact Mr. Perron if you have technical questions about the substance of our comments. 

Sincerely, 

/s/ Lee Nightingale (for) 

KENT P. CONNAUGHTON 

Regional Forester 

Enclosures (2) 

cc: Ralph Perron, Meg Mitchell, Tom Wagner, Richard Gillam 
1

Enclosure 1 

USDA Forest Service Comments Regarding 

Connecticut Draft Regional Haze Rule State Implementation Plan (SIP) 

The air program staff of the U.S. Forest Service has reviewed the Connecticut Draft Regional 

Haze State Implementation Plan (SIP) dated February 4, 2009, and has developed the comments 

listed below. We look forward to the Connecticut Department of Environmental Protection 

response to these comments, as required in the Code of Federal Regulations (CFR) per section 40 

CFR 51.308(i)(3). For further information regarding these comments, please contact Ralph 

Perron at (802) 222-1444 (rperron@fs.fed.us) or Rick Gillam at (404) 347-5058 

(rgillam@fs.fed.us). The comments below are categorized by the emphasis areas outlined in our 

letter to Ms. Anne Gobin dated October, 13, 2006, included as Enclosure 2. That letter discussed 

our perspectives relevant to Regional Haze SIP preparation. 

Overall Comments:

We are interested in the Connecticut Regional Haze SIP because analyses conducted by MANEVU have shown that air emissions sources located in Connecticut affect visibility in Forest 

Service Class I areas in the states of Vermont, New Hampshire, and West Virginia (see Table 2.1 

of Draft SIP and Attachment B – MANE-VU Contribution Assessment). Overall, Connecticut 

has done a commendable job compiling the Regional Haze SIP and addressing the requirements 

of the Regional Haze Rule. The following sections provide our comments related to specific 

sections of the Draft SIP. 

Specific Comments: 

Natural Condition and Uniform Rate (Section 4 of Draft CT RH SIP) 

 No comments. 

Emission Inventories (Section 6 of Draft CT RH SIP) 

 The discussion of emissions inventories is generic and only explains the work done by 

MANE-VU and NESCAUM. This section should include additional discussion of how 

the Connecticut specific emissions (presented in Tables 6.1 & 6.2) were generated. 

 We would like Connecticut to commit to tracking emissions annually and reporting how 

the projected emissions compare to actual emissions in the mid-course review due in 

2012 and required SIP revision due in 2018. 

Area of Influence (Section 2 of Draft CT RH SIP) 

 The discussion regarding Connecticut’s contribution to visibility impairment at other 

States’ Class I areas in Section 2 of the Draft SIP is brief. Section 8.2 of the Draft SIP 

provides additional information on Connecticut’s contribution to sulfate impacts. It is 

suggested that additional discussion be added to Section 2, including a reference to 

Section 8.2. 
2

Reasonable Progress Goals and Long Term Strategy (Sections 10 and 11 of Draft CT RH SIP) 

 Since Connecticut has no Class I areas, it is acceptable to state that Connecticut agrees 

with the reasonable progress goals established by the States of Maine, New Hampshire, 

Vermont and New Jersey for their Class I areas. Even though the impacts are minimal, 

this section should also, at least, recognize that emissions from Connecticut sources 

impact Class I areas in West Virginia and Virginia as well. 

 Section 11.5 of the Draft SIP discusses source retirement and replacement schedules and 

refers to Table B-5 in Attachment N for specific sources. Table B-5 in Attachment N 

does not specifically identify Connecticut sources that have been shutdown – it appears to 

list all sources in the MANE-VU region. A table identifying specific sources in 

Connecticut that have shut down should be added to Section 11.5. Are there any other 

sources that are planning to shut down before 2018? If information is available for any 

other sources that are expected to shut down before 2018, it should also be discussed in 

this section. 

Wildland Fire (Section 11.7 of Draft CT RH SIP) 

 We agree that based on existing inventories of smoke emissions from wildfires and 

prescribed fires, they are not a significant emission source for Connecticut or a significant 

contributor to regional haze in downwind Class I areas at this time. It would be helpful to 

add a reference to the specific sections in Attachment V which support this claim. Also, 

we request that Connecticut commit to track smoke emissions in the future to help 

determine the level of contribution for future planning periods. 

Regional Consistency (Section 3 of Draft CT RH SIP) 

 No comments. 

Verification and Contingencies 

 No comments. 

Coordination and Consultation (Section 3 of Draft CT RH SIP) 

 No comments. 

Best Available Retrofit Technology (BART) (Section 9 of Draft CT RH SIP) 

 No comments. 

Additional Suggestions:

 Section 5 discusses the monitoring strategy being used to assess visibility conditions. 

Even though Connecticut does not have any Class I areas, this section demonstrates the 

importance of continued operation of the IMPROVE monitoring network. We ask that 

Connecticut add a statement expressing their support for continued operation of the 

IMPROVE network. 

 In Sections 7.1 and 7.3, brief discussions of model performance would be helpful. 
United States 

Department of 

Agriculture

Forest 

Service 

Eastern Region 626 E. Wisconsin 

Suite 800 

Milwaukee, WI 53202

 Caring for the Land and Serving People Printed on Recycled Paper 

File Code: 2580-2 

Date: October 13, 2006 

 

Ms. Anne Gobin 

Director, Bureau of Air Management 

Connecticut Department of Environmental Protection 

79 Elm Street 

Hartford, CT 06106-5127 

Dear Ms. Gobin: 

Over the past several years, members of both our staff and yours have participated with neighboring 

states and tribes in the Central States Regional Air Partnership to develop best approaches and tools 

for preparing plans that will reduce haze in Class I areas. With preparation of your Regional Haze 

State Implementation Plan (SIP) at hand, we want to focus on collaboration with you and your staff 

to ensure success. As you know, consultation with you is required in the Regional Haze Rule 

(RHR). This is a priority for our air program. 

Our focus will be on Class I wildernesses, which the United States Department of Agriculture 

(USDA) Forest Service (FS) is responsible for. We are coordinating with the other Class I area 

managers, the National Park Service, and the US Fish and Wildlife Service to facilitate a common 

message from all federal land managers (FLM). We anticipate leveraging strengths of each FLM to 

our joint advantage. Since the FLM will be seeking a close working relationship with every state in 

this SIP writing process, the expectation is to share ideas from across the nation. The objective of 

every SIP is to play a critical role in a national emissions reduction plan. 

Enclosed are detailed perspectives pertinent to the SIP preparation. Any comments or questions 

should be directed to Ann Acheson, the principal FS point of contact, at (740) 373-9055 ext. 23 or 

aacheson@fs.fed.us. She will consult on your SIP throughout the required 60-day comment period, 

sharing our best insights and recommendations. Ann will also work with others on our staff, 

especially our National Haze Coordinator, Ann Mebane and the Department of Interior. Ann can be 

contacted at (307) 587-4597 or amebane@fs.fed.us. 

As required in the RHR, please identify, at your earliest convenience, your key point(s) of contact. 

Send all correspondence electronically to both Ann Acheson and Ann Mebane to ensure a 

successful consultation and SIP. 

Sincerely, 

/s/ Forrest L. Starkey (for) 

RANDY MOORE 

Regional Forester 

Enclosure 
Enclosure 1 

Subject: Connecticut and Regional Haze Rule Consultation with the United States Department of 

Agriculture (USDA) Forest Service (FS) 

September 2006 

The following perspectives are merely suggestions or recommendations not direction or 

requirements. They are deliberately very similar to those prepared by the Department of Interior to 

contribute to a common sense of purpose for improving haze in all Class I areas. We are sending 

these perspectives to each state. In so doing, we hope to facilitate inter-state coordination. At the 

same time, we fully acknowledge the discretion afforded in the Regional Haze Rule (RHR) for 

unique and creative solutions by individual states in writing plans that reduce haze. 

Natural Condition and Uniform Rate 

These factors apply mainly to states that have Class I areas. Other states that contribute to visibility 

impairment in Class I areas located in a different state might consider including discussion and 

conclusions on these factors in their individual plans. 

The basic calculation of baseline, natural condition, and uniform rate builds the foundation for the 

entire RHR State Implementation Plan (SIP) process. Considerable discussion and debate at the 

science and policy level has occurred regarding appropriate methods to be used. As a consequence, 

several equations that include varying parameters or multipliers are available. Because these 

calculations can have a significant effect on the resulting progress goal, it is important to provide a 

detailed description of the methods used in the SIP. Calculations that include only portions of 

established methods or utilize unique approaches will be better understood if the rationale for these 

differences is fully explained in the SIP or its supporting documentation. We encourage states to 

use calculations that are based on equations recommended by the Interagency Monitoring of 

Protected Visual Environments (IMPROVE) steering committee and that are consistent with 

recommended approaches from the pertinent Regional Planning Organization (RPO) and the 

Environmental Protection Agency (EPA) region. 

Emission Inventories 

Given the complexities associated with modern comprehensive emission inventories, spending 

some considerable effort in describing how these inventories were developed and used will be 

important. Emission descriptions will be most informative if they include an evolutionary 

discussion that includes an actual, base-year inventory used to evaluate model performance; a 

typical base-year inventory that represents the five year, average state which establishes modeled 

visibility impacts; and various future year, controlled inventories that demonstrate future visibility 

conditions. Consider adding future year inventories that are clearly partitioned to delineate source 

types (by text, charts, or graphics) that are included in each model simulation. Benefits to future 

visibility conditions suggested in the SIP that are not also clearly linked to a future inventory or are 

not clearly included in future model analysis, will warrant additional discussion. 

One part of your emission inventory includes the implementation of “Best Available Retrofit 

Technology” (BART) on a subset of pre-Prevention of Significant Deterioration sources. The 

BART source identification, elimination, and level determination will be of particular interest for 

review. We would prefer to see a clear progression through the three basic BART phases and a 

thorough description of the RHR prescribed factor analysis (if applicable). Consider discussing 

whether BART levels apply to individual or grouped source categories. 
Area of Influence 

The area of influence of significant visibility-impairing sources is an important SIP element. We 

suggest that that each state clearly identify and apportion by state, or other geographic means, the 

significant levels of pollutants contributed to each Class I area by source. Developing this 

information together with neighboring States and Tribes will facilitate consistency. Discussions of 

changing source area contributions at both the base- and future-year levels will help demonstrate 

SIP progress. Consider the benefits of presenting this information in the form of transported mass 

by pollutant or through individually calculated visibility impairment measures. Using a percentage 

or “Top 10” ranking for current contributions by geographic area may or may not clearly describe 

progress over time. 

Reasonable Progress Goals and Long Term Strategy

Establishing reasonable progress goals for Class I areas in your state and/or acknowledging 

reasonable progress goals for Class I areas in other states that are affected by emissions from your 

state, as well as defining associated emissions strategies to meet these goals, form the basis of the 

SIP process under the RHR. 

In developing the statute’s required Long Term Strategy (LTS), your state is offered broad 

flexibility when determining reasonable progress goals and associated emissions. As noted earlier, 

the RHR includes a requirement for states to assess a uniform rate of progress and compare that rate 

to the reasonable progress goals set by those states with Class I areas. We feel that this uniform rate 

of progress assessment is useful in determining the geographic and economic extent a state can 

consider when developing the LTS associated with the reasonable progress goals. 

In general, we will be looking at the degree to which the LTS is supported by RPO technical work 

and at the level of consistency among the contributing states. For Class I areas where your state is 

setting a year 2018 reasonable progress goal of equal or less impairment compared to the uniform 

rate of progress, our review will focus holistically on (1) whether strategies are applied equitably 

across source types; (2) if both local and regional emission strategies have been fully examined; and 

(3) how consistent assessments and strategies are applied regionally. 

For Class I areas where the reasonable progress goal is more impaired than the uniform rate of 

progress, consider presenting information on a component basis. Components could consist of 

emission source category as before, but also include contributions from individual pollutants or by 

geographic source area. Our intent is to better understand where and why a strategy falls short of 

the uniform progress rate goal. 

Because each region has focused their emission control strategy on different conditions, presenting 

results in a component format may assist in showing what level of progress was made in the focus 

area, verses other less controllable factors. 

Wildland Fire 

Your state has considerable flexibility as it addresses all anthropogenic sources of visibility 

impairment, including fire. The RHR requires consideration of smoke management techniques for 

agricultural and forestry management practices in the development of the LTS part of the SIP. On a 

short-term basis, fire has the potential to cause significant visibility reduction in Class I areas. If 

fire contributes to the index used to track long-term, reasonable progress in a Class I area, the 

visibility SIP should identify how it will be addressed. Your state may already have a smoke 

management program (SMP) that adequately describes how visibility impairment from fire will be 
addressed. If fire has been determined to contribute to visibility impairment, we suggest including a 

fire emissions inventory along with a comment about its reliability and a projection for changes to 

the future inventory. If your state has a SMP, is it a basic smoke management program or an 

enhanced smoke management plan? And has the SMP been certified by the Environmental 

Protection Agency (EPA) Interim Air Quality Policy on Wildland and Prescribed Fire? Identify the 

specific SMP requirements for minimizing visibility impairment in Class I areas. Are there 

differences in state regulation for the way in which smoke from agricultural burning and forest fires 

are treated? Is there a difference in the way emissions from wildfire, prescribed fire, and wildlandfire-use (WFU) fire are identified and treated on private, state, and federal lands? 

Regional Consistency 

The RPOs have been working toward regionally-consistent approaches to address visibility 

impairment throughout the SIP development process. There may be circumstances when different 

methods were used or impairment assessments reached different conclusions. The FLM 

understands that each state knows what emission control methods or air quality management 

strategies work best for its areas. Each state may wish to develop strategies that are independent 

from RPO or neighboring areas. 

In this context, our review of “regional consistency” will have less to do with individual discretion 

each state has in making decisions, and more on how well a group of states identifies and addresses 

similar agreed upon goals for each Class I area within a common area of influence. 

Regional consistency can also be difficult to evaluate if neighboring SIPs (or portions of SIPs) are 

released for review at different times. We expect that thorough inter-state consultation processes 

will lead to consistent descriptions of apportionment and emission control goals, thus resulting in 

development of similar progress goals, regardless of release dates. 

Verification and Contingencies 

Little emphasis has been placed in the RHR on verification and even less on contingency planning. 

By rule, each SIP must identify the monitoring data used to specify the original baseline and also as 

part of an ongoing progress review at five year intervals. 

Given the uncertain future of any individual monitoring site, we suggest that the SIP address the 

representation of both primary and alternative data sites for each Class I area. 

Consider not only the data necessary to measure progress, but also how to account for and mitigate 

both unexpected and reasonably foreseeable emissions growth, changes to the geographic 

distribution of emissions, and substantive errors that may be found in emission inventories or other 

technical bases of the SIPs. These factors, as well as other unanticipated circumstances, may 

adversely affect your state’s ability to achieve the emissions reductions projected by the SIP. 

Considering these factors through adaptive management or continual review strategies may assist in 

avoiding these circumstances. 

Coordination and Consultation 

The 1999 RHR requires states to consult with the FLM agencies at least 60 days prior to holding 

any public hearing on a RHR, SIP, or SIP revision (40 CFR 51.308(i). As named in the cover letter 

to this enclosure, a single FS air specialist has been assigned to your state. 
Federal Land Manager (FLM)/ CTDEP Regional Haze State Implementation Plan (SIP) Consultation

(3/18/09)

Conference Call Participants

Holly Salazer – National Park Service

Bruce Polkowsky – National Park Service

Don Shephard

Pat Brewer – National Park Service

Scott Copeland‐ US Forest Service

Tim Allen – US Fish & Wildlife Service

Anne McWilliams‐ EPA Region I

Anne Arnold‐ EPA Region I

Dave Wackter – CTDEP

Wendy Jacobs –CTDEP

Paul Bodner‐CTDEP

Susan Amarello‐CTDEP

Ric Pirolli‐CTDEP

Holly:  These are the National Park Service and US Fish & Wildlife Service preliminary comments.  The US

Forest Service does not have preliminary comments but will send in final comments before the 60 day

clock is over (April 6).   

Regarding the MANE‐VU ask and what the state is committing to with respect to the ask, there are

contradictory statements in the SIP.  CT needs to take ownership and say what actions the state will,

may, or will not take and why.  Bruce:  This comment was a pretty uniform concern across the MANE‐VU

states.   You need to say here are our sources and here’s what will happen.  Here is a list of regulations

in place and here are the affected sources.  Here are projected emissions.  At the 5 year review say this

is what actually happened.  They need as much detail as we can describe.  They want us to include a

timetable so the FLMs can look at that when they review SIP.

Move information about CT contributions as compared with other states in Section 8 to Section 2 as well

so it’s right up front.  Tim:  For 2002 emission totals, show apportionment by dv.  Provide 2018

apportionment to visibility.  Abandon showing %.  Not sure if the dv information is in the technical

document.  Pat:  There is MANE‐VU modeling work in the Contribution Assessment that includes

information beyond %.  

The SIP has to be clear about uncertainty regarding achieving reasonable progress goals.  Section 10

talks about a four factor analysis.

Monitoring Strategy (Section 5) – FLMs want states to say that they support IMPROVE network with

funding.  They are talking about the IMPROVE network in Class I areas.  Dave:  We could encourage EPA

to continue funding and say that we will continue to work with other states and the FLMs to continue

the network if EPA funding goes away.

Source Retirement (Section 11.5) – Talk about uncertainty of units shutting down.  Commit to talking

about units that have shut down in 5 year review.  Could include small NSR discussion.  There is a linkage

between PSD/NSR.  Although we want a 20% reduction on the worst days, we also want reductions on

the best days.
FLM Consultation conference call 3/18/09

2

Section 11.9 – What inventory was used to get to the modeled results in 2018?  CTDEP should identify

the strategies they expect to have in place to reduce emissions to these levels by 2018.

Section 11.12 – Importance of the PSD NSR program.  The FLM statement was more of an affirmatory

comment.  We don’t need to do anything to address that comment.  That was for their checklist

purposes (to indicate that we included that in our SIP).  

Smoke Management – Is it a voluntary program?  Does CTDEP work with the Forestry Division on it?  

The FLMs need more information summarizing the program.  CTDEP could explain how CGS 22a‐174(f)

came about and what it prohibits.  We should say if Class I areas are not included as sensitive receptors.  

Organic carbon is the second largest contributor to regional haze, but the states don’t really do anything

about it.  CTDEP could say that emissions are minimal and not expected to grow.

BART

CTDEP asserts that the alternative program vs. case‐by‐case determination is preferable.  EPA’s BART

guideline recommendations and MANE‐VU’s presumptive levels are not necessarily BART until an

analysis is conducted.  There is a lack of a 5 factor analysis.  In going through the pollutant by pollutant

description, it makes it clear that we’re not doing a case‐by‐case review.  CTDEP should describe on a

source‐by‐source basis existing and possible controls at each facility.  You can’t stop at saying that

MANE‐VU’s and EPA’s levels are BART.  CTDEP should talk about the 5 factors as they apply to individual

sources.  CTDEP should provide a summary of what each facility has done and what each facility could

have done.  FLMs want numbers in $/ton or $/dv instead of $/year.  For this company, NESCAUM

modeling found this impact.  Incorporate more specific 5 factor discussion.  For PM, show that it’s not

cost‐effective.  MD used their Healthy Air Act.  MD included a comparison about what plants could do.  

Anne Arnold – I’m confused about Tim not calling what CT is doing an alternative plan.  EPA interprets

what CT is doing as an alternative plan.  Anne McWilliams reads language in 40 CFR 51.308(e)(2)(i)(C)

about source specific and category wide information, as appropriate, being acceptable.  Dave talks

about extremely high electric rates in CT and how several of the BART‐eligible facilities will likely be

shutting down in a few years.  Anne McWilliams – The NH SIP includes categories of units.  The FLMs

think we should say a little bit about site specific information.  Tim:  The FLMs will add some additional

paragraphs to their preliminary comments.  Tim thinks that we are further along (closer to where we

need to be) than the preliminary comments would indicate.   

Future schedules      

We are already at 40 days on the clock.  There are two options:  1) CTDEP can stop the clock, take the

FLM preliminary comments, revise SIP, and provide the FLMs with another draft SIP before receiving

formal FLM comments or 2) FLMs can proceed as is and submit formal comments before the clock ends.  

Dave suggested the second option because we want to get our SIP in as soon as possible and we can

deal with additional comments through the hearing public comment process.

Tim:  If Region I is willing to accept a generic BART discussion, another option is to get rid of the case by

case headings (Table 9‐4 categorical substitute of alternative program for case‐by‐case reference and

other case‐by‐case references) and not go with the case‐by‐case discussions.  The FLMs encourage case‐

by‐case review though.   

EPA will also provide written comments during the first week of April.
 

Description of Environmental Protection Agency (EPA) Comments on Connecticut’s Draft 

Regional Haze State Implementation Plan (SIP) and Connecticut Department of Environmental 

Protection (CTDEP) Responses

CTDEP appreciates the time and effort put forth by EPA in the development of their comments 

on the Draft Regional Haze SIP. CTDEP looks forward to continuing the work with EPA, 

Federal Land Managers and other interested stakeholders to develop an approvable regional haze 

SIP for the State of Connecticut. CTDEP also looks forward to continuing the consultative 

process as we move forward regionally in addressing regional haze. 

Chapter 1: The Regional Haze Issue

Comment

Paragraph four on page 1-1 should be revised as follows: 

 “The Regional Haze Rule calls for each state to establish reasonable progress goals for 

visibility improvement and to formulate a long-term strategy for meeting these goals.” 

Response

CTDEP has revised paragraph four on page 1-1 in accordance with the comment. 

Comment

On page 1-5, Connecticut states, “On the worst 20 percent days, visibility impairment in 

Northeast and Mid-Atlantic Class I areas ranges from about 25 to 30 dv (deciviews).” This 

statement is inconsistent with the data presented later in Table 4.2 in Section 4.2. The table lists 

the baseline 20% worst visibility for MANE-VU Class I areas as 21.7 to 29.0 dv. In addition, in 

the page 1-5 discussion, it would be helpful to include the visibility range in miles in order to 

give the reader a better frame of reference. 

Response

CTDEP has revised the sentence “On the worst 20 percent of days, visibility impairment in 

Northeast and Mid-Atlantic Class I areas ranges from about 25 to 30 dv.” on page 1-5 as follows: 

“On the worst 20 percent of days, visibility impairment in Northeast and Mid-Atlantic Class I areas 

ranges from 21.4 to 29 dv (a visual range of about 30 to 14 miles).” 

Comment

Paragraph four on page 1-6 should be revised as follows: 

 “...about half of the worst visibility days in the New Hampshire Class I Areas occur in the 

summer when meteorological conditions are more conducive to the formation of sulfate from 

SO2 and to the oxidation of organic aerosols. In addition, winter and summer transport 

patterns are different, possibly leading to different contributions from upwind source 

regions. As a result, The remaining worst visibility days are divided nearly equally among 

spring, winter and fall. In addition, winter and summer transport patterns are different, 

possibly leading to different contributions from upwind source regions.”

Response

CTDEP has revised paragraph four on page 1-6 in accordance with the comment. 

Chapter 6, Emissions Inventory
Description of EPA Comments and CTDEP Responses 7/15/09 2 

Comment

Table 6.1 indicates that EGU Point SO2 emissions were 2,438 tons in 2002. Table 6.2 indicates 

that EGU Point SO2 emissions in 2018 are expected to be 6,697 tons. Connecticut should 

explain why SO2 emissions are expected to increase so significantly. 

Response

The EGU Point and non-EGU Point SO2 emissions in Table 6.1 were inadvertently reversed. 

The EGU Point SO2 emissions in Table 6.1 should be 13,550 tons and the non-EGU Point SO2

emissions in Table 6.1 should be 2,438 tons. CTDEP has corrected the tables. 

 

Chapter 8: Understanding the Sources of Haze-Causing Pollutants

Comment

The reference cited for Figure 8.11 appears inaccurate. Please correct this reference. 

Response

CTDEP has changed the (EPA, 2005) reference in Section 8.3.1, Sulfur Dioxide (SO2) to 

(MARAMA, 2005). 

Comment

In the second paragraph of Section 8.3.1, Connecticut states, “Most states in the region showed 

declines in annual SO2 emissions through 2002 compared with those previous inventories.” 

Connecticut should include the data that support this statement, refer to another document that 

contains the supporting data, or remove the statement. 

Response

CTDEP has reorganized and revised the text after the first paragraph in Section 8.3.1, Sulfur 

Dioxide (SO2) as follows: 

“Figure 8.11 shows SO2 emissions in the MANE-VU states as extracted from the 2002 MANEVU inventory (MARAMA, 2005). 
Description of EPA Comments and CTDEP Responses 7/15/09 3 

Figure 8.11:  Annual Sulfur Dioxide (SO2) Emissions, by State

0.0

0.2

0.4

0.6

0.8

1.0

1.2

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

MV 2002 v.3

The bar graph in Figure 8.12 displays the percentage contributions from different emission 

source categories to annual SO2 emissions in the MANE-VU states in 2002. The chart shows 

that point sources – consisting mainly of stationary combustion sources for generating electricity, 

industrial power, and heat – dominate SO2 emissions in the region. 
Description of EPA Comments and CTDEP Responses 7/15/09 4 

Figure 8.12:  2002 Sulfur Dioxide (SO2) Emissions, by State

Bar Graph = Percentage Fractions of Four Source Categories

Line Graph = Total Annual Emissions (106 tpy)

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.0

0.2

0.4

0.6

0.8

1.0

1.2

million t/y

AREA NONROAD ONROAD POINT Emission

As can be seen in Table 8.2 (EPA NEI database, 2008), most states in the region showed declines 

in annual SO2 emissions through 2002 compared with those from previous inventories. 

Table 8.2    MANE‐VU 1990, 1996 and 2002 SO2 Point Source Emissions (tpy)

CT DC DE ME MD MA NH NJ NY PA RI VT

1990 70,845 5,123 88,450 70,086 314,157 256,593 76,597 155,021 654,256 1,377,470 3,899 1,050

1996 44,055 1,717 83,836 28,128 275,360 121,119 58,605 133,862 404,465 1,156,280 2,664 2,117

2002 16,027 2,057 74,447 22,915 291,009 105,966 46,579 61,229 297,113 995,869 2,653 911

  

This decline can be attributed in part to implementation of Phase 2 of the Acid Rain Program, 

which in 2000 further reduced allowable emissions below Phase I levels and extended emission 

limits to a greater number of power plants. 
Description of EPA Comments and CTDEP Responses 7/15/09 5 

Smaller stationary combustion sources, referred to collectively as area sources, are another 

important source category in the MANE-VU states. These include smaller industrial, 

commercial, and institutional boilers as well as residential heating sources. By contrast, on-road 

and non-road mobile sources make a relatively minor contribution to overall SO2 emissions in 

the region (NESCAUM, 2001a).” 

Chapter 9: Best Available Retrofit Technology (BART)

Comment

In Section 9.2.3, Connecticut should include a discussion of the available controls for each 

source category and the determination of the BART control level benchmark. 

Response

Regarding a discussion of the available controls for each source category, CTDEP has added the 

following language to Section 9.2.3, Determination of what BART is for each source subject to 

BART: 

“The following discussions describe the currently available NOx, SO2 and PM control 

technologies for EGUs and Industrial Boilers, the EPA Guideline for BART Determinations, and 

the MANE-VU BART Workgroup recommended emission limits for NOx, SO2 and PM. 

 

Currently available control technologies for EGUs and Industrial Boilers

NOx

Firing Configurations and Firing Practices 

Firing configuration and firing practices can result in a 5 to 60% reduction in NOx formation. 

Firing configuration is a design characteristic of the boiler. Firing practices include such things 

as low excess air, flue-gas recirculation, staged combustion, reduced air preheat, low NOx 

burners, and fuel substitution/alteration. 

Operating at low excess air involves reducing the amount of combustion air to the lowest 

possible level while maintaining efficient and environmentally compliant boiler operation. NOx 

formation is inhibited because less oxygen is available in the combustion zone. These methods 

may change the normal operation of the boiler and the effectiveness is boiler-specific. 

Implementation of these techniques may also reduce operational flexibility; however, they may 

reduce NOx by 10 to 20% from uncontrolled levels. 

Flue-gas recirculation involves reinserting a portion of the flue-gas into the combustion chamber. 

The reduced oxygen content of the reused air will inhibit the production of NOx. 

Staged combustion involves a fuel-rich combustion zone, followed by a secondary combustion 

zone in which excess air is introduced. 

Reduced air preheat involves bypassing the combustion air preheater and thus lowering the 

combustion temperature and reducing the formation of thermal NOx. 
Description of EPA Comments and CTDEP Responses 7/15/09 6 

Low NOx burners are designed to control fuel/air mixing and increase heat dissipation. These 

alternative burners can be installed on new boilers or retrofitted on older units. Low NOx 

burners have been shown to reduce NOx formation by 35-55%. 

Fuel substitution requires burning fuel with a lower nitrogen content to inhibit the production of 

fuel NOx. The lower the content of nitrogen in a fuel, the lower the resultant NOx emissions 

will be. 

Overfire Air 

Overfire air involves injecting a portion of the total combustion air above the burners. Overfire 

air limits NOx by (1) suppressing thermal NOx by partially delaying an extending the 

combustion process resulting in less intense combustion and cooler flame temperatures; (2) a 

reduced flame temperature that limits thermal NOx formation, and/or (3) a reduced residence 

time at peak temperature which also limits thermal NOx formation. Overfire air can reduce NOx 

emissions by 20-30%. 

Water/Steam Injection 

Water or steam can be injected into the boiler combustion zone to reduce the peak flame 

temperature. The lower temperature results in a lower rate of formation of thermal NOx. 

Selective Non-Catalytic Reduction (SNCR) 

SNCR is a post-combustion technique that involves injecting ammonia or urea into specific 

temperature zones in the upper furnace or convective pass. The ammonia or urea reacts with 

NOx in the flue gas to produce nitrogen and water. The effectiveness of SNCR depends on the 

temperature where reagents are injected; mixing of the reagent in the flue gas; residence time of 

the reagent within the required temperature window; ratio of reagent to NOx; and the sulfur 

content of the fuel that may create sulfur compounds that deposit in downstream equipment. 

There is not as much commercial experience to base effectiveness on a wide range of boiler 

types; however, in limited applications, NOx reductions of 35 to 60% have been achieved. 

Selective Catalytic Reduction (SCR) 

SCR is another post-combustion technique that involves injecting ammonia into the flue gas in 

the presence of a catalyst to reduce NOx to nitrogen and water. The SCR reactor can be located 

at various positions in the process including before an air heater and particulate control device, or 

downstream of the air heater, particulate control device, and flue gas desulfurization systems. 

The performance of SCR is influenced by flue gas temperature, fuel sulfur content, ammonia-toNOx ratio, inlet NOx concentration, space velocity, and catalyst condition. NOx emission 

reductions of 75 to 90% have been achieved through the use of SCR on oil-fired boilers 

operating in the U.S. 

SO2 

Wet Flue Gas Desulphurization (FGD) 

FGD processes use an alkaline reagent to absorb SO2 in the flue gas and produce a sodium or a 

calcium sulfate compound. These solid sulfate compounds are then removed in downstream 
Description of EPA Comments and CTDEP Responses 7/15/09 7 

equipment. Wet regenerable, meaning the reagent material can be treated and reused, FGD 

processes are attractive because they have the potential for better than 95% sulfur removal 

efficiency, have minimal waste water discharges, and produce a saleable sulfur product. Some 

of the current nonregenerable calcium-based processes can, however, produce a saleable gypsum 

product. 

To date, wet systems are the most commonly applied. Wet systems generally use alkali slurries 

as the SO2 absorbent medium and can be designed to remove greater than 95% of the incoming 

SO2. Lime/limestone scrubbers, sodium scrubbers, and dual alkali scrubbing are among the 

commercially proven wet FGD systems. 

Low-Sulfur Fuels 

SO2 emissions are directly related to the sulfur content of the fuel burned. Reducing the amount 

of sulfur in the fuel will reduce SO2 emissions. The low-sulfur coal may be naturally occurring 

or the result of coal cleaning. 

PM

Mechanical Collectors 

Mechanical collectors, such as cyclones, are typically effective at collecting large particles. 

Smaller particles typically escape the cyclone along with the gases. Cyclones are best used in 

conjunction with other pollution control equipment. The collection efficiency for larger 

particulate matter (PM greater than 10 microns) typically runs around 85%. 

Electrostatic Precipitators (ESPs) 

When particle-laden gases pass through an ESP, the particles become charged. An electric field 

then acts on the particles and forces them to the sides of the precipitator. The particles can then 

be collected by washing the sides of the precipitator or knocking it so that the particles fall down 

into a collector. Existing ESPs are typically 40 to 60% efficient. New or rebuilt ESPs can 

achieve collection efficiencies of more than 99%. 

Fabric Filters 

Fabric filtration, or baghouses, incorporates multiple fabric bags/filters inside a structure. The 

particulate removal efficiency of the fabric filter system is dependent on a variety of particle and 

operational characteristics including particle size distribution, particle cohesion characteristics, 

and particle electrical resistivity. Operational parameters that affect collection efficiency include 

air-to-cloth ratio, operating pressure loss, cleaning sequence, interval between cleaning, and 

cleaning intensity. The structure of the fabric filter, filter composition, and bag properties also 

affect collection efficiency. Collection efficiencies of baghouses may be more than 99%. 

Fuel Substitution 

Cleaner fuels will result in less PM emissions. 

Scrubbing Systems 
Description of EPA Comments and CTDEP Responses 7/15/09 8 

Scrubbing systems involve the injection of chemicals and/or water into the flue gas to inhibit the 

physical or chemical absorption of particles or gaseous pollutants. Scrubbing systems have been 

shown to reduce PM emissions by 50-60%.” 

Sections 9.2, 9.2.1, 9.2.2, 9.2.3 and 9.2.4 of Connecticut’s Regional Haze SIP encompass the 

discussion on the determination of the BART control level benchmark. 

Comment

In Section 9.3, Connecticut states, “During the last few years Connecticut has developed 

additional regulatory measures aimed at reducing emissions of SO2 and NOx from a large 

universe of in-state sources.” Connecticut should include more information regarding the 

universe of sources impacted by these additional regulatory measures. Specifically, Connecticut 

should emphasize the number and size of non-BART sources that are subject to these measures. 

Response

CTDEP has added a new table (9-4) to Section 9.3, Connecticut’s Alternative Measures (see 

Attachment 1). The table lists all of the Post-2002 NOx Budget Program sources that are 

collectively referenced in the SO2 and NOx programs for alternative BART discussed in Section 

9.3. The list includes the size of the unit. CTDEP has added text describing or referencing the 

table, including specific numbers of sources impacted, to Sections 9.3, 9.3.1 and 9.3.2 as follows: 

Section 9.3, Connecticut’s Alternative Measures (added following sentence to end of paragraph)

“Table 9-4 lists the Connecticut sources, including Connecticut’s seven BART-eligible sources 

(highlighted), that are addressed in the following discussions on Connecticut’s SO2 and NOx 

Programs for Alternative BART.” 

Section 9.3.1, Connecticut’s SO2 Program for Alternative BART 

Added following parentheses to end of first sentence:

“(the approximately 59 sources referenced in Table 9-4)” 

Added following parentheses to first sentence in summary of Tier 1:

“(all sources listed in Table 9-4)” 

Added following parentheses to first sentence in summary of Tier 2: 

“(30 boldfaced sources in Table 9-4)” 

Added following parentheses to first sentence in fifth paragraph in Summary of RCSA section 

22a-174-19a section: 

“(subject sources are listed in Table 9-4)” 

Section 9.3.2, Connecticut’s NOx Program for Alternative BART

Added following language to Summary of Revisions to RCSA sections 22a-174-22, 22a, 22b and 

22c section:

Added following phrase to parentheses in third sentence of second paragraph:

“sources listed in Table 9-4” 

Added following parentheses to second sentence of third paragraph: 

“(listed in Table 9-4)” 
Description of EPA Comments and CTDEP Responses 7/15/09 9 

Chapter 11, Long-Term Strategy

Comment

In the second paragraph of Section 11.4.2, Connecticut discusses possible logistical issues that 

may impact implementation of the low-sulfur oil strategy in the northern New England states. It 

is not clear why this discussion is included in Connecticut’s SIP. The DEP should either explain 

how this might be relevant to Connecticut’s ability to enact the MANE-VU low sulfur fuel oil 

strategy, or delete the discussion. 

Response

CTDEP has deleted the discussion referenced in Section 11.4.2, Low-Sulfur Oil Strategy. 

Comment

In the third paragraph of Section 11.4.2, Connecticut states that DEP will review the details of 

the low-sulfur fuel oil strategy in five years, “to ascertain that requiring the use of low-sulfur 

fuel remains viable for implementation by 2018.” This appears inconsistent with the MANE-VU 

“Ask” for the other (sic) zone which calls for #2 distillate oil to be reduced to 0.05 percent (500 

ppm) sulfur, by weight, by no later than 2014. 

Response

CTDEP has revised the second paragraph (formerly the third paragraph) of Section 11.4.2, LowSulfur Oil Strategy, as follows: 

“The MANE-VU states agree that a fuel sulfur content limit on residual oil and distillate 

oil is reasonable to pursue over the next ten years. CTDEP will review the details of this 

strategy in five years, coincident with Connecticut’s first regional haze SIP progress 

report. Section 16a-21a of the Connecticut General Statutes limits fuel sulfur content of 

heating distillate oil and off-road diesel oil to 500 ppm as of the date on which the last of 

the States New York, Massachusetts and Rhode Island limit the sulfur content of such 

fuels. Therefore, implementation of this strategy in Connecticut is dependent upon 

adjacent states’ implementation. CTDEP continues to participate in consultations with 

other MANE-VU states to develop a low sulfur heating strategy consistent with the 

MANE-VU “Ask”. 

Comment

In Section 11.5, EPA recommends that Connecticut include a table of any verified source 

retirements or replacements, rather than referring the reader to the attachments. 

Response

CTDEP has removed the reference to Table B-5 in Attachment N because Table B-5 does not 

contain any Connecticut sources. Based on modeling performed to support the development of 

an Integrated Resource Plan for the CT Department of Public Utility Control (CTDPUC), 

CTDEP strongly believes that under Connecticut’s new forward capacity market, several large 

electric generating units will simply become too expensive to operate, thus forcing their 

economic retirement. As a result, CTDEP has added the following language to Section 11.5: 

“While the output of the IPM model predicts that a certain number of older plants will be 

replaced by newer units to meet future electric growth and state-specific NOX and SO2 caps, 

Connecticut did not directly rely on the closure of any particular plant in establishing the 2018 

inventory upon which the reasonable progress goals were set. 
Description of EPA Comments and CTDEP Responses 7/15/09 10 

The modeling used to develop the 2018 emissions inventory appears to predict that several large 

EGUs in Connecticut, including five of the six BART-eligible EGUs (Middletown Power 3 & 4, 

Montville Power 6, Norwalk Power 2 and PSEG Power Connecticut New Haven Harbor 1) will 

retire by 2018. Table 11.1 shows two non BART-eligible EGUs in Connecticut that have retired 

since 2002.” 

Table 11.1     Retired EGUs

Unit Capacity (MW) Retirement Date

Devon 7 109 11/28/07

Devon 8 109 11/28/07

Comment

The Section 11.9 discussion on Connecticut’s share of emission reductions currently focuses on 

SO2 reductions. Connecticut should also summarize any additional programs the state plans to 

implement that will lead to visibility improvements. For example, does Connecticut plan to 

adopt a rule for outdoor wood boilers, as has been done by several New England states? 

Response

CTDEP has added the following two paragraphs to the end of Section 11.9, Connecticut’s Share 

of Emission Reductions: 

“In terms of additional programs leading to visibility improvements, CTDEP recognizes the 

increased use of wood burning devices, as fuel prices rise and more people turn to wood as a 

primary or secondary fuel source. In 2005, the Connecticut General Assembly took initial steps 

to address some of the public health and environmental concerns, including visibility issues, 

caused by outdoor wood burning furnaces (OWBFs) through the adoption of minimum siting and 

operational restrictions.23 While actively enforcing the statute, CTDEP continues to gather and 

evaluate information concerning OWBF emissions and to learn from the success of surrounding 

states with more stringent regulatory programs for OWBFs. Adoption of performance standards 

for new OWBFs would be most effectively pursued by EPA since the sales market includes the 

entire northern United States. 

In addition, in 2005 CTDEP adopted RCSA section 22a-174-36b, Low Emission Vehicles II 

Program, which implements the California LEV II program beginning with model year 2008. 

The California LEV II program is more stringent than the federal Tier 2 motor vehicle emissions 

standards. An analysis provided by Cambridge Systemics for NESCAUM finds that the 

California LEV II program provides an additional emissions reduction benefit in light duty 

vehicle emissions (17 tons per day of NOx and VOC in CT, NJ and RI) over and above what the 

                                                           

23 Section 22a-174k of the Connecticut General Statutes prohibits the construction and use of an OWBF unless the OWBF is 

located more than 200 feet from any residence, meets certain stack height criteria and the owner complies with certain operating 

practices, including a requirement to burn only clean wood. 
Description of EPA Comments and CTDEP Responses 7/15/09 11 

federal Tier 2 program is expected to achieve. Reduced formation of secondary organic aerosol 

is likely another benefit of the California LEV II program.” 

Comment

Section 11.11 discusses enforceability of emission limitations. In order to ensure federal 

enforceability, Connecticut should submit to EPA as a SIP revision any regulations that the state 

considers part of its Regional Haze SIP. Also, section 11.11 includes the statement, “CTDEP 

will incorporate existing PM controls at the BART-eligible units into Title V permit renewals for 

BART purposes.” This will not necessarily make BART federally enforceable unless the 

underlying requirement is federally enforceable. 

Response

CTDEP has revised the fifth paragraph of Section 11.11 as follows: 

With respect to control measures for visibility improvement under the Regional Haze Rule, the 

following enforceable provisions will apply to affected in-state BART-eligible units: 

• Low-sulfur fuel limits in RCSA section 22a-174-19a have applied to all of the BART 

eligible units since 2002/2003 (0.5% fuel sulfur content or 0.55 lb/MMBtu quarterly SO2

emission limit for non-EGUs; 0.5%/0.3% fuel sulfur content or 0.55 lb/MMBtu/0.33 

lb/MMBtu quarterly SO2 emission limits for EGUs). CTDEP has submitted the emission 

limits of RCSA section 22a-174-19a to EPA on November 18, 2008 in order to make 

such provisions federally enforceable. The approval request is pending. 

• CTDEP has submitted RCSA section 22a-174-22(e)(3) to EPA on November 18, 2008 in 

order to make the 0.15 lb/MMBtu non-ozone seasonal NOx emission limit (effective 

October 2003) federally enforceable. The approval request is pending. 

• CTDEP will incorporate existing PM controls at the BART-eligible units into Title V 

permit renewals for BART purposes. Two of Connecticut’s BART-eligible units with 

PM controls have federally enforceable New Source Review permits (see Table 9-16). In 

addition, CTDEP submitted the current version of RCSA section 22a-174-18 to EPA for 

SIP approval on December 1, 2004. The approval request is pending. 
 ATTACHMENT 1 

Table 9-4: Universe of Sources Addressed in Connecticut’s SO2 and NOx Programs for Alternative BART Budget Program Source, Unit ID, Location, Size) (BART-eligible units are highlighted; Acid Rain Program boldfaced) 

AES Thames, Unit A, Montville, 200 MW Milford Power Company LLC 1, Milford, 272 

AES Thames, Unit B, Montville, 200 MW Milford Power Company LLC 2, Milford, 272 Algonquin Power Windsor Locks, 38 MW Montville Power LLC, Unit 5, Montville, 81 MConnecticut Jet Power, Branford, 20 MW Montville Power LLC, Unit 6, Montville, 410 Bridgeport Energy 1, Bridgeport, 170 MW PSEG Power Connecticut LLC, Unit 1, New HBridgeport Energy 2, Bridgeport, 170 MW Norwalk Power LLC, Unit 1, Norwalk, 172 MPSEG Power Connecticut LLC, Unit 2, Bridgeport, 170 MW Norwalk Power LLC, Unit 2, Norwalk, 172 MPSEG Power Connecticut LLC, Unit 3, Bridgeport, 410 MW Norwalk Power LLC, Unit 10, Norwalk, 20 MW PSEG Power Connecticut LLC, Unit 4, Bridgeport, 22 MW Norwich DPUC, Norwich, 20 MW Capitol District Energy Center, Hartford, 55 MW Pfizer Inc, Boiler 5, Groton, 399 MMBtu/hr Cascades Boxboard Group - Connecticut LLC, Versailles, 275 MMBtu/hr Pfizer Inc, Boiler 8, Groton, 267 MMBtu/hr Connecticut Jet Power, Cos Cob 10, Greenwich, 20 MW Pratt & Whitney Cogen, East Hartford, 32 MW Connecticut Jet Power, Cos Cob 11, Greenwich, 20 MW CRRA, South Meadow 11A, Hartford, 20 MW Connecticut Jet Power, Cos Cob 12, Greenwich, 20 MW CRRA, South Meadow 11B, Hartford, 20 MW Devon Power LLC, Unit 7, Milford, 109 MW CRRA, South Meadow 12A, Hartford, 20 MW Devon Power LLC, Unit 8, Milford, 109 MW CRRA, South Meadow 12B, Hartford, 20 MW Devon Power LLC, Unit 10, Milford, 20 MW CRRA, South Meadow 13A, Hartford, 20 MW Devon Power LLC, Unit 11, Milford, 40 MW CRRA, South Meadow 13B, Hartford, 20 MW Devon Power LLC, Unit 12, Milford, 40 MW CRRA, South Meadow 14A, Hartford, 20 MW Devon Power LLC, Unit 13, Milford, 40 MW CRRA, South Meadow 14B, Hartford, 20 MW Devon Power LLC, Unit 14, Milford, 40 MW Connecticut Jet Power, Torrington Terminal, ToConnecticut Jet Power, Franklin Drive, Torrington, 20 MW FirstLight Power Resources Services, Tunnel, PrLake Road Generating Company 1, Killingly, 264 MW Wallingford Energy 1, Wallingford, 50 MW Lake Road Generating Company 2, Killingly, 264 MW Wallingford Energy 2, Wallingford, 50 MW Lake Road Generating Company 3, Killingly, 264 MW Wallingford Energy 3, Wallingford, 50 MW Middletown Power LLC, Unit 2, Middletown, 117 MW Wallingford Energy 4, Wallingford, 50 MW Middletown Power LLC, Unit 3, Middletown, 245 MW Wallingford Energy 5, Wallingford, 50 MW Middletown Power LLC, Unit 4, Middletown, 400 MW Waterside Power 4, Stamford, 23.2 MW Middletown Power LLC, Unit 10, Middletown, 20 MW Waterside Power 5, Stamford, 23.2 MW  Waterside Power 7, Stamford, 23.2 MW 
Description of EPA Comments and CTDEP Responses 7/15/09 13 
Description of Federal Land Manager (FLM) Comments on Connecticut’s Draft Regional Haze 

SIP and Connecticut Department of Environmental Protection (CTDEP) Responses as Required 

by 40 CFR 51.308(i)(3)

CTDEP received preliminary comments on Connecticut’s draft Regional Haze SIP from 

the U.S. Department of the Interior (DOI), National Park Service (NPS) and U.S. Fish and 

Wildlife Service (USFWS) on March 16, 2009. A conference call to discuss the agencies’ 

comments was held on March 18, 2009, with representatives from NPS, U.S. Forest Service 

(USFS), USFWS, EPA, and CTDEP in attendance. Final comments from DOI – NPS and 

USFWS were received in a letter dated April 3, 2009. Final comments from USFS were received 

in a letter dated April 8, 2009. CTDEP’s responses to the USFS’ comments are described below 

(NPS and USFWS comments/responses are in a separate document). 

CTDEP appreciates the effort put forth by the U.S. Department of Agriculture (USDA) in 

crafting these very helpful comments. CTDEP firmly supports, and is committed to, the 

interagency consultative process and looks forward to a continuing working relationship with the 

FLMs as we convey the myriad of technical requirements inherent in clean air regulations and 

other programmatic nuances in Connecticut’s air pollution control programs. 

USDA Forest Service comments

Section 6, Emissions Inventory

Comment

The discussion of emissions inventories is generic and only explains the work done by MANE-VU 

and NESCAUM. This section should include additional discussion of how the Connecticut 

specific emissions (presented in Tables 6.1 & 6.2) were generated. 

Response

CTDEP has added references to locations of Connecticut-specific language for deriving 

emissions in Attachment M (Technical Support Document for 2002 MANE-VU SIP Modeling 

Inventories, Version 3) underneath Table 6.1: 

“Descriptions of how the Connecticut 2002 specific emissions were generated can be found in 

Attachment M (EGU Point, Non-EGU Point – pages 20, 43; Area – pages 58-59; Mobile – pages 

97-99; Non-Road Mobile – pages 77, 84; and Biogenic – page 117).” 

CTDEP has added references to locations of Connecticut-specific language for deriving 

emissions in Attachment N (Development of Emission Projections for 2009, 2012 and 2018 for 

NonEGU Point, Area, and Nonroad sources in the MANE-VU Region) and Attachment O 

(Development of MANE-VU Mobile Source Projection Inventories for SMOKE/MOBILE6 

Application) underneath Table 6.2: 

“Descriptions of Connecticut-specific adjustments to the 2018 RPG (Best and Final) Emissions 

Inventory can be found in Attachment N (Non-EGU Point source growth factors – page 2-5, 

control measures – pages 5-3 through 5-6; and Area growth factors – page 3-4, control measures 

- pages 3-9, 5-20 through 5-22) and Attachment O (Mobile source activity input data and 

scenario input files – page 3, SMOKE-related files – page 4). No Connecticut-specific 

adjustments were made to the EGU Point, Non-Road Mobile and Biogenic inventories.” 
Description of FLM Comments and CTDEP Responses 7/15/09 2 

Comment 

We would like Connecticut to commit to tracking emissions annually and reporting how the 

projected emissions compare to actual emissions in the mid-course review due in 2012 and 

required SIP revision due in 2018. 

Response

While CTDEP would like to commit to the enhanced tracking and reporting as requested by 

USDA, given the state’s current fiscal constraints we cannot support this effort at this time. 

However, if USDA would like to support this effort, CTDEP would be willing to track and report 

the requested information. In the alternative, CTDEP will continue to annually track and 

triennially report emissions, as follows by adding the following language to Section 6.4: 

“CTDEP will be preparing a periodic emission inventory on a three year schedule as required by 

EPA and these emissions will be used to track how the projected emissions compare to actual 

emissions in the first five-year regional haze SIP progress report and required SIP revision due in 

2018.” 

Section 2, Areas Contributing to Regional Haze

Comment

The discussion regarding Connecticut’s contribution to visibility impairment at other States’ 

Class I areas in Section 2 of the Draft SIP is brief. Section 8.2 of the Draft SIP provides 

additional information on Connecticut’s contribution to sulfate impacts. It is suggested that 

additional discussion be added to Section 2, including a reference to Section 8.2. 

Response

CTDEP has added the following language, some of which also appears in Section 8.2, 

Contributing States and Regions, to Section 2.1: 

“Table 2.2 shows Connecticut’s SO2 annual impacts at northeast Class I Areas as compared with 

other MANE-VU states. Connecticut consistently has one of the smallest impacts on all 

northeast Class I Areas when considering all MANE-VU states. 
Description of FLM Comments and CTDEP Responses 7/15/09 3 

Table 2.2: Percent Contributions (Mass Basis) of Individual States and Regions to Total 

Annual Sulfate Impacts at Northeast Class I Areas (REMSAD) 

Contributing

State or Region

Mandatory Class I Area

Acadia

ME

Brigantine

NJ

Dolly Sods

WV

Great Gulf &

Presidential

Range –Dry

River, NH

Lye Brook VT

Moosehorn

& Roosevelt

Campobello

Shenandoah

VA

Connecticut 0.76 0.53 0.04 0.48 0.55 0.56 0.08

Delaware 0.96 3.20 0.30 0.63 0.93 0.71 0.61

District of Columbia 0.01 0.04 0.01 0.01 0.02 0.01 0.04

Maine 6.54 0.16 0.01 2.33 0.31 8.01 0.02

Maryland 2.20 4.98 2.39 1.92 2.66 1.60 4.84

Massachusetts 10.11 2.73 0.18 3.11 2.45 6.78 0.35

New Hampshire 2.25 0.60 0.04 3.95 1.68 1.74 0.08

New Jersey 1.40 4.04 0.27 0.89 1.44 1.03 0.48

New York 4.74 5.57 1.32 5.68 9.00 3.83 2.03

Pennsylvania 6.81 12.84 10.23 8.30 11.72 5.53 12.05

Rhode Island 0.28 0.10 0.01 0.11 0.06 0.19 0.01

Vermont 0.13 0.06 0.00 0.41 0.95 0.09 0.01

MANE‐VU   36.17 34.83 14.81 27.83 31.78 30.08 20.59

MRPO 11.98 18.16 30.26 20.10 21.48 10.40 26.84

VISTAS 8.49 21.99 36.75 12.04 13.65 6.69 33.86

CenRAP 0.88 1.12 1.58 1.65 1.67 0.82 1.48

Canada 8.69 7.11 3.90 14.84 12.43 7.85 4.75

Other 33.79 16.78 12.70 23.54 18.99 44.17 12.48

             Source: Table 8‐1 of the MANE‐VU Contribution Assessment

Note: Indicated percent contributions from VISTAS, CenRAP and Canada apply only to those portions lying within 

the modeling domain (see Figure 7.1). Actual contributions, especially from CenRAP, would be higher than stated. 

The ranking of emission contributions to visibility impairment in the MANE-VU Class I Areas 

has direct relevance to the consultation process described in Section 3.0, Regional Planning and 

Consultation. Using results from the REMSAD model, MANE-VU applied the following three 

criteria to identify states and regions for the purposes of consultation on regional haze: 
Description of FLM Comments and CTDEP Responses 7/15/09 4 

1. Any state/region that contributed 0.1 μg/m3 sulfate or greater on the 20 percent worst 

visibility days in the base year (2002), 

2. Any state/region that contributed at least 2 percent of total sulfate observed on the 20 

percent worst visibility days in 2002, and 

3. Any state/region among the top ten contributors on the 20 percent worst visibility days in 

2002. 

For the purposes of deciding how broadly to consult, the MANE-VU States settled on the second 

of the three criteria: any state/region that contributed at least 2 percent of total sulfate observed 

on the 20 percent worst visibility days in 2002.  Connecticut, Rhode Island, Vermont, and the 

District of Columbia were not identified as being among the political or regional units 

contributing at least 2 percent of sulfate at any of the seven Class I areas. However, as 

participants in MANE-VU, those entities have agreed to pursue adoption of regional control 

measures aimed at visibility improvement on the haziest days and prevention of visibility 

degradation on the clearest days. Section 8.2 includes additional discussion regarding individual 

state contributions to regional haze at Class I areas.” 

Sections 10 and 11, Reasonable Progress Goals and Long Term Strategy

Comment

Since Connecticut has no Class I areas, it is acceptable to state that Connecticut agrees with the 

reasonable progress goals established by the States of Maine, New Hampshire, Vermont and 

New Jersey for their Class I areas. Even though the impacts are minimal, this section should 

also, at least, recognize that emissions from Connecticut sources impact Class I areas in West 

Virginia and Virginia as well.

Response

USDA is correct in asserting that emissions from Connecticut reach West Virginia (0.04 percent) 

and Virginia (0.08 percent). CTDEP has added the following language to Section 10.0: 

“As referred to in Subsection 2.1, emissions from Connecticut sources also impact Class I areas 

in West Virginia and Virginia, albeit to a much lesser extent than impacts on MANE-VU Class I 

areas.” 

Comment

Section 11.5 of the Draft SIP discusses source retirement and replacement schedules and refers 

to Table B-5 in Attachment N for specific sources. Table B-5 in Attachment N does not 

specifically identify Connecticut sources that have been shutdown – it appears to list all sources 

in the MANE-VU region. A table identifying specific sources in Connecticut that have shut down 

should be added to Section 11.5. Are there any other sources that are planning to shut down 

before 2018? If information is available for any other sources that are expected to shut down 

before 2018, it should also be discussed in this section. 

Response

CTDEP has removed the reference to Table B-5 in Attachment N because Table B-5 does not 

contain any Connecticut sources. Based on modeling performed to support the development of 

an Integrated Resource Plan for the CT Department of Public Utility Control (CTDPUC), 

CTDEP strongly believes that under Connecticut’s new forward capacity market, several large 

electric generating units will simply become too expensive to operate, thus forcing their 

economic retirement. As a result, CTDEP has added the following language to Section 11.5: 
Description of FLM Comments and CTDEP Responses 7/15/09 5 

“While the output of the IPM model predicts that a certain number of older power plants will be 

replaced by newer units to meet future electric growth and state-specific NOX and SO2 caps, 

Connecticut did not directly rely on the closure of any particular plant in establishing the 2018 

inventory upon which the reasonable progress goals were set. 

The modeling used to develop the 2018 emissions inventory appears to predict that several large 

EGUs in Connecticut, including five of the six BART-eligible EGUs (Middletown Power 3 & 4, 

Montville Power 6, Norwalk Power 2 and PSEG Power Connecticut New Haven Harbor 1) will 

retire by 2018. Table 11.1 shows two non BART-eligible EGUs in Connecticut that have retired 

since 2002.” 

Table 11.1     Retired EGUs

Unit Capacity (MW) Retirement Date

Devon 7 109 11/28/07

Devon 8 109 11/28/07

Section 11.7, Agricultural and Forestry Smoke Management

Comment

We agree that based on existing inventories of smoke emissions from wildfires and prescribed 

fires, they are not a significant emission source for Connecticut or a significant contributor to 

regional haze in downwind Class I areas at this time. It would be helpful to add a reference to 

the specific sections in Attachment V which support this claim. Also, we request that 

Connecticut commit to track smoke emissions in the future to help determine the level of 

contribution for future planning periods.

Response

CTDEP has added the following references to specific sections in Attachment V to the second 

paragraph of Section 11.7: 

End of second sentence

(see Figure 2 in Subsection 4.1 of Attachment V) 

End of fourth sentence

(see Figure 2 in Subsection 4.1 of Attachment V) 

In addition, CTDEP added the following paragraph at the end of Section 11.7: 

“CTDEP’s Bureau of Air Management currently obtains wildfire and prescribed burning data, 

including number of acres burned, when the wildfire or prescribed burn occurred and the 

location of the wildfire or prescribed burn, from CTDEP’s Forestry Division. The wildfire and 

prescribed burning data will be included in CTDEP’s periodic inventory every three years. 

CTDEP will track smoke emissions from wildfires and prescribed fires and will assess if 

emissions from such activities are increasing in the first five-year regional haze SIP progress 

report and required SIP revision due in 2018.” 
Description of FLM Comments and CTDEP Responses 7/15/09 6 

Additional Suggestions

Section 5, Air Monitoring Strategy

Comment

Section 5 discusses the monitoring strategy being used to assess visibility conditions. Even 

though Connecticut does not have any Class I areas, this section demonstrates the importance of 

continued operation of the IMPROVE monitoring network. We ask that Connecticut add a 

statement expressing their support for continued operation of the IMPROVE network. 

Response

While CTDEP would like to commit to the continued operation of the IMPROVE network as 

requested by USDA, given the state’s current fiscal constraints we cannot support an unqualified 

statement of commitment at this time. However, if USDA would like to support this effort, 

CTDEP would certainly be willing to do so. In the alternative, CTDEP will continue to use these 

data sources and has added the following language to the end of Section 5.2, Monitoring 

Requirements: 

“Assuming adequate resources, CTDEP will continue using these and other data sources for the 

purposes of understanding visibility impairment and documenting progress toward national 

visibility goals for Class I areas under the Regional Haze Rule. CTDEP agrees that the 

IMPROVE network is an appropriate monitoring network to track regional haze progress and 

encourages EPA to continue funding the IMPROVE network. CTDEP will work with other 

states and the FLMs to maintain the IMPROVE network to the extent resources are available.” 

Section 7, Air Quality Modeling

Comment

In Sections 7.1 and 7.3, brief discussions of model performance would be helpful. 

Response

CTDEP understands that air quality modeling is sometimes difficult to follow and has added the 

following language to Section 7.1, Meteorology to help clarify the modeling effort: 

“The analyses show that in general, the performance of the MM5 is reasonable both at the 

surface and in the vertical, thereby providing confidence in the use of these data in the CMAQ 

simulations.” 

CTDEP has revised Paragraph 2 of Section 7.3, Model Platforms, as follows: 

NYSDEC performed an extensive model performance analysis to evaluate CMAQ model 

predictions against observations of ozone, PM2.5, and other pollutant species. In general, the 

CMAQ results were best for daily maximum O3 and daily average PM2.5 and SO4 mass. Many 

other species vary tremendously over the course of a day, or from day to day, and small model 

over- or underprediction at low concentrations can lead to large biases on a composite basis. It is 

important to demonstrate that the model performs reasonably over the diurnal cycle, not just in 

terms of daily maximum or average values. Also, it is important to demonstrate that the model 

can reproduce concentrations above the ground level. This model performance evaluation is 

described in detail in NYSDEC’s technical support document TSD-1e, “CMAQ Model 

Performance and Assessment, 8-Hr OTC Ozone Modeling,” February 23, 2006 (Attachment S). 

Due to the simplified chemistry mechanism, REMSAD may not simulate atmospheric processes 

as well as CMAQ. However, advantages such as the tagging feature for sulfur, more efficient 
Description of FLM Comments and CTDEP Responses 7/15/09 7 

modeling, and reasonable correspondence with measurements for many species, make REMSAD 

an important source apportionment tool for MANE-VU. A model performance evaluation for 

PM2.5 species, aerosol extinction coefficient, and the haze index is provided in NESCAUM’s 

report, “MANE-VU Modeling for Reasonable Progress Goals, Model Performance Evaluation, 

Pollution Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment G). 
Description of Federal Land Manager (FLM) Comments on Connecticut’s Draft Regional Haze 

SIP and Connecticut Department of Environmental Protection (CTDEP) Responses as Required 

by 40 CFR 51.308(i)(3)

CTDEP received preliminary comments on Connecticut’s draft Regional Haze SIP from 

the U.S. Department of the Interior (DOI), National Park Service (NPS) and U.S. Fish and 

Wildlife Service (USFWS) on March 16, 2009. A conference call to discuss the agencies’ 

comments was held on March 18, 2009, with representatives from NPS, U.S. Forest Service 

(USFS), USFWS, EPA, and CTDEP in attendance. Final comments from DOI – NPS and 

USFWS were received in a letter dated April 3, 2009. Final comments from USFS were received 

in a letter dated April 8, 2009. CTDEP’s responses to the NPS/USFWS’ comments are 

described below (USFS comments/responses are in a separate document). 

CTDEP appreciates the effort put forth by NPS and USFWS in crafting these very helpful 

comments. CTDEP firmly supports, and is committed to, the interagency consultative process 

and looks forward to a continuing working relationship with the FLMs as we convey the myriad 

of technical requirements inherent in clean air regulations and other programmatic nuances in 

Connecticut’s air pollution control programs. 

National Park Service and U.S. Fish and Wildlife Service comments

Overall Comments

Comment

In general, we are concerned the draft SIP does not include an analysis for the full adoption of 

the MANE-VU Ask (Ask). The draft SIP appears contradictory without such an analysis, 

because the State fully adopts the Ask as its long-term strategy early in the draft SIP, however, 

throughout the document the State only commits to pursuing certain elements of the Ask. 

Response

See response to comment on Section 3.2.2 below. 

Comment

We also have concerns regarding best available retrofit technology (BART) requirements. The 

draft SIP is unclear with respect to the State’s approach to meeting BART requirements. The 

SIP and supporting documentation are not sufficient for establishing a source-by-source BART 

emission limit. If the State wishes to rely on existing rules as the basis for an alternative to 

BART, then additional demonstrations of the adequacy of that alternative approach should be 

presented in the SIP. Please see our comments below regarding BART and the BART-alternative 

program. 

Response

See response to comment on Section 9 below. 

Section 2, Areas Contributing to Regional Haze

Comment

In Section 2.0 Areas Contributing to Regional Haze, the State needs to include a summary of the 

Contribution Assessment. The draft SIP states that Connecticut emissions have measurable 

impacts on Class I areas, but provides no details or comparisons to other states’ impacts in the 

region. 
Description of FLM Comments and CTDEP Responses 7/15/09 2 

At a minimum, the State should include a discussion on the three criteria used by MANE-VU to 

determine consultation. This would at least provide context to what Connecticut determines as 

their contribution. In addition, the draft SIP should provide percent contributions of 

neighboring states to better understand the magnitude of the State’s contributions. 

Response

CTDEP has added the following language, some of which also appears in Section 8.2, 

Contributing States and Regions, to Section 2.1: 

“Table 2.2 shows Connecticut’s SO2 annual impacts at northeast Class I Areas as compared with 

other MANE-VU states. Connecticut consistently has one of the smallest impacts on all 

northeast Class I Areas when considering all MANE-VU states. 
Description of FLM Comments and CTDEP Responses 7/15/09 3 

Table 2.2: Percent Contributions (Mass Basis) of Individual States and Regions to Total 

Annual Sulfate Impacts at Northeast Class I Areas (REMSAD) 

Contributing

State or Region

Mandatory Class I Area

Acadia

ME

Brigantine

NJ

Dolly Sods

WV

Great Gulf &

Presidential

Range –Dry

River, NH

Lye Brook VT

Moosehorn

& Roosevelt

Campobello

Shenandoah

VA

Connecticut 0.76 0.53 0.04 0.48 0.55 0.56 0.08

Delaware 0.96 3.20 0.30 0.63 0.93 0.71 0.61

District of Columbia 0.01 0.04 0.01 0.01 0.02 0.01 0.04

Maine 6.54 0.16 0.01 2.33 0.31 8.01 0.02

Maryland 2.20 4.98 2.39 1.92 2.66 1.60 4.84

Massachusetts 10.11 2.73 0.18 3.11 2.45 6.78 0.35

New Hampshire 2.25 0.60 0.04 3.95 1.68 1.74 0.08

New Jersey 1.40 4.04 0.27 0.89 1.44 1.03 0.48

New York 4.74 5.57 1.32 5.68 9.00 3.83 2.03

Pennsylvania 6.81 12.84 10.23 8.30 11.72 5.53 12.05

Rhode Island 0.28 0.10 0.01 0.11 0.06 0.19 0.01

Vermont 0.13 0.06 0.00 0.41 0.95 0.09 0.01

MANE‐VU   36.17 34.83 14.81 27.83 31.78 30.08 20.59

MRPO 11.98 18.16 30.26 20.10 21.48 10.40 26.84

VISTAS 8.49 21.99 36.75 12.04 13.65 6.69 33.86

CenRAP 0.88 1.12 1.58 1.65 1.67 0.82 1.48

Canada 8.69 7.11 3.90 14.84 12.43 7.85 4.75

Other 33.79 16.78 12.70 23.54 18.99 44.17 12.48

             Source: Table 8‐1 of the MANE‐VU Contribution Assessment

Note: Indicated percent contributions from VISTAS, CenRAP and Canada apply only to those portions lying within 

the modeling domain (see Figure 7.1). Actual contributions, especially from CenRAP, would be higher than stated. 

The ranking of emission contributions to visibility impairment in the MANE-VU Class I Areas 

has direct relevance to the consultation process described in Section 3.0, Regional Planning and 

Consultation. Using results from the REMSAD model, MANE-VU applied the following three 

criteria to identify states and regions for the purposes of consultation on regional haze: 
Description of FLM Comments and CTDEP Responses 7/15/09 4 

1. Any state/region that contributed 0.1 μg/m3 sulfate or greater on the 20 percent worst 

visibility days in the base year (2002), 

2. Any state/region that contributed at least 2 percent of total sulfate observed on the 20 

percent worst visibility days in 2002, and 

3. Any state/region among the top ten contributors on the 20 percent worst visibility days in 

2002. 

For the purposes of deciding how broadly to consult, the MANE-VU States settled on the second 

of the three criteria: any state/region that contributed at least 2 percent of total sulfate observed 

on the 20 percent worst visibility days in 2002.  Connecticut, Rhode Island, Vermont, and the 

District of Columbia were not identified as being among the political or regional units 

contributing at least 2 percent of sulfate at any of the seven Class I areas. However, as 

participants in MANE-VU, those entities have agreed to pursue adoption of regional control 

measures aimed at visibility improvement on the haziest days and prevention of visibility 

degradation on the clearest days. Section 8.2 includes additional discussion regarding individual 

state contributions to regional haze at Class I areas.” 

Section 3, Regional Planning and Consultation

Comment

In Section 3.2.2, Connecticut agrees with the MANE-VU Ask and commits to pursuing emission 

reductions consistent with the Ask. However, in Section 3.2.2.2, Connecticut does not address 

all elements of the Ask, instead saying it will review the viability of the remainder of the Ask in 

the 2013 review. It is inconsistent language to conclude the State will pursue emission 

reductions consistent with the Ask but at the same time say it will continue to review the viability 

of certain measures of the Ask over the next five years. 

Response

CTDEP has revised Sections 3.2.2.2, 11.4.2, 11.4.3, 11.9 and 11.10 as follows: 

Section 3.2.2.2 (replaced with following section)

“Connecticut, being a MANE-VU member state, participated in the development of the MANEVU “Ask” which was approved by the MANE-VU Board on June 20, 2007. Connecticut intends 

to meet the terms of this agreement as follows: 

• By demonstrating BART equivalency through its existing regulations (for additional 

details, refer to Section 9.0, Best Available Retrofit Technology (BART)). 

• All of Connecticut’s BART-eligible sources, as well as all NOx Budget Program/CAIR 

sources, meet the recommended residual oil content or use lower sulfur content residual 

oil than specified in MANE-VU’s low-sulfur fuel oil strategy as a result of Regulations of 

Connecticut State Agencies section 22a-174-19a. In terms of a state-wide limitation of 

#4 residual oil to 0.25-0.5% by weight by no later than 2018, and of #6 residual oil to no 

greater than 0.5% sulfur by weight by no later than 2018, CTDEP has done a preliminary 

analysis of the potential number of sources impacted. Given regional fuel supply issues, 

such a limitation in Connecticut is dependent on multi-state implementation. CTDEP 

continues to participate in consultations with other MANE-VU states to develop a low 

sulfur heating strategy consistent with the MANE-VU “Ask”. 
Description of FLM Comments and CTDEP Responses 7/15/09 5 

• Section 16a-21a of the Connecticut General Statutes limits fuel sulfur content of heating 

distillate oil and off-road diesel oil to 500 ppm as of the date on which the last of the 

States New York, Massachusetts and Rhode Island limit the sulfur content of such fuels. 

Therefore, implementation of the 500 ppm limitation in Connecticut is contingent upon 

New York, Massachusetts and Rhode Island adopting a 500 ppm limitation for heating 

distillate oil and off-road diesel oil. Regarding the reduction of sulfur content of distillate 

oil to 15 ppm by 2018 component of the MANE-VU “Ask”, Connecticut continues to 

work with other states in the region and the fuel industry to take steps to implement 

reductions consistent with the MANE-VU “Ask” in the most efficient and reasonable 

manner. 

• None of Connecticut’s EGUs fall on the list of the top 167 contributing EGU emission 

points. 

• CTDEP is currently evaluating other control measures including energy efficiency, 

alternative clean fuels, and other measures to reduce SO2 and NOx emissions from all 

coal-burning facilities by 2018. CTDEP will evaluate new source performance standards 

for wood combustion. 

CTDEP will provide an update of the progress towards meeting the MANE-VU “Ask” in its first 

progress report in support of this Regional Haze SIP, to be submitted five years from the date of 

final submittal of this SIP.” 

Section 11.4.2 (the second paragraph (formerly third paragraph) was replaced with following

paragraph)

“The MANE-VU states agree that a fuel sulfur content limit on residual oil and distillate oil is 

reasonable to pursue over the next ten years. CTDEP will review the details of this strategy in 

five years, coincident with Connecticut’s first regional haze SIP progress report. Section 16a21a of the Connecticut General Statutes limits fuel sulfur content of heating distillate oil and offroad diesel oil to 500 ppm as of the date on which the last of the States New York, Massachusetts 

and Rhode Island limit the sulfur content of such fuels. Therefore, implementation of this 

strategy in Connecticut is dependent upon adjacent states’ implementation. CTDEP continues to 

participate in consultations with other MANE-VU states to develop a low sulfur heating strategy 

consistent with the MANE-VU “Ask”.” 

Section 11.4.3 (the last two sentences of the third paragraph were replaced with the following

sentence): 

“CTDEP will continue to evaluate other control measures for EGUs and will provide an update 

on its evaluation in Connecticut’s first five-year regional haze SIP progress report.” 

Section 11.9 (the last sentence of the second paragraph has been replaced with the following 

sentence):

“To further meet its obligation beyond those controls already adopted, CTDEP has agreed to 

pursue the following measures, consistent with the provisions of the MANE-VU “Ask”:” 

Section 11.10 (the first sentence of the second paragraph has been replaced with the following 
Description of FLM Comments and CTDEP Responses 7/15/09 6 

sentence): 

“CTDEP will continue to pursue these measures, consistent with the provisions of the MANEVU “Ask”, and will provide a status update in the first five-year regional haze SIP progress 

report.” 

Comment

In Section 3.2.3, Connecticut implies that addressing inconsistencies with emission inventories, 

both within MANE-VU and out, “caused” most States to miss the 2007 statutory submittal to 

EPA. This statement should be considered for accuracy and removed. 

Response

CTDEP has revised the referenced statement as follows: 

“Most states missed the required Regional Haze SIP filing date of December 17, 2007.” 

Comment

In Section 3.2.5, please include February 4, 2009, as the date of submission to FLMs. 

Response

CTDEP has included the February 4, 2009 date in Section 3.2.5. 

Section 5, Air Monitoring Strategy

Comment

In Section 5.0 Air Monitoring Strategy, Connecticut should include language that commits the 

State to continuing support of the IMPROVE network. Support, in this context means the State 

agrees IMPROVE is an appropriate monitoring network to track regional haze progress and that 

the State agrees to work with neighboring states and federal land managers in meeting the goals 

of the IMPROVE program. 

Response

While CTDEP would like to commit to the continued operation of the IMPROVE network as 

requested by NPS and USFWS, given the state’s current fiscal constraints we cannot support an 

unqualified statement of commitment at this time. However, if NPS and USFWS would like to 

support this effort, CTDEP would certainly be willing to do so. In the alternative, CTDEP will 

continue to use these data sources and CTDEP has added the following paragraph to the end of 

Section 5.2, Monitoring Requirements: 

“Assuming adequate resources, CTDEP will continue using these and other data sources for the 

purposes of understanding visibility impairment and documenting progress toward national 

visibility goals for Class I areas under the Regional Haze Rule. CTDEP agrees that the 

IMPROVE network is an appropriate monitoring network to track regional haze progress and 

encourages EPA to continue funding the IMPROVE network. CTDEP will work with other 

states and the FLMs to maintain the IMPROVE network to the extent resources are available.” 

Comment

Section 5.3 should be revised to reflect that Moosehorn Wilderness and Roosevelt Campobello 

International Park also share a monitoring site. 

Response

CTDEP has added the following sentence to Section 5.3, Monitoring Sites for MANE-VU Class 

I Areas: 
Description of FLM Comments and CTDEP Responses 7/15/09 7 

“Moosehorn Wilderness and Roosevelt Campobello International Park also share a monitoring 

site.” 

Section 6, Emissions Inventory

Comment

In Section 6.0, please provide for purposes of comparison an explanation as to why NH3 

emissions go up in projected 2018 inventory (Best and Final inventory). 

Response

CTDEP has added the following two paragraphs to the end of Section 6.4, Summary of Emission 

Inventories: 

“Note that total ammonia emissions in 2018 are projected to increase slightly from total 

ammonia emissions in 2002. This can likely be attributed to a projected increase in vehicle miles 

traveled and projected increase in EGU Point NH3 emissions (possibly from projected 

installation of SCR controls on one or more units). 

CTDEP will be preparing a periodic emission inventory on a three year schedule as required by 

EPA and these emissions will be used to track how the projected emissions compare to actual 

emissions in the first five-year regional haze SIP progress report and required SIP revision due in 

2018.” 

Section 11, Long Term Strategy

Comment

In Section 11.2, the State references technical reports that were used to determine the level of 

emission reduction required by the State to achieve reasonable progress goals in Class I areas 

affected by its emissions. However, there is no statement or summary information identifying 

what the necessary reduction levels actually were. 

Response

CTDEP has added the following paragraph to Section 11.2, Technical Basis for Strategy 

Development: 

“As described in Attachment G, the “beyond on the way” scenario – defined by CAIR with other 

“on the books” measures and the limitation of fuel sulfur content to 500 ppm for all No. 2 

“distillate” fuel oil sold in the MANE-VU region – is sufficient to achieve visibility 

improvement beyond the so-called “uniform rate of progress” defined by uniform visibility 

improvement between now and 2064, the planning horizon for the regional haze program. 

However, it should be noted that USEPA guidance for setting reasonable progress goals asks 

states to consider reviewing all measures identified through the four factor analysis process (see 

Section 10.2.1) and to adopt each measure that is determined to be reasonable.” 

Comment

For Section 11.5 Source Retirement and Replacement Schedule, please include Table B-5 from 

Attachment N in the text. As written, the draft SIP provides no information on source retirement 

in Connecticut. 

Response

CTDEP has removed the reference to Table B-5 in Attachment N because Table B-5 does not 

contain any Connecticut sources. Based on modeling performed to support the development of 

an Integrated Resource Plan for the CT Department of Public Utility Control (CTDPUC), 
Description of FLM Comments and CTDEP Responses 7/15/09 8 

CTDEP strongly believes that under Connecticut’s new forward capacity market, several large 

electric generating units will simply become too expensive to operate, thus forcing their 

economic retirement. As a result, CTDEP has added the following language to Section 11.5: 

“While the output of the IPM model predicts that a certain number of older plants will be 

replaced by newer units to meet future electric growth and state-specific NOX and SO2 caps, 

Connecticut did not directly rely on the closure of any particular plant in establishing the 2018 

inventory upon which the reasonable progress goals were set. 

The modeling used to develop the 2018 emissions inventory appears to predict that several large 

EGUs in Connecticut, including five of the six BART-eligible EGUs (Middletown Power 3 & 4, 

Montville Power 6, Norwalk Power 2 and PSEG Power Connecticut New Haven Harbor 1) will 

retire by 2018. Table 11.1 shows two non BART-eligible EGUs in Connecticut that have retired 

since 2002.” 

Table 11.1     Retired EGUs

Unit Capacity (MW) Retirement Date

Devon 7 109 11/28/07

Devon 8 109 11/28/07

Comment

In Section 11.9, please include what strategy is used to get the predicted 2018 results. 

Response

CTDEP added the following paragraph to Section 11.9, Connecticut’s Share of Emission 

Reductions: 

“As referred to in Section 11.2, the “beyond on the way” scenario described in Attachment G 

(defined by CAIR with other “on the books” measures and the limitation of fuel sulfur content to 

500 ppm for all No. 2 “distillate” fuel oil sold in the MANE-VU region) is sufficient to achieve 

visibility improvement beyond the so-called “uniform rate of progress” defined by uniform 

visibility improvement between now and 2064, the planning horizon for the regional haze 

program. Section 16a-21a of the Connecticut General Statutes limits fuel sulfur content of 

heating distillate oil and off-road diesel oil to 500 ppm as of the date on which the last of the 

States New York, Massachusetts and Rhode Island limit the sulfur content of such fuels.” 

Comment

In Section 11.12 Prevention of Significant Deterioration, we appreciate the State making a clear 

link between its regional haze program and the importance of the PSD program in achieving 

reasonable progress goals. This link is especially important for protection of the twenty percent 

best visibility days. 

Response

No response required. 

Section 11.7, Agricultural and Forestry Smoke Management
Description of FLM Comments and CTDEP Responses 7/15/09 9 

Comment

The State concludes that there is no information suggesting smoke emissions will increase over 

the next decade (Section 11.7). Will the State track such emissions to determine if this 

assumption is correct? 

Response

CTDEP added the following paragraph at the end of Section 11.7: 

“CTDEP’s Bureau of Air Management currently obtains wildfire and prescribed burning data, 

including number of acres burned, when the wildfire or prescribed burn occurred and the 

location of the wildfire or prescribed burn, from CTDEP’s Forestry Division. The wildfire and 

prescribed burning data will be included in CTDEP’s periodic inventory every three years. 

CTDEP will track smoke emissions from wildfires and prescribed fires and will assess if 

emissions from such activities are increasing in the first five-year regional haze SIP progress 

report and required SIP revision due in 2018.” 

Comment

The draft SIP states Connecticut has a smoke management program. Please include a brief 

summary of what that program entails. It is unclear why the State has a smoke management 

program, considering the draft SIP previously concludes that wood smoke is only a fraction of 

fine particle mass. Attachment FF is listed as Connecticut Smoke Management Documentation 

and does not include any information specific to the smoke management program. 

Response

CTDEP has revised the last sentence of paragraph four of Section 11.7 as follows: 

“Although CTDEP does not have a formal smoke management program, as a smoke 

management policy, CTDEP’s Division of Forestry can only initiate prescribed burns when such 

activity has less significant impacts on air quality (see Attachment FF).” 

Section 9, Best Available Retrofit Technology (BART)

Comment

The State has done a commendable job in the overall level of control required of its BARTeligible sources (e.g., 0.3 percent sulfur fuel-oil). It stands out among all the states in the region 

in this regard. However, the State should better support its determination that existing rules 

provide an acceptable alternative to BART on a source-by-source basis. 

The draft SIP lacks rigor required for comparison with a source-by-source BART determination. 

The EPA and MANE-VU ‘benchmarks’ as described in Section 9.2.3 as being BART are not 

necessarily BART. Since the overall level of control among Connecticut BART sources is 

significant, source-by-source BART determinations may conclude that additional controls are 

not cost-effective and the existing proposed controls are BART. Nevertheless, these BART 

determinations should be performed as an integral part of the demonstration of the “alternative 

measure” for BART as proposed by the State. 40 CFR 51.308(e)(2)(i)(C) requires that a 

“determination of BART for each source” be performed. Approval by EPA of an “alternative 

method” may relieve the State from requiring installation of BART on certain sources, but it 

does not relieve the State from performing source-by-source BART determinations in developing 

a demonstration that justifies using an “alternative method”. 

Sulfur Dioxide
Description of FLM Comments and CTDEP Responses 7/15/09 10 

In attempting to comply with the 40 CFR 51.308(e)(2) requirement that the State submit an 

“implementation plan” for the proposed “alternative measure”, the State assumes that the EPA 

BART Guidelines1set SO2 BART for oil-fired boilers as burning a 1.0 percent sulfur fuel-oil. The 

State then used this definition as a de facto standard to show that a requirement of 0.3 percent 

sulfur fuel-oil resulted in “greater reasonable progress” and the ability to use an “alternative 

measure” for BART. The assumption that SO2 BART is the use of 1.0 percent sulfur fuel-oil is 

not correct. 

The EPA BART Guidelines state that you should “evaluate limiting the sulfur content of the fueloil burned to 1 percent or less by weight”, but this is not to be interpreted that the use of 1 

percent fuel-oil is considered to be BART for oil-fired boilers. It is only a presumptive BART 

alternative that should be considered. In the EPA BART Guidelines where the process for the 

analysis of control options for sources subject to BART is described, it is stated that, “Best 

Available Retrofit Technology (BART) means an emission limitation based on the degree of 

reduction achievable through the application of the best system of continuous emission reduction 

for each pollutant which is emitted by...[a BART-eligible source]. The emission limitation must 

be established, on a case-by-case basis, taking into consideration the technology available, the 

costs of compliance...and the degree of improvement in visibility which may reasonably be 

anticipated to result from the use of such technology.”2

 For this reason additional feasible 

control alternatives should have been considered for each source in order to determine BART. 

Then, greater reasonable progress could be determined by comparing the BART for all BARTeligible sources against the across-the-board 0.3 percent sulfur in fuel-oil requirement. 

Examples of additional control alternatives to be considered for SO2 BART for each emission 

unit include the applicability of using progressively lower sulfur oils below 0.3 percent sulfur 

content (e.g., #2 distillate oils of 0.0015%, 0.05% sulfur content). The associated costs should 

be examined for each alternative. This would show a cost gradient as the sulfur in oil decreases 

and selection of BART would be based on the alternative presenting the most control where the 

cost remains reasonable. Dispersion modeling for a unit should also determine visibility impacts 

of that given unit on Class I areas for each viable fuel-oil alternative. In addition, the costs and 

visibility impacts of wet or dry flue gas desulphurization (FGD) techniques should be 

considered. Retrofit FGD systems can result in 90%-95% reductions. FGD is a welldemonstrated technology on oil-fired utility units in some other countries (e.g., Japan, South 

Korea and Cyprus). 

The full five-factor SO2 BART determinations described above should be performed for the 

facilities at Middletown Power Units 3 and 4, Montville Power Unit 6, PSEG Bridgeport Harbor 

Station Unit 3, and PSEG New Haven Harbor Station Unit 1. 

                                                           

1 See 40 CFR Part 51, Appendix Y.  The U.S. Environmental Protection Agency finalized its BART Guidelines on June

15, 2005, and published the preamble and final rule text in the Federal Register on July 6, 2005.  The rulemaking

action added Appendix Y to Part 51, titled “Guidelines for BART Determinations Under the Regional Haze Rule.”  

See Section IV.E.4.

2 Ibid, See Section IV.A.
Description of FLM Comments and CTDEP Responses 7/15/09 11 

Nitrogen Oxides

Once again we commend the State for its past efforts in implementing the ozone reasonably 

available control technology (RACT) provisions in the 1990s and NOx Budget Program for the 

NOx SIP Call to significantly reduce NOx emission limits. Using the same line of reasoning as 

discussed above for SO2, it is incumbent on the State to use a baseline emissions year 

(presumably 2001) and examine NOx BART control alternatives for each BART-eligible source. 

Even though the EPA BART Guidelines state that combustion control is “generally highly costeffective and should be considered”3

in a BART determination for oil-fired boilers, combustion 

controls are not a de facto BART standard. Alternative NOx controls to achieve BART should be 

considered at each BART-eligible source to complete the full five-factor analysis. Oil-fired 

utility boilers have a variety of combustion controls available, such as, low excess air, low NOx 

burners, over-fired air, flue gas recirculation and optimum staged combustion. Also, postcombustion alternatives such as Selective Non-Catalytic Reduction (SNCR) and Selective 

Catalytic Reduction (SCR) should be considered at facilities where they do not currently exist. 

Particulate Matter

Regarding particulate matter (PM) controls at BART-eligible facilities, Table 9-16 presents cost 

ranges for installing electrostatic precipitators (ESP) on sources not currently controlled for 

PM. More documentation of these costs is necessary as provided in the EPA BART Guidelines 

which state, “The basis for equipment cost estimates also should be documented, either with data 

supplied by an equipment vendor (i.e., budget estimates or bids) or by a referenced source (such 

as the OAQPS Control Cost Manual...).4 In order to maintain and improve consistency, cost 

estimates should be based on the OAQPS Control Cost Manual, where possible. The Control 

Cost Manual addresses most control technologies in sufficient detail for a BART analysis.”5

 Of 

course, the presented costs per ton ($64,000 at a minimum) of emissions reduced, if 

substantiated, would make such an installation uneconomical. 

For the ESPs currently operating the State should analyze cost-effective ESP upgrade 

alternatives as per the EPA BART Guidelines, “...for retrofitting existing sources in addressing 

BART, you should consider ways to improve the performance of existing control devices, 

particularly when a control device is not achieving the level of control that other similar sources 

are achieving in practice with the same device. For example, you should consider requiring 

those sources with electrostatic precipitators (ESPs) performing below currently achievable 

levels to improve their performance.”6

                                                           

3

Ibid, See Section IV.E.5.

4 U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, OAQPS Control Cost Manual,

Fifth Edition, February 1996, EPA 453/B‐96‐001.

5 See 40 CFR Part 51, Appendix Y.  The U.S. Environmental Protection Agency finalized its BART Guidelines on June

15, 2005, and published the preamble and final rule text in the Federal Register on July 6, 2005.  The rulemaking

action added Appendix Y to Part 51, titled “Guidelines for BART Determinations Under the Regional Haze Rule.”  

See Section IV.D.4.Step 4.a.5.  

6 Ibid, See Section IV.D.3.Step 3.4.
Description of FLM Comments and CTDEP Responses 7/15/09 12 

The State determined that two BART-eligible facilities (Norwalk Power Unit 2 and Cascades 

Boxboard Group) had a de minimus impact of less than 0.1 deciview on the nearest Class I area, 

so as to not be subject to BART. The NESCAUM exemption modeling that documents these 

conclusions should be included in the SIP as an appendix. 

Considerations for the Alternative to BART Demonstration

If the State rules cited on page 9-2 of the draft SIP apply to sources beyond those subject to 

BART requirements and achieve more emissions reductions than the highest level of emissions 

reduction technology applied to only BART sources, the demonstration of an acceptable 

alternative to BART could be less rigorous than what we noted above. In such a case, the State 

should demonstrate the emissions reductions will occur during the first implementation period of 

the regional haze rule, 2000 through 2018. In addition, the expected emissions reductions form 

the non-BART facilities should not be substantially shifted geographically from where reductions 

would occur under a source-by-source approach to BART. Given the relatively small size of the 

State, the latter demonstration could be addressed by mapping locations of emission reductions 

expected from the program and inclusion of nearby Class I areas and highlighting the BART 

facilities. 

Response

CTDEP has added the following sentences to the “Timing” paragraphs of Sections 9.3.1 

(Analysis of CT’s Alternative BART Program for SO2) and 9.3.2 (Analysis of CT’s Alternative 

BART Program for NOx), respectively: 

“As can be seen in Tables 9-8 and 9-9, emissions reductions from Connecticut’s Alternative 

BART Program for SO2 occurred during the first implementation period of the regional haze 

rule, 2000 through 2018.” 

“As can be seen in Tables 9-13, 9-14 and 9-15, emissions reductions from Connecticut’s 

Alternative BART Program for NOx occurred during the first implementation period of the 

regional haze rule, 2000 through 2018.” 

Also, CTDEP has added maps including trends of potential emission reductions from the 

alternative SO2 and NOx programs with locations of the BART-eligible facilities and nearby 

Class I areas highlighted (Figures 9.5 and 9.7). CTDEP has added maps of actual emission 

trends for SO2 (2001, 2006, 2006) and NOx (1994, 2002, 2006) with locations of the BARTeligible facilities and nearby Class I areas highlighted to Attachment X. 

In response to comments received from EPA, CTDEP has also added a discussion of available 

control technologies for EGUs and industrial boilers in Section 9.2.3 and a new table (9-4) to 

Section 9.3, Connecticut’s Alternative Measures. The table lists all of the Post-2002 NOx 

Budget Program sources that are collectively referenced in the SO2 and NOx programs for 

alternative BART discussed in Section 9.3. The list includes the size of the unit. CTDEP has 

added text describing or referencing the table, including specific numbers of sources impacted, to 

Sections 9.3, 9.3.1 and 9.3.2. 
Description of FLM Comments and CTDEP Responses 7/15/09 13 

Finally, in response to a verbal concern voiced by the FLMs during the March 18, 2009 

consultation telephone call between CTDEP, the FLMs and EPA, CTDEP has removed 

references to case-by-case BART determinations in the following locations of the revised draft 

SIP: 

• Bottom of page 9-1 

• Bottom of page 9-13 

• Middle of page 9-16 

• Heading of fifth and sixth columns in Table 9-5 on page 9-18 

• Bottom of page 9-22 

• Top of page 9-23 

• Bottom of page 9-29 

CTDEP has substituted the term “case-by-case” with a more categorical type of terminology (all 

sources subject to BART, presumptive BART, etc.). 
Chuck Carlin, August 27, 2009, Regional Haze

I’m Chuck Carlin representing myself, and I would like to commend the Department on this particular

rule.  This has gotten appropriate attention levels and fits well within the Department’s current plans

and programs.  I caution that the Federal government does not mistakenly add a requirement that

requires Connecticut to meet the same emissions limits that we are now meeting but requires that the

state does so in a way that it is not now doing, which would create an additional limitation.  I don’t

believe this will happen but I thought I would mention it.   
,3,!-\

EO sr,q,.

\  .. 

1- 

( PRO

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 1

1 CONGRESS STREET, SUITE 1100

BOSTON, MASSACHUSETTS 02114-2023

August 14, 2009

MelTil y Gere

Connecticut Department of Environmental Protection

79 Elm Street

Hartford, CT 06106-5127

Dear Ms. Gere:

Thank you for the opportunity to review Connecticut's proposed Regional Haze State

Implementation Plan (SIP). EP A has reviewed your proposed SIP and has found that

most of our previous comments have been adequately addressed. Those include

comments provided by EPA on May 22 2008 on a preliminary draft of "Section 8 - Best

Available Retrofit Technology (BART)" and on April 3 , 2009 on the Connecticut's

February 2009 draft of the Regional Haze SIP.

Connecticut has scheduled a public hearing on its proposed Regional Haze SIP on August

2009. You wil find the Agency s comments on the proposal in the Enclosure.

Please address these comments before final submission of the Regional Haze Plan to

EPA.

If you have any questions on these comments, please contact Anne McWiliams at (617)

918- 1697.

Sincerely,

Anne Arnold, Manager

Air Quality Planning Unit

Enclosure

cc: Dave Wackter (CTDEP)

Wendy Jacobs (CTDEP)

Toll Free. 1-888-372-7341

Internet Address (URL) . http://www. epa.gov/region1

Recycled/Recyclable. Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)
Enclosure

EPA Comments on Connecticut'

Proposed Regional Haze SIP (August 2009)

0 Best Available Retrofit Technolol!V (BART)

1) Connecticut's proposed alternative to BART for SOz and NO appears reasonable.

However, EP A recommends that Connecticut provide some discussion of how costs were

considered in establishing the BART benchmark for SOz and NO

2) Page 9-30 states

, 

By comparing NO potential emissions reductions since 1994 from

all Post-2002 NO Budget Program sources with NO potential emissions reductions

since 1994 from BART-eligible units, it is evident that Connecticut s existing NO

regulatory requirements achieve greater NO reductions than from BART alone (see

Figure 9. 6). " EP A recommends that Connecticut follow this statement with a table

quantifying the tons of NO reduced by Connecticut's BART alternative vs. BARTeligible sources alone, similar to Table 9- 8 provided for SOz reductions.

3) The asterisk for Table 9- 14 on Page 9-32 indicates that the NO potential emissions are

based on the lower of RSCAsection 22a- 174-22 regulatory limits or federally

enforceable permit conditions." EPA recommends that Connecticut specify the

mechanism by which the permit is federally enforceable (for example, New Source

Review).

4) Connecticut's proposed determination that existing controls represent BART with

respect to PM appears reasonable. However, EP A recommends the following addition to

Connecticut's discussion to better demonstrate this conclusion.

The third paragraph on page 9-34 states

, 

MANE- VU' s 2002 individual unit modeling

shows that none of Connecticut s PM emissions from BART -eligible sources have a

significant visibility impact on any Class I area." EPA recommends that this statement

be elaborated by following it with a table of the PM visibility impacts from the BARTeligible sources. This wil help to demonstrate that, although the PM emission limits

imposed by Connecticut, as outlined on page 9- , are less stringent than the MANE- VU

recommended emission limits, they can be considered reasonable, since the highest PM

visibility impact from anyone BART unit is 0.0035 deciviews (as compared to the 0.

deciview impact considered in the MANE-VU recommended limits).

11.0 Lone-term Stratel!V

5) The MANE-VU long-term strategy includes the following for an "outer-zone" state

such as Connecticut:

#2 distilate oil to 0.05 percent (500 ppm) sulfur, by weight, by no later than 2014;

#4 residual oil to 0.25 percent sulfur, by weight, by no later than 2018;

#6 residual oil to 0. 5 percent sulfur, by weight, by no later than 2018;
Further reduction of the sulfur content of distilate oil to 15 ppm by 2018

contingent on supply and availability.

With respect to the reduction of sulfur in #2 distilate by 2014, Connecticut's proposed

Regional Haze SIP references Section 16a-21a of the Connecticut General Statutes

which limits fuel sulfur content of heating distilate oil and off-road diesel oil to 500 ppm

as of the date on which the last of the States New York, Massachusetts and Rhode Island

limit the sulfur content of such fuels. However, Connecticut should also explain the

mechanism by which the state plans to make this fuel sulfur content limit federally

enforceable. Also, EPA recommends that Connecticut work closely with New York

Massachusetts and Rhode Island to ensure that the 2014 milestone is met.

With respect to the remaining components of the MANE- VU low sulfur fuel oil strategy,

on page 11- , the proposal states

, 

Connecticut intends to adopt all reasonable control

measures as expeditiously as practicable, in a manner consistent with state law, so that

they may be in place by the end of the ten-year planning period. " Connecticut's Regional

Haze SIP submittal should include a schedule for the adoption of these measures.

Areas Contributine to Reeional Haze

6) The reference to 40 CFR 51.308(3)(iii) should be revised to 40 CFR 51.308iQ(3)(iii).
‐‐‐‐‐Original Message‐‐‐‐‐ 

From: Holly_Salazer@nps.gov [mailto:Holly_Salazer@nps.gov]  

Sent: Tuesday, August 25, 2009 4:45 PM

To: Wackter, David; Jacobs, Wendy

Cc: Dean_Gillam/FC/R9/FWS/DOI.FWS@nps.gov; Patricia_F_Brewer@nps.gov;

sandra_v_silva@fws.gov; Tim_Allen@fws.gov; Bruce_Polkowsky@nps.gov;

Copeland@cira.colostate.edu; rperron@fs.fed.us; mcwilliams.anne@epamail.epa.gov

Subject: DOI Review of draft RH SIP available for public review

Hi Dave and Wendy,

The U.S. National Park Service and U.S. Fish & Wildlife Service have

reviewed the July 2009 draft Connecticut Regional Haze SIP and

Connecticut's response to EPA and FLM comments that are now available for

public review.  We appreciate your consideration and response to the issues

we raised in our April 2009 Department of the Interior (DOI) comments.

We are pleased that DOI comments have been reflected in this recent draft

SIP.  We were particularly interested in how our concerns regarding further

information and analysis on alternatives to BART were addressed.  We are

satisfied that the draft SIP accurately documents how overall emissions

will be decreasing in the near future.  For future planning efforts, we

suggest highlighting even more this important relationship between the

change in emissions and the change in visibility in Class I areas.

We look forward to continued cooperation with Connecticut and MANE‐VU

during the next  planning stages of the regional haze process.

Sincerely,

Holly Salazer

************************************

Holly S. Salazer

National Park Service

Northeast Region

Air Resources Coordinator

Mailing Address:

National Park Service

207 Buckhout Lab

University Park, PA 16802

Phone: (814) 865‐3100

Fax: (814) 863‐7217
‐‐‐‐‐Original Message‐‐‐‐‐ 

From: Ralph Perron [mailto:rperron@fs.fed.us] 

Sent: Thursday, August 27, 2009 4:19 PM 

To: Wackter, David; Jacobs, Wendy 

Cc: mcwilliams.anne@epamail.epa.gov; Holly Salazer; Copeland@cira.colostate.edu; Charles E Sams 

Subject: USDA Forest Service response to CT draft RH SIP hearing notice 

Hi Dave and Wendy  

We appreciate receiving notice of your hearing with the link to the Connecticut DEP's RH SIP. The USDA 

Forest Service has no additional comments for the public hearing. We look forward to working with 

Connecticut and MANE-VU in the future.  

Thanks 

Ralph Perron, Air Quality Specialist, USDA Forest Service 

Allegheny, Green Mountain, Finger Lakes and White Mountain National Forests 

603-726-7178  

cell: (802) 222-1444 

email: rperron@fs.fed.us