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-V U 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, Charl es 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 Progres s" 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 ad vancement of the S1 and S2 strategies to include within Section 5.1, in close proximity to t he 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 BenM AP Draft Report

Opport unity To Comment

### MANE-VU

(Mid-Atlantic/Nor theast Visibility Union)

Dec ember 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 be low will assist in this process. Please see below for brief descriptions and links to more info rmation.

. MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportio nment, and Control

Measure Benefits

. Public Health Benefits of Reduc ing 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@ma rama.org.

MANE-VU Modeling for Reasonable Progress Goals Draf t Report

The main purpose of this report is to assist states in developing effective solutions to regional visibility and fine particle problems and comply wi th requirements under the Regional Haze Rule. Northeast States for Coordinated Air Use Management (NESCAUM) conducted regional air quality simulations for calendar year 2002 and seve ral 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 ap portionment for 2018, and the evaluation of visibility benefits of control measures being consi dered for achieving reasonable progress goals and establishing a long-term emission management st rategy for MANE-VU Class I areas.

This report describes efforts that form the foundat ion upon which MANE-VU states will base their haze SIP submissions. After the MANE-VU regional pl anning 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 co nducted to serve as a basis for calculating final reasonable progress goals.

Results show that sulfate aerosol, the dominant con tributor to visibility impairment in the Northeast's Class I areas on the 20 percent worst v isibility days, has significant contributions from states throughout the eastern U.S. These contributi ons are projected to continue in future years

from all three of the eastern RPOs.

An assessment of potential control measures that wo uld address this future contribution has identified a number of promising strategies that wo uld yield significant visibility benefits. These measures include the adoption of low sulfur heating oil, implementation of Best Available Retrofit Technology (BART) requirements, and additional elec tric generating unit

### (EGU) controls on select sources. The combined bene fits 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=31 Modeling%20for%20Reasonab le%20Progress%2012.10.07.doc

Public Health Benefits of Reducing Ground-level Ozo ne and Fine Particle Matter in the Northeast U.S. Draft Report

NESCAUM used the U.S. Environmental Protection Agen cy'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. asso ciated with various emission control programs in 2018. Future year air quality associated with im plementation of various control strategies was simulated using two air quality modeling platforms, the Community Multi-scale Air Quality modeling system (CMAQ) and the California Photochem ical Grid Model (CALGRID). NESCAUM examined the public health and monetary ben efits of several potential emission control programs under consideration by the Ozone T ransport Commission (OTC) and MANEVU states. These programs include an EGU control st rategy for nitrogen oxides (NOX) and sulfur dioxide (SO2) that increase the stringency of the c urrent Clean Air Interstate Rule (CAIR) and SO2 emissions control strategies that wo uld complement existing regulations to further reduce fine particle concentrations and imp rove visibility under the Regional Haze Rule. In addition, NESCAUM examined the benefits of achievin g several different levels of the National Ambient Air Quality Standard (NAAQS) for 8-hour ave rage ozone concentrations (NAAQS rollback).

The draft document is available at: http://filesharing.nescaum.org/download.php?file=36 6BenMAP_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 t hose comments received by January 9,

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

Please send comments and questions to Angela King a t 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 BART

### eligible 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 th e Interior (DOI) Comments March 16, 2009

GENERAL ISSUES

Issues of concern are:

- No analysis available for the “full” adop tion of the MANE-VU As k. 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 th e 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 equiva lency (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 deta ils or comparison to other states in the region.

At a minimum, the State should include a di scussion on the three cr iteria used by MANEVU to determine consultation. This would at l east provide context to what CT states as

their contribution. In additi on, 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 As k. However, in Section 3.2.2.2, Connecticut does not address all elements of the Ask, instea d 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 meas ures of the Ask over the next five years.

In Section 3.2.3, Connecticut im plies that addressi ng inconsistencie s with emission inventories, both within MANE-VU and out , “caused” most States to miss the 2007 statutory submittal to EPA. This statem ent 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, Co nnecticut should include language that commits the State to continuing su pport of the IMPROVE network.

In Section 5.3, the statement is incorr ect. Moosehorn Wilderness and Roosevelt Campobello International Park also share a monitoring site.

Emission Inventories

Section 6.0 is dedicated to the emission i nventory development by MANE-VU and used by Connecticut. For comparison of Table 6.1 an d 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 le vel 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 informati on identifying what the necessary reduction levels actually were.

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

from Attachment N in the text. As wr itten, 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 Dete rioration – The Stat e makes a clear link between its regional haze program and the impo rtance of the PSD program in helping to meet the goals of that program.

Fire

The State concludes that there is no in formation 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 ma nagement 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 al ready concludes that wood smoke is only a fraction of fine particle mass. Attach ment FF is listed as Connecticut Smoke Management Documentation.

## Comments/Issues Regarding the Best Available Retrofit Technology (BART) Provisions of the Co nnecticut Regional Haze SIP

The Connecticut Department of Envir onmental Protection (CDEP) has done a commendable job in the overall level of cont rol required of its BART-eligible sources (e.g., 0.3 percent sulfur fuel-oil). It stands out among all the st ates 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 perf orm 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-sour ce BART determinations may

conclude that additional contro ls are not cost-effective and th e existing proposed controls are BART. Nevertheless, these BART determina tions should be performed as an integral part of the demonstration of the “alternat ive measure” for BART as proposed by CDEP. 40 CFR 51.308 (e) (2) (i) (C) requires that a “d etermination 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 Guidelines 1 

### set SO 2 

### BART for oil-fired boilers as burning a 1.0 percent sulfur fu el-oil. CDEP then used th is definition as a de facto standard to show that a requirement of 0.3 pe rcent sulfur fuel-oil resulted in “greater reasonable progress” and the ability to use an “alternative measure” for BART. The assumption that SO 2 

### BART is the use of 1.0 percent sulf ur fuel-oil is not correct.

The EPA BART Guidelines state that you shoul d “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 c onsidered to be BART for o il-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 contro l options for sources subject to BART is described, it is stated that, “Best Availa ble Retrofit Technology (BART) means an emission limitation based on the degree of redu ction achievable thr ough the application of the best system of continuous emission reduction for each pollutant which is emittedby . . . [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 visibi lity 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 fo r each source in order to determine BART. Then, greater reasonable progr ess 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 alte rnatives to be considered for SO 2 

### BART for each emission unit include the applicability of usi ng 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 a nd 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 visi bility 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% re ductions. FGD is a well-demonstrated technology on oil-fired utility units in some other countries (e.g., Ja pan, South Korea and Cyprus).

The full five-factor SO 2 

### 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 PSE G New Haven Harbor Station Unit 1.

Once again CDEP is commended for its pa st efforts in implementing the ozone reasonably available control technology (RACT) provisions in the 1990s and NO

x 

### Budget Program for the NO

x 

### SIP Call to significantly reduce NO

x 

### emission limits. Using the same line of reasoning as discussed above for SO 2, 

### it is incumbent on CDEP to use a baseline emissions year (presumably 2001) and examine NO

x 

### BART control alternatives for each BART-eligible source.

Even though the EPA BART Guidelines stat e that combustion cont rol 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 NO

x 

### controls

to achieve BART should be considered at ea ch BART-eligible source to complete the full five-factor analysis. Oil-fired utility boile rs have a variety of combustion controls available, such as, low excess air, low NO

x 

### burners, over-fired air, flue gas recirculation and optimum staged combustion. Also, post-co mbustion alternatives such as Selective Non-Catalytic Reduction (SNCR) and Sel ective Catalytic Reduction (SCR) should be

considered at facilities where th ey do not currently exist.

3 Ibid, See Section IV.E.5.

### Regarding particulate matter (PM) controls at BART-eligible f acilities, Table 9-16 presents cost ranges for installing electro static precipitators (ESP) on sources not currently controlled for PM. More documentati on of these costs is necessary as provided in the EPA BART Guidelines which state, “T he 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 s ource (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, wh ere possible. The Control Cost Manual

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

### Of course, the astronomical costs per ton ($64,000 at a mi nimum) of emissions reduced according to the amounts presented would make such and installation uneconomical.

For the ESPs currently operating CDEP s hould analyze cost-effective ESP upgrade alternatives as per the EPA BART Guidelines , “. . . for retrofitti ng existing sources in addressing BART, you should consider ways to improve the performance of existing control devices, particularly wh en a control device is not ac hieving 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 le vels to improve their performance.” 6



### CDEP determined that two BART-eligible facilities (Norwalk Power Unit 2 and Cascades Boxboard Group) had a de minimi s 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 res ponse to the Connecticut Draft Regi onal 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 tech nical 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 T eam available to work with you and your staff

on all air resource issues that ar e of concern to the Forest Serv ice’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 Ag ency, 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 comp leteness and provide final approval.

We would appreciate a response re garding our comments per Sect ion 51.308(i)(3) of the CFR. Please contact Mr. Perron if you have technical qu estions 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 Serv ice has reviewed the C onnecticut Draft Regional Haze State Implementation Plan (SIP) dated Fe bruary 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 C ode of Federal Regulatio ns (CFR) per section 40 CFR 51.308(i)(3). For further information rega rding 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 Enclos ure 2. That letter discussed our perspectives relevant to Regional Haze SIP preparation.

Overall Comments:

We are interested in the Conn ecticut Regional Haze SIP becaus e 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 Cont ribution Assessment). Overall, Connecticut has done a commendable job compiling the Regiona l Haze SIP and addressing the requirements of the Regional Haze Rule. The following sectio ns 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 s hould include additiona l discussion of how the Connecticut specific emissions (present ed in Tables 6.1 & 6.2) were generated.

 We would like Connecticut to commit to tr acking emissions annually and reporting how the projected emissions compare to actual em issions 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 contri bution to visibility impairment at other

States’ Class I areas in Section 2 of the Draf t 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 di scussion be added to Secti on 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 establishe d by the States of Maine, New Hampshire, Vermont and New Jersey for their Class I area s. 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 sour ce retirement and replacement schedules and refers to Table B-5 in Attachment N for sp ecific sources. Table B-5 in Attachment N does not specifically identify Connecticut sour ces 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 info rmation 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 Dr aft CT RH SIP)

 We agree that based on existing inventorie s of smoke emissions from wildfires and prescribed fires, they are not a significant emission source fo r Connecticut or a significant contributor to regional haze in downwind Class I ar eas at this time. It would be helpful to add a reference to the specific sections in Attachme nt V which support this claim. Also, we request that Connecticut commit to track smoke emissions in the future to help

determine the level of contribu tion 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 Retrof it Technology (BART) (Section 9 of Draft CT RH SIP)

 No comments.

Additional Suggestions:

 Section 5 discusses the monitoring strategy be ing used to assess visibility conditions. Even though Connecticut does not have any Clas s I areas, this sect ion demonstrates the importance of continued operation of the IM PROVE monitoring netw ork. We ask that Connecticut add a statement expressing thei r 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 partic ipated with neighboring states and tribes in the Central States Regional Ai r 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 Fi sh 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 seeki ng a close working relations hip with every state in this SIP writing process, the expectation is to sh are ideas from across the nation. The objective of every SIP is to play a critical role in a national emissi ons reduction plan.

Enclosed are detailed perspectives pertinent to the SIP prepara tion. 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 throughou t the required 60-day comment period, sharing our best insights and recommendations. A nn will also work with others on our staff, especially our National Haze Coordi nator, Ann Mebane and the Depart ment of Interior. Ann can be contacted at (307) 587-4597 or amebane@fs.fed.us

.

As required in the RHR, please identify, at your ea rliest convenience, your ke y point(s) of contact. Send all correspondence electroni cally 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 Consu ltation with the United States Department of Agriculture (USDA) Fo rest Service (FS) September 2006

The following perspectives are merely suggest ions or recommendations not direction or requirements. They are deliberately very similar to those prepared by the De partment of Interior to contribute to a common sense of purpose for improv ing haze in all Class I areas. We are sending these perspectives to each state. In so doing, we hope to facilitate inter-st ate coordination. At the same time, we fully acknowledge the discretion afforded in th e 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 differe nt state might consider including discussion and

conclusions on these factors in their individual plans.

The basic calculation of baseline, natural condit ion, and uniform rate builds the foundation for the entire RHR State Implementation Plan (SIP) proce ss. 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 resu lting 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 base d on equations recommended by th e Interagency Monitoring of Protected Visual Environments (IMPROVE) steer ing 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 th ese 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 inve ntory used to evaluate model performance; a typical base-year inventory that represents the fi ve year, average state which establishes modeled visibility impacts; and various future year, contro lled inventories that demonstrate future visibility conditions. Consider adding future year inventories that are clearl y partitioned to delineate source types (by text, charts, or graphics ) that are included in each model simulation. Benefits to future visibility conditions suggested in th e SIP that are not also clearly li nked to a future inventory or are not clearly included in future model analys is, will warrant additional discussion.

One part of your emission inventory includes th e implementation of “Best Available Retrofit Technology” (BART) on a subset of pre-Preventi on of Significant Deterioration sources. The BART source identification, elimination, and level de termination will be of particular interest for review. We would prefer to see a clear progr ession 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 indivi dual or grouped source categories.

### Area of Influence The area of influence of significant visibility-impai ring sources is an important SIP element. We suggest that that each state cl early identify and apporti on by state, or other geographic means, the significant levels of pollutants c ontributed to each Class I area by source. Developing this information together with neighborin g States and Tribes will facilita te 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 c ontributions by geographic area may or may not clearly describe progress over time.

Reasonable Progress Goals and Long Term Strategy Establishing reasonable progre ss goals for Class I areas in your state and/or acknowledging reasonable progress goals for Class I areas in other states that ar e affected by emissions from your state, as well as defining associ ated 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 reason able 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 ar eas. We feel that this uniform rate of progress assessment is useful in determini ng 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 eq ual 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 lo cal and regional emission strategies have been fully examined; and (3) how consistent assessments and st rategies are applied regionally.

For Class I areas where the reasonable progress go al is more impaired than the uniform rate of progress, consider presenting in formation on a component basis. Components could consist of emission source category as before, but also include contributions from indi vidual 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 c ontrol 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 a ddresses all anthropogenic sources of visibility impairment, including fire. The RHR requires co nsideration 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 si gnificant visibility reduction in Class I areas. If

fire contributes to the index us ed to track long-term, reasonabl e progress in a Class I area, the visibility SIP should identify how it will be addressed. Your st ate may already have a smoke management program (SMP) that adequately describe s how visibility impairment from fire will be

### addressed. If fire has been determin ed 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 st ate has a SMP, is it a basic smoke management program or an enhanced smoke management plan? And has th e 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 whic h smoke from agricultural burning and forest fires are treated? Is there a difference in the way emis sions from wildfire, prescribed fire, and wildlandfire-use (WFU) fire are identified and trea ted on private, state, and federal lands?

Regional Consistency The RPOs have been working toward regionally-c onsistent 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 know s what emission control methods or air quality management strategies work best for its areas. Each state ma y wish to develop strategies that are independent from RPO or neighboring areas.

In this context, our review of “regional consiste ncy” 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 evalua te if neighboring SIPs (or portions of SIPs) are

released for review at different times. We expect th at thorough inter-state consultation processes will lead to consistent descriptions of apportionm ent 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 veri fication and even less on contingency planning. By rule, each SIP must identify the monitoring data used to specify th e original baseline and also as part of an ongoing progress revi ew at five year intervals.

Given the uncertain future of any individual moni toring site, we suggest that the SIP address the representation of both primar y and alternative data site s 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 em issions growth, changes to the geographic distribution of emissions, and subs tantive 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 abil ity to achieve the emissions re ductions 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 FL M 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 speciali st 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 Agen cy (EPA) Comments on Connecticut’s Draft
Regional Haze State Implementation Plan (SIP) a nd Connecticut Department of Environmental
Protection (CTDEP) Responses

CTDEP appreciates the time and ef fort 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 stak eholders 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 st ate to establish reas onable progress goals for visibility improvement and to formulate a long-term strate gy 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, visi bility 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 T able 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 incl ude 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 impa irment 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 s hould be revised as follows:

“...about half of the worst visibility days in th e New Hampshire Class I Areas occur in the summer when meteorological conditions are more co nducive to the formation of sulfate from

SO 2 and to the oxidation of organic aerosols. In addition, winter and summer transport patterns are different, possibly leading to different contributions from u pwind source regions. As a result, T he 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 Respons es 7/15/09 2

Comment

Table 6.1 indicates that EGU Point SO 2 

### emissions were 2,438 tons in 2002. Table 6.2 indicates

that EGU Point SO 2 

### emissions in 2018 are expected to be 6,697 tons. Connecticut should explain why SO 2 

### emissions are expected to increase so significantly. Response

The EGU Point and non-EGU Point SO 2 

### emissions in Table 6.1 were inadvertently reversed.

The EGU Point SO 2 

### emissions in Table 6.1 should be 13,550 tons and the non-EGU Point SO 2 

### emissions in Table 6.1 should be 2,438 t ons. CTDEP has corrected the tables.

Chapter 8: Understanding the Sources of Haze-Causing Pollutants

Comment The reference cited for Figure 8.11 appears inac curate. Please correct this reference. Response CTDEP has changed the (EPA, 2005) refere nce in Section 8.3.1, Sulfur Dioxide (SO 2 

### ) to (MARAMA, 2005).

Comment In the second paragraph of Section 8.3.1, Connectic ut states, “Most states in the region showed

declines in annual SO 2 

### 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 afte r the first paragraph in Section 8.3.1, Sulfur Dioxide (SO 2 

### ) as follows:

“Figure 8.11 shows SO 2 

### emissions in the MANE-VU states as extracted from the 2002 MANEVU inventory (MARAMA, 2005).

### Description of EPA Comments and CTDEP Respons es 7/15/09 3

Figure 8.11: Annual Sulfur Dioxide (SO 2 ) Emissions, by State

0.0 0.2 0.4 0.6 0.8 1.0 1.2

Connecticut

De

l aw

are

D

i s t r ic

t of

C

olumbia Maine

M

a ryland

Ma

s sa

c hu

s ett

s

Ne

w

Ha

mp

sh

i re

Ne

w

J

erse y New York

Pe

n

ns

y l v an

i a
Rho d e Island

V

er

mo

ntmillion t/y MV 2002 v.3



### The bar graph in Figure 8.12 displays the percen tage contributions from different emission source categories to annual SO 2 

### emissions in the MANE-VU states in 2002. The chart shows that point sources – consisting ma inly of stationary combustion s ources for generating electricity, industrial power, and heat – dominate SO 2 

### emissions in the region.

### Description of EPA Comments and CTDEP Respons es 7/15/09 4

Figure 8.12: 2002 Sulfur Dioxide (SO 2 ) Emissions, by State

Bar Graph = Percentage Fractions of Four Source Categories

Line Graph = Total Annual Emissions (10 6 tpy)

0% 25% 50% 75% 100%

Con n ect

ic

ut

D

ela

wa

r e

D

istr

ict

of

Co

lu

mbia Ma i n e

M a rylan d Massachusetts

N

ew

H

ampshire New Jersey

N

e w

Y

o rk

Pe

n ns

yl

va

n ia

Rho d

e I sl

a n d

V e rmo n t 0.0 0.2 0.4 0.6 0.8 1.0 1.2million 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 SO 2 

### emissions through 2002 compared with those from previous inventories.

Table 8.2 MANE

‐ VU 1990, 1996 and 2002 SO 2 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 impl ementation 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 Respons es 7/15/09 5

Smaller stationary combustion sources, referred to collectively as area sources, are another important source category in the MANE-VU st ates. These include smaller industrial, commercial, and institutional boilers as well as re sidential heating sources. By contrast, on-road

and non-road mobile sources make a rela tively minor contribu tion to overall SO 2 

### emissions in the region (NESCAUM, 2001a).”

Chapter 9: Best Availabl e 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, SO 2 

### and PM control technologies for EGUs and Industrial Boilers, th e EPA Guideline for BART Determinations, and the MANE-VU BART Workgroup recommended emission limits for NOx, SO 2 

### and PM.

Currently available control technolo gies for EGUs and Industrial Boilers

NOx

Firing Configurations and Firing Practices

Firing configuration and firing pr actices can result in a 5 to 60% reduction in NOx formation. Firing configuration is a design ch aracteristic of the boiler. Firi ng practices include such things as low excess air, flue-gas recirculation, st aged 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 av ailable in the combustion zone. These methods may change the normal operation of the boiler an d the effectiveness is boiler-specific. Implementation of these techniques may also reduce operational flexibil ity; however, they may reduce NOx by 10 to 20% from uncontrolled levels.

Flue-gas recirculation involves re inserting 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 combus tion 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 reducin g the formation of thermal NOx.

### Description of EPA Comments and CTDEP Respons es 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 bo ilers or retrofitted on older units. Low NOx burners have been shown to reduce NOx formation by 35-55%.

Fuel substitution requires burning fu el with a lower nitr ogen content to inhi bit the production of

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

will be.

Overfire Air

Overfire air involves injecting a portion of the total combustion ai r 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 cool er 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 ther mal NOx formation. Overfire air can reduce NOx emissions by 20-30%.

Water/Steam Injection

Water or steam can be injected into the boile r combustion zone to re duce 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 techni que that involves injecting a mmonia or urea into specific temperature zones in the upper furnace or convect ive pass. The ammonia or urea reacts with NOx in the flue gas to produce nitrogen and wa ter. The effectiveness of SNCR depends on the temperature where reagents are in jected; mixing of the reagent in the flue gas; residence time of the reagent within the required temperature window; ratio of r eagent to NOx; and the sulfur content of the fuel that may create sulfur co mpounds 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 re ductions of 35 to 60% have been achieved.

Selective Catalytic Reduction (SCR)

SCR is another post-combustion te chnique 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, part iculate 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 velo city, and catalyst condition. NOx emission

reductions of 75 to 90% have been achieved through the use of SC R on oil-fired boilers operating in the U.S.

SO 2



### Wet Flue Gas Desulphurization (FGD)

FGD processes use an alkaline reagent to absorb SO 2 

### in the flue gas and produce a sodium or a calcium sulfate compound. These solid sulfat e compounds are then removed in downstream

### Description of EPA Comments and CTDEP Respons es 7/15/09 7

equipment. Wet regenerable, meaning the reag ent material can be tr eated and reused, FGD processes are attractive because they have the potential for be tter than 95% sulfur removal efficiency, have minimal waste water discharges , and produce a saleable sulfur product. Some of the current nonregenerable calcium-based proc esses can, however, produce a saleable gypsum product.

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

as the SO 2 

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

SO 2 

### . Lime/limestone scrubbers, sodium scrubbers, and dual alkali scrubbing are among the commercially proven wet FGD systems.

Low-Sulfur Fuels

SO 2 

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

of sulfur in the fuel will reduce SO 2 

### 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 equipmen t. The collection efficiency for larger particulate matter (PM greater than 10 microns) typically runs around 85%.

Electrostatic Preci pitators (ESPs)

When particle-laden gases pass through an ESP, th e 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 precipit ator 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, inco rporates multiple fabric bags/fil ters 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 co hesion characteristics, and particle electrical resistivit y. Operational parameters that a ffect collection efficiency include air-to-cloth ratio, operating pressure loss, cl eaning sequence, interval between cleaning, and cleaning intensity. The structure of the fabric filter, filter co mposition, 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 Respons es 7/15/09 8

Scrubbing systems involve the injection of chemicals and/or water into the fl ue gas to inhibit the physical or chemical absorption of particles or ga seous 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 Connectic ut’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 aime d at reducing emissions of SO 2 

### and NOx from a large universe of in-state sources.” Connecticut should include more in formation regarding the universe of sources impac ted by these additional re gulatory measures. Speci fically, 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 Altern ative Measures (see Attachment 1). The table lis ts all of the Post-2002 NOx Budget Program sources that are collectively referenced in the SO 2 

### and NOx programs for alternativ e 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 numb ers of sources impacted, to Se ctions 9.3, 9.3.1 and 9.3.2 as follows:

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

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

(highlighted), that are a ddressed in the following di scussions on Connecticut’s SO 2 

### and NOx

Programs for Alternative BART.”

Section 9.3.1, Connecticut’s SO 2 

### 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 li sted in Table 9-4)”

Section 9.3.2, Connecticut’s NO

x 

### Program for Alternative BART Added following language to Summary of Revisi ons 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 Respons es 7/15/09 9

Chapter 11, Long-Term Strategy

Comment In the second paragraph of Section 11.4.2, Connecticut discusses possible logi stical 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 C onnecticut’s SIP. The DEP should either explain how this might be relevant to Connecticut’s abi lity 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, “t o 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 re duced to 0.05 percent (500 ppm) sulfur, by weight, by no later than 2014. Response CTDEP has revised the second paragraph (forme rly the third paragraph) of Section 11.4.2, LowSulfur Oil Strategy, as follows:

“The MANE-VU states agree that a fuel sulf ur content limit on residual oil and distillate oil is reasonable to pursue over the next ten ye ars. CTDEP will review the details of this strategy in five years, coincident with C onnecticut’s first regional haze SIP progress report. Section 16a-21a of the Connecticut General Statutes li mits fuel sulfur content of heating distillate oil and off-ro ad diesel oil to 500 ppm as of the date on which the last of the States New York, Massachusetts and Rhode Island limit the sulf ur content of such fuels. Therefore, implementation of this strategy in Connecticut is dependent upon adjacent states’ implementation. CTDEP conti nues 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 Depa rtment of Public Uti lity 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 th at a certain number of older plants will be replaced by newer units to meet future electric growth and state-specific NO X 

### and SO 2 

### caps, Connecticut did not directly rely on the closure of any particular plan t in establishing the 2018 inventory upon which the reasonab le progress goals were set.

### Description of EPA Comments and CTDEP Respons es 7/15/09 10

The modeling used to develop the 2018 emissions i nventory appears to pred ict that several large EGUs in Connecticut, including fi ve of the six BART-eligible EGUs (Middletown Power 3 & 4, Montville Power 6, Norwalk Power 2 and PSEG Po wer 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

SO 2 

### reductions. Connecticut should also summarize any additional programs the state plans to implement that will lead to vi sibility improvements. For exa mple, 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 vi sibility 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 envi ronmental 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 statut e, CTDEP continues to gather and evaluate information concerning OWBF emissions and to learn from the success of surrounding states with more stringent regu latory programs for OWBFs. A doption of performance standards for new OWBFs would be most effectively pursu ed by EPA since the sales market includes the

entire northern United States.

In addition, in 2005 CTDEP adopted RCSA sec tion 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 th an the federal Tier 2 motor vehicle emissions standards. An analysis pr ovided by Cambridge Systemics for NESCAUM finds that the California LEV II program provides an additiona l 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 Genera l Statutes prohibits the construction a nd use of an OWBF unless the OWBF is
located more than 200 feet from any residenc e, meets certain stack height criteria and the owner complies with certain operatin g practices, including a requiremen t to burn only clean wood.

### Description of EPA Comments and CTDEP Respons es 7/15/09 11

federal Tier 2 program is expect ed to achieve. Reduced formati on of secondary organic aerosol is likely another benefit of th e California LEV II program.”

Comment Section 11.11 discusses enforceability of emissi on limitations. In orde r to ensure federal enforceability, Connecticut should submit to EPA as a SIP revision any regul ations 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 para graph of Section 11.11 as follows:

With respect to control measures for visibil ity 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-1 74-19a have applied to all of the BART eligible units since 2002/2003 ( 0.5% fuel sulfur content or 0.55 lb/MMBtu quarterly SO 2 

### emission limit for non-EGUs; 0.5%/0.3% fuel sulfur content or 0.55 lb/MMBtu/0.33 lb/MMBtu quarterly SO 2 

### emission limits for EGUs). CTDEP has submitted the emission

limits of RCSA section 22a-174-19a to EP A 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 NO

x 

### emission limit (effective October 2003) federally enforceable. The approval request is pending.

• CTDEP will incorporate existi ng PM controls at the BART-e ligible units into Title V permit renewals for BART purposes. Two of Connecticut’s BART-e ligible units with PM controls have federally enforceable New S ource Review permits (see Table 9-16). In addition, CTDEP submitted the current versi on of RCSA section 22a-174-18 to EPA for SIP approval on December 1, 2004. The approval request is pending.ATTACHMENT 1Table 9-4: Universe of SourcesAddressed in Connecticut’s SO2and NOx Programs for Alternative BART (Post-2002 NOxBudget Program Source, Unit ID, Location, Size) (BART-eligible units are highlighted; Acid Rain Program units areboldfaced)AES Thames, Unit A, Montville, 200 MWMilford Power Company LLC 1, Milford, 272 MWAES Thames, Unit B, Montville, 200 MWMilford Power Company LLC 2, Milford, 272 MWAlgonquin Power Windsor Locks, 38 MWMontville Power LLC, Unit 5, Montville, 81 MWConnecticut Jet Power, Branford, 20 MWMontville Power LLC, Unit 6, Montville, 410 MWBridgeport Energy 1, Bridgeport, 170 MWPSEG Power Connecticut LLC, Unit 1, New Haven, 465 MWBridgeport Energy 2, Bridgeport, 170 MWNorwalk Power LLC, Unit 1, Norwalk, 172 MWPSEG Power Connecticut LLC, Unit 2, Bridgeport, 170 MWNorwalk Power LLC, Unit 2, Norwalk, 172 MWPSEG Power Connecticut LLC, Unit 3, Bridgeport, 410 MWNorwalk Power LLC, Unit 10, Norwalk, 20 MWPSEG Power Connecticut LLC, Unit 4, Bridgeport, 22MW Norwich DPUC, Norwich, 20 MWCapitol District Energy Center, Hartford, 55 MWPfizer Inc, Boiler 5, Groton, 399 MMBtu/hrCascades Boxboard Group - Connecticut LLC, Versailles, 275 MMBtu/hr Pfizer Inc, Boiler 8, Groton, 267 MMBtu/hrConnecticut Jet Power, Cos Cob 10, Greenwich, 20 MWPratt & Whitney Cogen, East Hartford, 32 MWConnecticut Jet Power, Cos Cob 11, Greenwich, 20 MWCRRA, South Meadow 11A, Hartford, 20 MWConnecticut Jet Power, Cos Cob 12, Greenwich, 20 MWCRRA, South Meadow 11B, Hartford, 20 MWDevon Power LLC, Unit 7, Milford, 109 MWCRRA, South Meadow 12A, Hartford, 20 MWDevon Power LLC, Unit 8, Milford, 109 MWCRRA, South Meadow 12B, Hartford, 20 MWDevon Power LLC, Unit 10, Milford, 20 MWCRRA, South Meadow 13A, Hartford, 20 MWDevon Power LLC, Unit 11, Milford, 40 MWCRRA, South Meadow 13B, Hartford, 20 MWDevon Power LLC, Unit 12, Milford, 40 MWCRRA, South Meadow 14A, Hartford, 20 MWDevon Power LLC, Unit 13, Milford, 40 MWCRRA, South Meadow 14B, Hartford, 20 MWDevon Power LLC, Unit 14, Milford, 40 MWConnecticut Jet Power, Torrington Terminal, Torrington, 20 MWConnecticut Jet Power, Franklin Drive, Torrington, 20 MWFirstLight Power Resources Services, Tunnel, Preston, 20 MWLake Road Generating Company 1, Killingly, 264 MWWallingford Energy 1, Wallingford, 50 MWLake Road Generating Company 2, Killingly, 264 MWWallingford Energy 2, Wallingford, 50 MWLake Road Generating Company 3, Killingly, 264 MWWallingford Energy 3, Wallingford, 50 MWMiddletown Power LLC, Unit 2, Middletown, 117 MWWallingford Energy 4, Wallingford, 50 MWMiddletown Power LLC, Unit 3, Middletown, 245 MWWallingford Energy 5, Wallingford, 50 MWMiddletown Power LLC, Unit 4, Middletown, 400 MWWaterside Power 4, Stamford, 23.2 MWMiddletown Power LLC, Unit 10, Middletown, 20 MWWaterside Power 5, Stamford, 23.2 MWWaterside Power 7, Stamford, 23.2 MWDescription of EPA Comments and CTDEP Responses 7/15/0913

### Description of Federal Land Manager (FLM) Co mments 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 C onnecticut’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 di scuss the agencies’ comments was held on March 18, 2009, with repres entatives from NPS, U.S. Forest Service (USFS), USFWS, EPA, and CTDEP in attendanc e. 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 U SFS’ 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. CTDE P firmly supports, and is committed to, the interagency consultative process and looks forwar d to a continuing workin g relationship with the FLMs as we convey the myriad of technical requirements inherent in clean air regulations and other programmatic nuances in Connectic ut’s air pollution control programs.

USDA Forest Service comments Section 6, Emissions Inventory

Comment The discussion of emissions inventories is gene ric 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 Ta bles 6.1 & 6.2) were generated. Response

CTDEP has added references to locations of Connecticut-specific language for deriving emissions in Attachment M (Technical S upport Document for 2002 MANE-VU SIP Modeling Inventories, Version 3) underneath Table 6.1:

“Descriptions of how the Connecticut 2002 specifi c emissions were generated can be found in Attachment M (EGU Point, Non-EGU Point – pa ges 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 Pr ojection Inventories for SMOKE/MOBILE6 Application) underneath Table 6.2:

“Descriptions of Connecticut-specific adjustme nts 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 Ar ea growth factors – page 3-4, control measures
- pages 3-9, 5-20 through 5-22) and Attachment O (Mobile source activ ity input data and
scenario input files – page 3, SMOKE-related files – page 4). No Connecticut-specific
adjustments were made to the EGU Point, N on-Road Mobile and Bi ogenic inventories.”

### Description of FLM Comments and CTDEP Respons es 7/15/09 2

Comment

We would like Connecticut to commit to trac king emissions annually and reporting how the projected emissions compare to actual emissi ons in the mid-course review due in 2012 and required SIP revision due in 2018. Response

While CTDEP would like to commit to the e nhanced tracking and reporting as requested by USDA, given the state’s current fi scal constraints we cannot support this effort at this time. However, if USDA would like to support this e ffort, CTDEP would be willing to track and report the requested information. In the alternativ e, CTDEP will continue to annually track and triennially report emissions, as follows by a dding the following language to Section 6.4: “CTDEP will be preparing a periodic emission i nventory 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 SI P progress report and requir ed SIP revision due in

2018.”

Section 2, Areas Contributing to Regional Haze

Comment The discussion regarding Connecticut’s contributi on to visibility impairm ent at other States’ Class I areas in Section 2 of th e 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 SO 2 

### annual impacts at northeast Class I Areas as compared with

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

northeast Class I Areas when cons idering all MANE-VU states.

### Description of FLM Comments and CTDEP Respons es 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 visibi lity impairment in the MANE-VU Class I Areas

has direct relevance to the c onsultation 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 Respons es 7/15/09 4

1. Any state/region that contributed 0.1 μ g/m 3 

### 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 sulf ate observed on the 20 percent worst visibility days in 2002, and

3. Any state/region among the top te n contributors on the 20 percen t worst visibility days in

2002.

For the purposes of deciding how broadly to cons ult, the MANE-VU States settled on the second of the three criteria: any state/region that cont ributed at least 2 percent of total sulfate observed on the 20 percent worst vi sibility 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 a ny 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 th e haziest days and prevention of visibility degradation on the clearest days. Section 8.2 includes additional di scussion regarding individual state contributions to regi onal haze at Class I areas.”

Sections 10 and 11, Reasonable Prog ress Goals and Long Term Strategy

Comment

Since Connecticut has no Class I ar eas, it is acceptable to state t hat Connecticut agrees with the reasonable progress goals establis hed 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 asse rting that emissions from Connecticut reach West Virginia (0.04 percent) and Virginia (0.08 percent). CTDEP has adde d 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 replacemen t schedules and refers to Table B-5 in Attachment N for specific so urces. Table B-5 in Attachment N does not specifically identify Connecticut sources that ha ve been shutdown – it appea rs to list all sources in the MANE-VU region. A table identifying speci fic sources in Connecticut that have shut down should be added to Section 11.5. Are there any other sources that ar e planning to shut down before 2018? If information is available for an y 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 Depa rtment of Public Uti lity 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 Respons es 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 NO X 

### and SO 2 

### caps, Connecticut did not directly rely on the closure of any particular plan t in establishing the 2018 inventory upon which the reasonab le progress goals were set.

The modeling used to develop the 2018 emissions i nventory appears to pred ict that several large EGUs in Connecticut, including fi ve of the six BART-eligible EGUs (Middletown Power 3 & 4, Montville Power 6, Norwalk Power 2 and PSEG Po wer 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 in ventories of smoke emissions from wildfires and prescribed fires, they are not a sign ificant emission source fo r Connecticut or a sign ificant contributor to regional haze in downwind Class I areas at this ti me. 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 speci fic 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 pa ragraph at the en d of Section 11.7:

“CTDEP’s Bureau of Air Manage ment currently obtains wildfire and prescribed burning data, including number of acres burned, when the w ildfire or prescribed burn occurred and the location of the wildfire or pres cribed burn, from CTDEP’s Forest ry Division. The wildfire and prescribed burning data will be included in CTDE P’s periodic inventory every three years.

CTDEP will track smoke emissions from wildfire s 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 Respons es 7/15/09 6

Additional Suggestions Section 5, Air Monitoring Strategy

Comment Section 5 discusses the monitoring strategy bei ng used to assess visibi lity 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 c ontinued operation of th e IMPROVE network as requested by USDA, given the state’s current fi scal constraints we ca nnot support an unqualified

statement of commitment at this time. Howeve r, if USDA would like to support this effort, CTDEP would certainly be willing to do so. In th e alternative, CTDEP will continue to use these data sources and has added the following la nguage 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 visibi lity impairment and documen ting progress toward national visibility goals for Class I areas under the Re gional 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 IM PROVE network. CTDEP will work with other

states and the FLMs to maintain the IMPROVE ne twork 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 quali ty modeling is sometimes difficu lt to follow and has added the following language to Section 7.1, Meteorolog y to help clarify the modeling effort:

“The analyses show that in general, the perf ormance of the MM5 is reasonable both at the surface and in the vertical, thereby providing conf idence in the use of these data in the CMAQ

simulations.”

CTDEP has revised Paragraph 2 of Sec tion 7.3, Model Platforms, as follows:

NYSDEC performed an extensiv e model performance analysis to evaluate CMAQ model predictions against observations of ozone, PM 2.5 

### , and other pollutant species. In general, the CMAQ results were best for daily maximum O3 and daily average PM 2.5 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 concen trations can lead to large biases on a composite basis. It is important to demonstrate that th e model performs reasonably over th e diurnal cycle, not just in terms of daily maximum or average values. Also, it is important to demonstrate that the model can reproduce concentrations a bove the ground level. This m odel performance evaluation is

described in detail in NYSDEC’s techni cal 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 Respons es 7/15/09 7

modeling, and reasonable correspondence with measurements for many species, make REMSAD an important source apportionment tool for M ANE-VU. A model performance evaluation for

PM 2.5 

### species, aerosol extinction coefficient, a nd the haze index is provided in NESCAUM’s report, “MANE-VU Modeling for Reasonable Progr ess Goals, Model Performance Evaluation, Pollution Apportionment, and Control Measure Be nefits,” February 7, 2008 (Attachment G).

### Description of Federal Land Manager (FLM) Co mments 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 C onnecticut’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 di scuss the agencies’ comments was held on March 18, 2009, with repres entatives from NPS, U.S. Forest Service (USFS), USFWS, EPA, and CTDEP in attendanc e. 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 Ap ril 8, 2009. CTDEP’s responses to the NPS/USFWS’ comments are described below (USFS comments/respons es are in a separate document).

CTDEP appreciates the effort put forth by N PS and USFWS in crafting these very helpful comments. CTDEP firmly supports, and is comm itted to, the interagency consultative process

and looks forward to a continui ng working relationship with the FLMs as we convey the myriad of technical requirements inherent in clean air regulat ions and other programmatic nuances in Connecticut’s air pollution control programs.

National Park Service and U.S. Fi sh and Wildlife Service comments

Overall Comments

Comment In general, we are concerned the draft SIP doe s not include an analysis for the full adoption of the MANE-VU Ask (Ask). The draft SIP appe ars 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 availabl e retrofit technology (BART ) requirements. The draft SIP is unclear with respect to the State’s approach to m eeting BART requirements. The SIP and supporting documentation are not sufficie nt 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 ad equacy of that alternative approach should be presented in the SIP. Please see our co mments 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 need s to include a summary of the

Contribution Assessment. The draft SIP states that Connect icut emissions have measurable impacts on Class I areas, but prov ides no details or co mparisons to other st ates’ impacts in the region.

### Description of FLM Comments and CTDEP Res ponses 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 woul d at least provide context to w hat Connecticut determines as their contribution. In addition, the draft SI P should provide percent contributions of neighboring states to better understand the magnitude of the St ate’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 SO 2 

### annual impacts at northeast Class I Areas as compared with

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

northeast Class I Areas when cons idering all MANE-VU states.

### Description of FLM Comments and CTDEP Res ponses 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 visibi lity impairment in the MANE-VU Class I Areas

has direct relevance to the c onsultation 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 Res ponses 7/15/09 4

1. Any state/region that contributed 0.1 μ g/m 3 

### 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 sulf ate observed on the 20 percent worst visibility days in 2002, and

3. Any state/region among the top te n contributors on the 20 percen t worst visibility days in

2002.

For the purposes of deciding how broadly to cons ult, the MANE-VU States settled on the second of the three criteria: any state/region that cont ributed at least 2 percent of total sulfate observed on the 20 percent worst vi sibility 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 a ny 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 th e haziest days and prevention of visibility degradation on the clearest days. Section 8.2 includes additional di scussion regarding individual state contributions to regi onal haze at Class I areas.”

Section 3, Regional Planning and Consultation

Comment In Section 3.2.2, Connecticut agr ees 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 re view the viability of the remainder of the Ask in the 2013 review. It is inconsistent language to conclude the Stat e 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 w ith following section) “Connecticut, being a MANE-VU memb er state, participated in the development of the MANEVU “Ask” which was approved by the MANE-VU Bo ard 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 Ava ilable Retrofit Technology (BART)).

• All of Connecticut’s BART-eligible sources, as well as all NO

x 

### Budget Program/CAIR sources, meet the recommended residual oil cont ent 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 sect ion 22a-174-19a. In terms of a state-wide limitation of #4 residual oil to 0.25-0.5% by we ight by no later th an 2018, and of #6 re sidual oil to no greater than 0.5% sulfur by weight by no la ter than 2018, CTDEP has done a preliminary analysis of the potential number of sources impacted. Given regiona l fuel supply issues, such a limitation in Connecticut is dependent on multi-state implementation. CTDEP continues to participate in consultations w ith other MANE-VU states to develop a low sulfur heating strategy consistent with the MANE-VU “Ask”.

### Description of FLM Comments and CTDEP Res ponses 7/15/09 5

• Section 16a-21a of the Connecticut General Stat utes limits fuel sulfur content of heating

distillate oil and off-road di esel 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 li mitation 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. Regardi ng the reduction of sulfur content of distillate oil to 15 ppm by 2018 component of the MA NE-VU “Ask”, Connecticut continues to

work with other states in th e 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 cont rol measures including energy efficiency, alternative clean fuels, and other measures to reduce SO 2 

### and NO

x 

### 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 th e 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 para graph (formerly third paragra ph) was replaced with following paragraph) “The MANE-VU states agree that a fuel sulfur content limit on resi dual oil and distillate oil is reasonable to pursue over the next ten years. CT DEP will review the details of this strategy in five years, coincident with Connecticut’s firs t regional haze SIP progress report. Section 16a21a of the Connecticut General Statutes limits fuel sulfur content of heati ng distillate oil and offroad diesel oil to 500 ppm as of the date on whic h 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 adjacen t 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 sent ences of the third paragraph we re replaced with the following sentence):

“CTDEP will continue to evalua te other control measures for EGUs and will provide an update

on its evaluation in Connecticut’s first fi ve-year regional haze SIP progress report.”

Section 11.9 (the last sentence of the second pa ragraph has been replaced with the following sentence): “To further meet its obligation beyond those c ontrols already adopted, CTDEP has agreed to pursue the following measures, consistent wi th 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 Res ponses 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 regi onal haze SIP progress report.”

Comment In Section 3.2.3, Connecticut imp lies that addressing inconsistencie s with emission inventories, both within MANE-VU and out, “caused” most Stat es 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, Connec ticut should include language that commits the State to continuing supp ort of the IMPROVE network. Support, in this context means the State agrees IMPROVE is an appropriate monitoring netw ork 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 c ontinued operation of th e IMPROVE network as requested by NPS and USFWS, given the state’s current fiscal constrai nts 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 wi lling to do so. In the alternative, CTDEP will

continue to use these data s ources and CTDEP has added the fo llowing 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 visibi lity impairment and documen ting progress toward national visibility goals for Class I areas under the Re gional Haze Rule. CTDEP agrees that the IMPROVE network is an appropriate monitoring network to track regi onal haze progress and encourages EPA to continue funding the IM PROVE network. CTDEP will work with other

states and the FLMs to maintain the IMPROVE ne twork 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 Se ction 5.3, Monitoring Sites for MANE-VU Class

I Areas:

### Description of FLM Comments and CTDEP Res ponses 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 provid e for purposes of comparison an explanation as to why NH3 emissions go up in projected 2018 in ventory (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 attri buted to a projected increase in vehicle miles
traveled and projected increase in EGU Point NH 3 

### emissions (possibly from projected

installation of SCR controls on one or more units).

CTDEP will be preparing a peri odic emission inventory on a thr ee 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 SI P progress report and requir ed SIP revision due in

2018.”

Section 11, Long Term Strategy

Comment In Section 11.2, the State referenc es technical reports that were used to determine the level of emission reduction required by the State to ac hieve 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 th e 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 guidan ce for setting reasonable progress goals asks states to consider reviewing al l measures identified through the f our factor analysis process (see Section 10.2.1) and to adopt each measure th at 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 draf t SIP provides no inform ation 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 Depa rtment of Public Uti lity Control (CTDPUC),

### Description of FLM Comments and CTDEP Res ponses 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 th at a certain number of older plants will be replaced by newer units to meet future electric growth and state-specific NO X 

### and SO 2 

### caps, Connecticut did not directly rely on the closure of any particular plan t in establishing the 2018 inventory upon which the reasonab le progress goals were set.

The modeling used to develop the 2018 emissions i nventory appears to pred ict that several large EGUs in Connecticut, including fi ve of the six BART-eligible EGUs (Middletown Power 3 & 4, Montville Power 6, Norwalk Power 2 and PSEG Po wer 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 ge t the predicted 2018 results. Response CTDEP added the following paragraph to S ection 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” fu el oil sold in the MANE-VU re gion) is sufficient to achieve visibility improvement beyond the so-called “uni form 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 Ge neral Statutes limits fuel sulfur content of heating distillate oil and off-road diesel oil to 500 ppm as of th e date on which the last of the States New York, Massachusetts and Rhode Isla nd limit the sulfur content of such fuels.”

Comment In Section 11.12 Prevention of Significant Deteri oration, 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 Res ponses 7/15/09 9

Comment The State concludes that there is no informati on suggesting smoke emissions will increase over the next decade (Section 11.7). Will the Stat e track such emissions to determine if this assumption is correct? Response CTDEP added the following paragra ph at the end of Section 11.7: “CTDEP’s Bureau of Air Manage ment currently obtains wildfire and prescribed burning data, including number of acres burned, when the w ildfire or prescribed burn occurred and the location of the wildfire or pres cribed burn, from CTDEP’s Forest ry Division. The wildfire and prescribed burning data will be included in CTDE P’s periodic inventory every three years.

CTDEP will track smoke emissions from wildfire s 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 co ncludes 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 speci fic to the smoke management program. Response CTDEP has revised the last sentence of pa ragraph 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 su lfur fuel-oil). It stands out am ong all the states in the region in this regard. However, the State should bett er support its determina tion 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 o verall 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 c ontrols are BART. Nevertheless, these BART determinations should be performe d as an integral part of the de monstration 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 pe rformed. Approval by EPA of an “alternative method” may relieve the State from requiring in stallation 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 Res ponses 7/15/09 10

In attempting to comply with the 40 CFR 51.3 08(e)(2) requirement that the State submit an “implementation plan” for the pr oposed “alternative measure”, th e State assumes that the EPA

BART Guidelines 1 

### set SO 2 

### BART for oil-fired boilers as burning a 1.0 percent sulfur fuel-oil. The State then used this definition as a de facto st andard to show that a requirement of 0.3 percent sulfur fuel-oil resulted in “greater reasonable pr ogress” and the ability to use an “alternative measure” for BART. The assumption that SO 2 

### BART is the use of 1.0 pe rcent 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 th is is not to be interpreted that the use of 1 percent fuel-oil is considered to be BART for o il-fired boilers. It is only a presumptive BART

alternative that should be cons idered. In the EPA BART Guidelin es 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 app lication of the best system of continuous emission reduction for each pollutant which is em itted by...[a BART-eligible source]. The emission limitation must be established, on a case-by-case basis, taking in to consideration the technology available, the costs of compliance...and the degree of impro vement 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 de termined by comparing the BART for all BARTeligible sources against the ac ross-the-board 0.3 percent sulfur in fuel-oil requirement.

Examples of additional control alter natives to be considered for SO 2 

### BART for each emission unit include the applicability of using progressi vely 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 co st gradient as the sulf ur in oil decreases and selection of BART would be ba sed on the alternativ e 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 viabl e fuel-oil alternative. In addition, the costs and visibility impacts of wet or dry flue gas desulphurization (FGD) techniques should beconsidered. 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 SO 2 

### BART determinations described above should be performed for the facilities at Middletown Power Units 3 and 4, M ontville 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 Res ponses 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 1990 s 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 SO 2 

### , it is incumbent on the State to use a baseline emissions year (presumably 2001) and examine NOx BART control al ternatives 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. Alter native NOx controls to achieve BART should be considered at each BART-eligible source to comp lete the full five-factor analysis. Oil-fired utility boilers have a variety of combustion contro ls available, such as, low excess air, low NOx burners, over-fired ai r, flue gas recirculat ion and optimum staged combustion. Also, postcombustion alternatives such as Selective Non-Catalytic Reduction (SNCR) and Selective Catalytic Reduction (SCR) should be considered at facilities wher e 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 curre ntly controlled for PM. More documentation of these costs is nece ssary as provided in the EPA BART Guidelines which state, “The basis for equipment cost estimat es 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 Contro l Cost Manual, where possible. The Control

Cost Manual addresses most cont rol technologies in suffici ent 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 Stat e 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 Res ponses 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 NE SCAUM exemption modeling that documents these

conclusions should be include d in the SIP as an appendix.

Considerations for the Altern ative to BART Demonstration If the State rules cited on page 9-2 of the draft SIP apply to s ources beyond those subject to BART requirements and achieve mo re emissions reductions than th e highest level of emissions reduction technology applied to only BART sour ces, the demonstration of an acceptable

alternative to BART could be less rigorous than what we noted abo ve. In such a case, the State

should demonstrate the emissions reductions will occur during th e first implementation period of the regional haze rule, 2000 through 2018. In additi on, the expected emissions reductions form the non-BART facilities should not be substantia lly 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 loca tions of emissi on reductions expected from the program and inclusion of ne arby Class I areas and highlighting the BART facilities. Response CTDEP has added the following sentences to th e “Timing” paragraphs of Sections 9.3.1 (Analysis of CT’s Altern ative BART Program for SO 2 

### ) and 9.3.2 (Analysis of CT’s Alternative BART Program for NO

x 

### ), respectively:

“As can be seen in Tables 9-8 and 9-9, emissi ons reductions from Connecticut’s Alternative

BART Program for SO 2 

### occurred during the first implemen tation 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 NO

x 

### occurred during the first im plementation period of the

regional haze rule, 2000 through 2018.”

Also, CTDEP has added maps including trends of potential emission reductions from the

alternative SO 2 

### and NO

x 

### programs with locations of the BA RT-eligible facilities and nearby

Class I areas highlighted (Figures 9.5 and 9.7). CTDEP has added maps of actual emission

trends for SO 2 

### (2001, 2006, 2006) and NO

x 

### (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 a nd industrial boilers in Secti on 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 co llectively referenced in the SO 2 

### and NOx programs for

alternative BART discussed in S ection 9.3. The list includes the size of the unit. CTDEP has added text describing or referenc ing 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 Res ponses 7/15/09 13

Finally, in response to a verbal concer n 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 colu mns 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 t ype 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 BART

### eligible 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 pub lic hearing. We look forward to working with

Connecticut and MANE-VU in the future.

Thanks Ralph Perron, Air Quality Spec ialist, 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