9-1 

9.0 Reasonable Progress Goals (RPGs)

40 CFR Section 51.308(d)(1) of the EPA’s Regional Haze Rule requires each 

state containing a Class I area to establish, for each Class I area within the state, 

visibility goals (expressed in deciviews) that provide for reasonable progress 

toward achieving natural visibility. In addition, the EPA released guidance on 

June 7, 2007 to use in setting reasonable progress goals. The goals must 

provide improvement in visibility for the most impaired days, and ensure no 

degradation in visibility for the least impaired days over the initial SIP period. 

Each Class I state must also provide an assessment of the number of years it 

would take to attain natural visibility conditions if improvement continues at the 

rate represented by the reasonable progress goal (RPG). 

 This SIP covers the first planning period which ends in 2018. 

Under 40 CFR Section 51.308 (d)(1)(iv) consultation is required in developing 

reasonable progress goals. The rule states: 

“In developing each reasonable progress goal, the State must consult with 

those States which may reasonably be anticipated to cause or contribute 

to visibility impairment in the mandatory Class I Federal area. In any 

situation in which the State cannot agree with another such State or group 

of States that a goal provides for reasonable progress, the State must 

describe in its submittal the actions taken to resolve the disagreement. In 

reviewing the State's implementation plan submittal, the Administrator will 

take this information into account in determining whether the State's goal 

for visibility improvement provides for reasonable progress toward natural 

visibility conditions.” 

In developing RPGs, Class I states must consider four factors (cost, time 

needed, energy and non-air quality environmental impacts, and remaining useful 

life). The Class I states also must show that they considered the uniform rate of 

improvement and the emission reduction measures needed to achieve the RPG 

for the period covered by the implementation plan. If the state proposes a rate of 

progress slower than the uniform rate of progress, it must assess the number of 

years it would take to attain natural conditions if visibility improvement continues 

at the rate proposed. 

9.1 Consultation and Agreement with Other States’ Goals

 

The MANE-VU states of New Jersey, New Hampshire, Maine and Vermont sent 

letters to New York in the spring of 2007 stating that, based on 2002 emissions 

and modeling results, New York contributed to visibility impairment in Class I 

areas in those states. While New York has no Class I areas, these MANE-VU 

Class I states asked for New York State’s continued participation in further 

consultation with these states during the summer of 2007. New York agreed in 
9-2 

written responses back to these states. Consistent with the Regional Haze Rule 

requirements, New York State has consulted, and continues to consult, with 

states containing Class I areas that are or may be impacted by emission sources 

within New York State as they established reasonable progress goals for each 

Class I area within their state. More detail on consultation is provided in 

Appendix F, Summary of Consultation Meetings and Conferences. 

As a result of the consultation process, it was the Department’s expectation that 

each state whose Class I areas are affected by emissions in New York would 

formally provide a notification by letter of the measures that they expected would 

be taken by New York to meet the reasonable progress goals for the initial period 

of the SIP (i.e., 2018) as well as attaining natural haze conditions by 2064. Since 

the consultation process began with a letter from MANE-VU Class I states 

advising New York that its emissions caused or contributed to regional haze 

within each state’s Class I areas and requesting participation in the consultation 

process, it was anticipated that the Department would receive a similar letter 

from each of these states (New Jersey, New Hampshire, Maine and Vermont) 

advising that the consultation process had resulted in the recommendation that 

certain, specific measures would be required in order to meet the reasonable 

progress goals for each Class I area in these states. Although not all of the 

Class I states whose visibility is affected by emissions from New York have 

provided such a letter, the Department received a letter dated May 16, 2008 from 

the State of New Hampshire summarizing New York State’s consultation process 

via MANE-VU. The information in New Hampshire’s consultation letter (Appendix 

X), is indicative of the measures that must be taken. 

Except as provided below, the reasonable progress modeling used by MANE-VU 

states to establish reasonable progress goals reflect the G2 and Base K 2018 

emissions inventories for the VISTAS and Midwest RPO regions, respectively. 

Based on consultation with those regions, those inventories reflected the 

measures States in those regions consider to be reasonable to implement by 

2018 including CAIR, BART, and other federal and state requirements. 

With the implementation of the measures described in Section 9.4, New York will 

meet the Reasonable Progress Goals and long-term strategy requirements 

developed for New York's regional haze SIP at MANE-VU’s Class I areas. New 

York commits to satisfying its responsibilities under the Regional Haze Program, 

the Act, and this SIP. 

MANE-VU’s Contribution Assessment (Appendix A) indicated that the dominant 

contributor to visibility impairment is SO2. Control of SO2 emissions, therefore, 

will yield the greatest near-term benefit. It has been determined that the control 

measures listed above and the costs of compliance are reasonable, based on 

available control technologies. New York State is committed to reducing 

emissions at least equal to those predicted in the model, through the measures 
9-3 

described above. These are reasonable measures designed to meet our CAA 

Section 110(a)(2)(D) obligations. 

Except as provided below, the reasonable progress modeling used by MANE-VU 

states to establish reasonable progress goals reflects the G2 and Base K 2018 

emissions inventories for the VISTAS and Midwest RPO regions, respectively. 

Based on consultation with those regions, those inventories reflect the measures 

states in those regions consider to be reasonable to implement by 2018 including 

CAIR, BART, and other federal and state requirements. 

Reasonable progress goals are based on an analysis of visibility conditions, 

including a comparison of baseline conditions to natural visibility conditions, 

which quantifies the improvement necessary to achieve natural visibility 

conditions by the year 2064 (Guidance for Estimating Natural Visibility Conditions 

Under the Regional Haze Rule, Appendix C). The uniform rate of improvement 

per year needed to achieve natural background visibility conditions is also shown 

in Table 9-1 below. 

Table 9-1 - Uniform Rate of Progress

Class I Area 

(2000-2004)

2000-2004 

Baseline 

Visibility 

(deciviews) 

(20% Worst 

Days)

Natural 

Visibility 

Condition 

(deciviews) 

 (20% Worst 

Days)

Deciview 

Improvement 

Needed by 

2018 

from 2004

Deciview 

Improvement 

Needed by 

2064

Uniform Rate 

of 

Improvement 

Annually

Acadia National Park, 

Maine 22.9 12.4 2.4 10.5 0.174 

Moosehorn National 

Wildlife Refuge, Maine 21.7 12.0 2.3 9.7 0.162 

Roosevelt/Campobello 

International Park, 

Maine & New 

Brunswick, Canada 

21.7 12.0 2.3 9.7 0.162 

Great Gulf Wilderness 

Area, New Hampshire 22.8 12.0 2.5 10.8 0.180 

Presidential Range/Dry 

River Wilderness Area, 

New Hampshire 

22.8 12.0 2.5 10.8 0.180 

Lye Brook Wilderness 

Area, Vermont 24.5 11.7 3.0 12.8 0.212 

Brigantine Wilderness 

Area, New Jersey 29.0 12.2 3.9 16.8 0.280 

Source: VIEWS (http://vista.circa.colostate.edu/views/), prepared on 7/06/06

States containing Class I areas are required to show that visibility improvements 

will ultimately meet the 2064 goal. States without Class I areas contribute to 
9-4 

visibility in these areas as well, and so their emissions must be included in the 

analysis. The State of New York does not contain any Class I areas. 

In determining the reasonable progress goal for each Class I area, both natural 

conditions and baseline visibility for the 5-year period from 2000 through 2004 

were calculated in conformance with an alternative method recommended by the 

IMPROVE Steering Committee.1 As explained below, the reasonable progress 

goals established for the Class I area(s) affected by emissions from New York 

provide for at least as much visibility improvement by 2018 as would be achieved 

by the uniform rate of progress shown above. 

9.2 Reasonable Progress Goals for Class I Areas

In accordance with the requirements of 40 CFR Section 51.308(d)(1), this 

Regional Haze SIP addresses the necessary measures that New York State 

must take to meet the reasonable progress goals for each Class I area located in 

MANE-VU for the period of the implementation plan. Tables 9-2a and 9-2b 

below provide a summary of Reasonable Progress Goals located within MANEVU states in which Class I areas are located. 

 1

“Baseline and Natural Visibility Conditions, Considerations and Proposed Approach to 

the Calculation of Baseline and Natural Visibility Conditions at MANE-VU Class I Areas,” 

NESCAUM, December 2006 
9-5 

Table 9-2a - Reasonable Progress Goals—20 Percent Worst Days

Class I Area 

Baseline 

Visibility 

(deciviews) 

(20% worst days 

2000-2004) 

Reasonable Progress 

Goals, 20% worst 

days (Expected 

deciview level by 

2018) 

Deciview 

improvement 

expected 

by 2018 

Natural 

Visibility 

Conditions 

(20% worst 

days) 

 Acadia National Park 22.9 19.4 3.5 12.4 

 Roosevelt/Campobello 

International Park 21.7 19.0 2.7 12.0 

 Moosehorn National 

Wildlife Refuge 21.7 19.0 2.7 12.0 

 Presidential Range/Dry 

River Wilderness Area 22.8 19.1 2.7 12.0 

Great Gulf Wilderness 

Area 22.8 19.1 2.7 12.0 

 Lye Brook Wilderness 24.5 20.9 3.6 11.7 

 Brigantine Wilderness 29.0 25.1 3.9 12.2 
9-6 

Table 9-2b - Reasonable Progress Goals—20 Percent Best Days

Class I Area 

Baseline 

Visibility 

(deciviews) 

(20% Best Days) 

Reasonable Progress 

Goals, 20% best days 

(deciviews) 

(expected by 2018) 

Deciview 

improve

ment 

expected 

by 2018 

Natural 

Visibility (20% 

best days) 

(deciviews) 

 Acadia National Park 8.8 8.3 0.5 4.7 

 Roosevelt/Campobello 

International Park 9.2 8.6 0.6 5.0 

 Moosehorn National 

Wildlife Refuge 9.2 8.6 0.6 5.0 

 Presidential Range/Dry 

River Wilderness Area 7.7 7.2 0.5 3.7 

Great Gulf Wilderness 

Area 7.7 7.2 0.5 3.7 

 Lye Brook Wilderness 6.4 5.5 0.9 2.8 

 Brigantine Wilderness 14.3 12.2 2.1 5.5 

Both natural conditions and baseline visibility for the 5-year period from 2000 

through 2004 were calculated in conformance with an alternative method 

recommended by the IMPROVE Steering Committee.2

 Progress toward the 

2018 target will be calculated based on 5-year averages calculated in a manner 

consistent with the EPA’s Guidance for Tracking Progress Under the Regional 

Haze Rule (EPA-454/B-03-004, September 2003) as updated by the alternative 

method for calculating regional haze recommended by the IMPROVE Steering 

Committee. 

To determine the RPG in deciviews, MANE-VU conducted modeling with certain 

control measure assumptions. The control measures reflected in these 

 2

“Baseline and Natural Visibility Conditions, Considerations and Proposed 

Approach to the Calculation of Baseline and Natural Visibility Conditions at MANE-VU 

Class I Areas,” NESCAUM, December 2006.
9-7 

reasonable progress goals are summarized below in Table 9-3. In establishing 

the reasonable progress goals for 2018, contributing states have the flexibility to 

submit SIP revisions between now and 2018 as they are able to adopt control 

measures to implement these goals. This long-term strategy to reduce and 

prevent regional haze will allow each state up to 10 years to pursue adoption and 

implementation of reasonable and cost-effective NOx and SO2 control measures 

as appropriate and necessary. 

9.2.1 Consideration of Other Air Quality Requirements 

40 CFR Section 51.308 (d)(1)(vi) of EPA’s Regional Haze Rule requires that 

reasonable progress goals represent at least the visibility improvement expected 

from implementation of other Clean Air Act programs during the applicable 

planning period. 

As documented in the emissions inventory and long term strategy sections of this 

SIP, the modeling that formed the basis for reasonable progress goals in MANEVU Class I Areas included an estimate of all of the other programs required by 

the Clean Air Act. Further information may be found in those sections of this SIP 

and in the documentation for the MANE-VU modeling. 

9.2.2 Rationale for Determining Reasonable Controls

40 CFR 51.308(d)(1)(i)(A) of EPA’s Regional Haze Rule requires that, in 

establishing reasonable progress goals for each Class I area, the state must 

consider the costs of compliance, the time necessary for compliance, the energy 

and non-air quality environmental impacts of compliance, and the remaining 

useful life of any potentially affected sources. The SIP must include a 

demonstration showing how these factors were taken into consideration in setting 

the RPGs. These factors are sometimes termed the “four statutory factors,” 

since their consideration is required by the Clean Air Act. 

MANE-VU conducted a Contribution Assessment (Appendix A) and developed a 

conceptual model that showed the dominant contributor to visibility impairment at 

all MANE-VU Class I areas during all seasons in the base year was particulate 

sulfate formed from emissions of SO2. While other pollutants, including organic 

carbon, will need to be addressed in order to achieve the national visibility goals, 

MANE-VU’s contribution assessment suggested that an early emphasis on SO2 

would yield the greatest near-term benefit. Therefore, it is reasonable to 

conclude that the additional measures considered in setting reasonable progress 

goals require reductions in SO2 emissions. 

The MANE-VU Contribution Assessment indicates that emissions from within 
9-8 

MANE-VU in 2002 were responsible for approximately 25 percent of the sulfate 

at MANE-VU Class I Areas. Sources in the Midwest and Southeast regions were 

responsible for about 15 to 25 percent each. Point sources dominated the 

inventory of SO2 emissions. Therefore, MANE-VU’s long-term strategy includes 

additional measures to control sources of SO2 both within the MANE-VU region 

and in other states that were determined to contribute to regional haze at MANEVU Class I Areas. 

The Contribution Assessment documented the source categories most 

responsible for visibility degradation at MANE-VU Class I Areas. As described in 

Section 10, Long Term Strategy, there was a collaborative effort between the 

Ozone Transport Commission and MANE-VU to evaluate a large number of 

potential control measures. Several measures that would reduce SO2 emissions 

were identified for further study. 

These efforts led to production of the MANE-VU report by MACTEC Federal 

Programs, Inc., “Assessment of Reasonable Progress for Regional Haze in 

MANE-VU Class I Areas,” Final, July 9, 2007, otherwise known as the 

Reasonable Progress Report (Appendix J). This report provides an analysis of 

the four statutory factors for five major source categories: electrical generating 

units (EGUs); industrial, commercial, and institutional (ICI) boilers; cement and 

lime kilns; heating oil combustion; and residential wood combustion. Table 9-3 

summarizes the results of MANE-VU’s four-factor analysis for the source 

categories considered. 
9-9 

Table 9-3 - Summary of Results from Four-Factor Analysis 

of Different Source Categories

Source 

Category 

Primary 

Regional 

Haze 

Pollutant

Control Measure(s)

Average Cost in 

2006 dollars 

(per ton of 

pollutant 

reduction)

Compliance 

Timeframe 

Energy and 

Non-Air 

Quality 

Environmental 

Impacts

Remaining 

Useful Life

Electric 

Generating 

Units 

SO2

Switch to a low-sulfur coal 

(generally <1% sulfur); 

switch to natural gas 

(virtually 0% sulfur); coal 

cleaning; flue gas 

desulfurization (FGD), 

including wet, spray-dry, or 

dry.

$775-$1,690 

based on IPM® 

v.2.1.9 * 

$170-$5,700 based 

on available literature 

2-3 years 

following SIP 

submittal 

Fuel supply 

issues, possible 

permitting issues, 

reduced electricity 

production 

capacity, 

wastewater issues

50 years or 

more

Industrial, 

Commercial, 

Institutional 

Boilers 

SO2

Switch to a low-sulfur coal 

(generally <1% sulfur); 

switch to natural gas 

(virtually 0% sulfur); switch 

to a lower-sulfur oil; coal 

cleaning; combustion 

controls; flue gas 

desulfurization (FGD), 

including wet, spray-dry, or 

dry.

$130-$11,000 

based on available 

literature; 

dependent on size. 

2-3 years 

following SIP 

submittal 

Fuel supply 

issues, potential 

permitting issues, 

control device 

energy 

requirements, 

wastewater issues

10-30 years

Cement and 

Lime Kilns SO2

Fuel switching; flue gas 

desulfurization (FGD), 

including wet, spray-dry, or 

dry; advanced flue gas 

desulfurization (FGD).

$1,900-$73,000 

based on available 

literature; 

dependent on size. 

2-3 years 

following SIP 

submittal 

Control device 

energy 

requirements, 

wastewater issues

10-30 years

Heating Oil SO2 Switch to lower-sulfur fuel 

(varies by state)

$550-$750 based on 

available literature; 

high degree of 

uncertainty with this 

cost estimate 

Currently feasible; 

capacity issues 

may influence 

timeframe for 

implementation of 

new fuel 

standards 

Increased 

furnace/boiler 

efficiency, 

reduced 

furnace/boiler 

maintenance 

requirements

18-25 years

Residential 

Wood 

Combustion 

PM

State implementation of 

NSPS, 

ban on resale of uncertified 

devices, installer training 

certification or inspection 

program, pellet stoves, EPA 

Phase II certified RWC 

devices, retrofit 

requirement, accelerated 

changeover requirement or 

inducement

$0-$10,000 based on 

available literature 

Several years, 

depending on 

mechanism for 

emission 

reductions 

Increased 

efficiency of 

combustion 

device, reduced 

greenhouse gas 

emissions 

10-15 years

The MANE-VU states reviewed the four-factor analyses presented in the 

Reasonable Progress Report, consulted with one another about possible control 
9-10 

measures, and concluded by adopting the statements known as the MANE-VU 

“Ask.” These statements identify the control measures that would be pursued 

toward improving visibility in the region. The following discussions focus on the 

four basic control strategies chosen by MANE-VU and included in the modeling 

to establish the reasonable progress goals: 

1. Best Available Retrofit Technology (BART), 

2. Low-sulfur fuel oil requirements, 

3. Emission reductions from specific EGUs, and 

4. Additional measures determined to be reasonable. 

9.3 Controls Within MANE-VU

In accordance with draft EPA guidance, states must establish baselines from 

which reasonable progress will be measured. The progress sought is in visibility 

improvement. However, emission reductions are effectively used as a surrogate 

for this progress, with visibility improvement assessed over the first five years of 

the implementation of the haze SIP. If mid-course adjustments are appropriate 

at that time, the SIP will be revised to provide for any necessary corrections. The 

baseline year for emissions reductions used by MANE-VU is 2002. 

Sulfates have been identified as the major pollutant contributing to visibility 

impairment in the MANE-VU region, and a number of programs are already in 

place that include measures to reduce the emission of sulfates and their 

precursors. Several of these are as follows: 

$ NYS Acid Deposition Reduction Program 

$ 6 NYCRR Part 225, Fuel Composition and Use 

$ The Acid Rain Program 

$ 2004 Clean Air Nonroad Diesel Rule 

$ 2007 Clean Diesel Trucks and Buses Rule 

$ California Low Emission Vehicle Standards 

$ Emission standards for other engines (highway and non-highway use) 

$ National Clean Diesel Campaign 

These are discussed in detail in Section 10 of this document. 

As a part of the haze SIP development effort, MANE-VU, through its contractor 

MACTEC, conducted a contribution assessment to identify the sources that are 

significant contributors to visibility impairment in the MANE-VU area and looked 

for additional control reduction opportunities to reduce the level of haze in Class I 

areas (See Assessment of Reasonable Progress for Regional Haze in MANE-VU 

Class I Areas, Appendix J). 
9-11 

After beginning the assessment with a more extensive list, the following source 

categories were selected for further consideration: 

$ Coal and oil-fired Electric Generating Units (EGUs); 

$ Point and area source industrial, commercial and institutional boilers (ICI 

boilers); 

$ Cement kilns; 

$ Lime kilns; 

$ The use of heating oil; and 

$ Residential wood combustion. 

In assessing each of these categories, MACTEC conducted an analysis of 

economic and environmental impacts of potential control scenarios that could be 

implemented by MANE-VU states. The purpose of this analysis was to develop 

information that could be used by the states in producing implementation plans to 

address regional haze. Each category was evaluated with respect to the four 

factors described in Section 169A of the Clean Air Act. The factors are: 

1. Cost; 

2. Compliance timeframe; 

3. Energy and non-air quality environmental impacts; and 

4. Remaining useful life for affected sources. 

The results of this analysis were used to develop the final list of measures that 

were recommended by Class I states in MANE-VU as being necessary to meet 

the reasonable progress goal requirements. These measures focus primarily on 

the reduction of sulfates and particulate matter as a first step during the initial 

planning period toward reducing visibility reductions to pre-industrial levels. 

9.4 Controls Within MANE-VU Selected by Class I States to Meet Reasonable 

Progress Goals 

The reasonable progress goals shown above in Tables 9-2a and 9-2b represent 

implementation of the regional strategy adopted by MANE-VU on June 20, 2007 

entitled, Statement of the Mid-Atlantic/Northeast Visibility Union (MANE-VU) 

Concerning a Course of Action Within MANE-VU Toward Assuring Reasonable 

Progress” (See Appendix K). These actions, consisting of control and other 

measures intended to reduce the emissions of visibility impairing pollutants and 

their precursors, are referred to in the SIP as the “Ask.” As such, these goals are 

intended to reflect the pursuit by MANE-VU States, including New York, of a 

course of action including pursuing the adoption and implementation of the 

following “emission management” strategies, as appropriate and necessary: 
9-12 

a. Timely implementation of BART requirements, and 

 

b. A 90 percent or greater reduction in sulfur dioxide (SO2) emissions from 

each of the electric generating unit (EGU) stacks identified by MANE-VU 

(Appendix P- List of Top 167 Sources, dated June 20, 2007) as 

reasonably anticipated to cause or contribute to impairment of visibility in 

each mandatory Class I Federal area in the MANE-VU region. If it is 

infeasible to achieve that level of reduction from a unit, alternative 

measures will be pursued in such State; and 

 

c. A low sulfur fuel oil strategy in the inner zone states (New Jersey, New 

York, Delaware, and Pennsylvania, or portions thereof) to reduce the 

sulfur content of: 

i. Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later 

than 2012, 

ii. #4 residual oil to 0.25 percent sulfur by weight by no later than 

2012, 

iii. #6 oil to 0.3 – 0.5 percent sulfur by weight by no later than 2012, 

and 

iv. Further reduce the sulfur content of distillate oil to 15 ppm by 2016; 

and 

d. A low sulfur fuel oil strategy in the outer zone states (the remainder of the 

MANE-VU region) to reduce the sulfur content of: 

i. Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later 

than 2014, 

ii. #4 residual oil to 0.25 percent-0.50 percent sulfur by weight by no 

later than 2018, 

iii. #6 oil to no greater than 0.5 percent sulfur by weight by no later 

than 2018, and 

iv. Further reduce the sulfur content of distillate oil to 15 ppm by 2018; 

and 

e. Continued evaluation of other control measures including energy 

efficiency, alternative clean fuels, and other measures to reduce SO2 and 

NOx emissions from all coal-burning facilities by 2018 and new source 

performance standards for wood combustion. These measures and other 

measures identified will be evaluated during the consultation process to 

determine if they are cost effective and reasonable. 
9-13 

As stated above, this long-term strategy to reduce and prevent regional haze will 

allow each state up to 10 years to pursue adoption and implementation of 

reasonable and cost-effective NOx and SO2 control measures as appropriate 

and necessary. See Section 9.5, below for a description of how these 

assumptions were modeled in order to estimate the visibility impact of the MANEVU “Ask.” 

9.4.1 New York State Measures

Although New York has no Class I areas, the emissions from its sources are 

contributory to regional haze in several states that contain Class I areas. 

Through the collaborative effort described above, these Class I states have 

identified control measures that should be applied in order to meet the 

Reasonable Progress Goals out until 2018. These measures include the 

application of Best Available Retrofit Technology (BART) to eligible facilities as 

expeditiously as practicable, but no later than January 1, 2013, sulfate reductions 

from specific source sectors defined in the Clean Air Act, a low-sulfur oil strategy 

for all sectors (commercial, industrial, and residential), an EGU strategy that 

targets a 90% sulfate reduction from each of the stacks impacting any MANE-VU 

Class I area, or a reduction equivalent to that amount within each State, as well 

as continued evaluation of other control measures to reduce SO2 and NOx 

emissions. 

Specifically, New York State anticipates meeting these goals as follows: 

a. Timely implementation of BART requirements

New York is in the process of promulgating 6 NYCRR Part 249 which will 

contain the requirements for the federal BART rule. This rule will provide 

the state authority necessary to require BART controls for eligible sources, 

and will require BART-eligible EGUs to apply BART by July 1, 2013. 

Promulgation of this rule is expected to be completed by May 2010. 

After promulgation is completed, BART requirements will be applied in 

New York to eligible sources in accordance with federal requirements, 

including the Class I areas’ requested control measures. 

b. Ninety percent or greater reduction in sulfur dioxide (SO2) emissions from 

the 167 electric generating unit (EGU) stacks. 

A 90 percent or greater reduction in sulfur dioxide (SO2) emissions from 

each of the electric generating unit (EGU) stacks identified by MANE-VU 

comprising a total of 167 stacks as reasonably anticipated to cause or 
9-14 

contribute to impairment of visibility in each mandatory Class I Federal 

area in the MANE-VU region. If it is infeasible to achieve that level of 

reduction from a unit, alternative measures will be pursued in such State. 

Table 9-4 below identifies the facilities and units in New York State that 

are contained in the list of 167 stacks. A complete listing of the 167 

sources can be found in Appendix P, List of Top 167 Sources. Emission 

reductions for SO2 that are presently expected to occur for the New York 

sources in Table 9-4 by 2018 range from 100% (for those units shutting 

down) to 0% (at the present time) for the Oswego facility. Based on 

present expectations, most other units expect SO2 emission reductions in 

the 80-95% range. 

Other measures, will reduce emissions from those facilities even further, 

including: 

• The reduction of fuel sulfur limits for most types of fuel oil, as 

discussed below and in Section 10.3, 

• The revisions to 6 NYCRR Part 227 that will require RACT for major 

sources of PM2.5 (those greater than 100 tpy), 

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

Transport Region (revisions adopted January 15, 2009), 

• MACT under Section 112 of the 1990 CAA Amendments, 

• NOx RACT measures for High Electricity Demand Day Units, 

• Emission reductions resulting from consent orders, and 

• The continued evaluation of other control measures including energy 

efficiency, alternative clean fuels, and other approaches. 

Each of these measures is described in detail in Section 10.3. 

Finally, the replacement of equipment at these facilities, such as the 

construction of a new facility, will result in additional reductions by 2018. 

Overall, these measures will reduce emissions significantly, approaching 

the required 90%. As such, in aggregate, it is expected that the necessary 

reductions will be achieved to meet this portion of the MANE-VU Class I 

states’ “Ask.” 

9.4.2 New York State Modeling Reductions

Modeling of emission control strategies for the low sulfur fuel oil strategy outlined 

above produced the following projections of emissions reductions for 2018: 
9-15 

• A reduction in sulfur from 500 ppm to 15 ppm results in emissions 

reductions of 7,444 tons per year (TPY). Reducing sulfur content of #4/#6 

oil results in 12,385 TPY fewer emissions. Starting with no sulfur controls 

as a baseline, then reducing the sulfur to 500 ppm results in a 51,929 TPY 

reduction. Thus, the total TPY reduced as a result of reduced sulfur in oil 

reductions is 71,759 TPY. 

• Point source reductions resulting from BART controls are 19,942 TPY. 

• Area source reductions resulting from controls are 51,817 TPY. 

• The total emissions being modeled after controls are applied are 13,955 

TPY. 
9-16 

Table 9-4 - Units in New York Included in the List of 167 Stacks Identified by 

MANE-VU for Which 90 Percent or Greater Reductions 

 in Sulfur Dioxide (SO2) Emissions are Recommended 

Plant Name Type Unit(s)

NOx Control SO2 Control

Existing Planned Existing Planned

C R HUNTLEY1 Coal Steam 67,68 LNB SNCR Low Sulfur Coal 

Low S Coal, Trona Injection 

and Baghouse (w/ 63 - 66 

80 % control) with Dunkirk 

14,169 ton cap

C R HUNTLEY1 Coal Steam 63 through 

66 LNB Shutdown Low Sulfur Coal Shutdown

DANSKAMMER O/G Steam 4 LNB & OFA

Nothing 

additional 

planned 

None Trona Injection and 

Baghouse 

DUNKIRK1 Coal Steam 3,4 LNB & OFA SNCR Low Sulfur Coal 

Low S Coal, Trona Injection 

and Baghouse (80 % 

control) with Huntley 14,169 

ton cap 

GOUDEY Coal Steam 11,12,13 Burners out 

of service SCR None FGD Scrubber (95 % control) 

GREENIDGE Coal Steam 6 SNCR/SCR SNCR/SCR 

Hybrid 

Dry scrubber 

w/lime injection 

FB Dry Scrubber (95 % 

control) 

NORTHPORT O/G Steam 3 

OFA 

System-wide 

averaging 

New plant to 

be 

constructed 

Low S Fuel New plant to be constructed

OSWEGO O/G Steam 5 Emission 

limit Emission limit Fuel S Limit (Oil) Fuel S Limit (Oil) 

ROCHESTER 7 Coal Steam 3,4 SNCR Shutdown None Shutdown 

ROSETON O/G Steam 1 System-wide 

averaging 

Nothing 

planned Fuel S Limit 

Trona Injection and 

Baghouse (w/ 63 - 66 80 % 

control) 

ROSETON O/G Steam 2 System-wide 

averaging 

Nothing 

planned Fuel S Limit 

Trona Injection and 

Baghouse (w/ 63 - 66 80 % 

control) 

Notes: 1Consent order requires NOx and SO2 emissions reductions by 2013. Controls not yet determined.
9-17 

 c. Low sulfur fuel oil strategy in New York 

A low sulfur fuel oil reduction strategy will be implemented to reduce the 

sulfur content to specific limits by 2012 and 2016. 6 NYCRR Part 225, 

which contains the state’s fuel sulfur limits, will be revised to incorporate 

these lower fuel sulfur limits, thus implementing this strategy. The 

expected schedule for promulgation of these measures is as follows: 

 Proposal in State Register: July 1, 2011 

 Package to Environmental Board: October 1, 2011 

 File Regulation with the Secretary of State: November 14, 2011 

 Regulation Effective Date: December 31, 2011 

This schedule is based on EPA approval of the SIP within a year after it is 

submitted. If the EPA does not approve the SIP within a year, the schedule 

is subject to change. 

 

d. Continued evaluation of other measures 

The evaluation of other control measures, including energy efficiency, 

alternative clean fuels, and other measures to reduce SO2 and NOx 

emissions from all coal-burning facilities by 2018 and new source 

performance standards for wood combustion, will be continued. This is 

expected to take place on an ongoing basis, and will be more formally 

assessed during the five-year reassessment of the effectiveness of the 

regional haze SIP required under 40 CFR Section 51.308(g). For example, 

MANE-VU considered how to best deal with residential wood combustion 

and outdoor wood boilers. Although neither have significant sulfate 

emissions, both of these source categories are sources of organic carbon 

and direct particulate matter that also impact visibility. Because of the 

nature of these sources and the varied rates of use among states, it was 

recommended that the regulation of woodburning appliances be left to 

each state rather than being part of a regional strategy. New York State is 

currently developing a rulemaking and regulatory program to control 

outdoor wood boilers to address a category of sources that is of concern to 

many states, especially those in the Northeast. 

In addition to the above measures, a number of measures intended to reduce the 

emissions of VOCs will be implemented as a part of the ozone SIPs that have 

been submitted to EPA. VOCs are precursors to some of the pollutants that 

cause regional haze and, as such, this reduction will also have a positive impact 

on the impairment of visibility in Class I areas as well as others. Although these 

measures are not part of New York’s commitments for the purposes of this SIP, 
9-18 

additional VOC control measures are expected to have a positive effect on 

visibility impairment. 

 Table 9-5 below lists the New York State On-The-Books (OTB) and On-The-Way 

(OTW) VOC control measures. 

Table 9-5 - New York State OTB/OTW VOC Control Measures 

 in the 8-Hour Ozone SIP

OTB/OTW Control Measures

6 NYCRR Part 228- Adhesives and Sealants -effective 7/2010 

6 NYCRR Part 241- Asphalt Formulation -effective 7/2010 

6 NYCRR Part 212.10- Asphalt Production -effective 8/2010 

6 NYCRR Part 235- Consumer Products -effective 10/15/09 

6 NYCRR Part 239- Portable Fuel Containers -effective 7/30/09 

9.5 Visibility Impacts of Additional Reasonable Controls

40 CFR Section (d)(1)(i)(A) of the EPA’s Clean Air Visibility Rule requires that in 

establishing reasonable progress goals for each Class I area, each Class I state 

must consider the costs of compliance, the time necessary for compliance, the 

energy and non-air quality environmental impacts of compliance, and the 

remaining useful life of any potentially affected sources, and the SIP must include 

a demonstration showing how these factors were taken into consideration in 

setting the goal. These factors are sometimes termed the “four statutory factors,” 

since their consideration is required by the Clean Air Act. The analysis performed 

by the Class I states impacted by emissions from New York is presented in 

Appendix N, MANE-VU Basis for Reasonable Controls, of this document for 

reference. 

Preliminary modeling was conducted by NESCAUM on behalf of the MANE-VU 

Class I states to estimate the impact of various elements of the MANE-VU “Ask” 

as described above. This modeling is described in NESCAUM’s report entitled 

MANE-VU Modeling for Reasonable Progress Goals: Model Performance 

Evaluation, Pollution Apportionment, and Control Measure Benefits (February 

2008, Appendix R). 

NESCAUM also conducted additional revised modeling to assess combined 

impacts. This modeling is described in NESCAUM’s report entitled 2018 Visibility 

Projections (March 2008, Appendix V). The following information about the 

effects of specific strategies is taken from those reports. 
9-19 

NESCAUM evaluated the visibility benefits of the potential control strategies that 

go beyond the “On the Books/On the Way” controls already required by actions to 

implement other requirements of the Clean Air Act. This section explains 

assumptions used to model the impact of potential control strategies and 

describes the combined potential visibility benefits of all the strategies based on 

CMAQ modeling. As with all modeling, emissions estimates and modeling results 

for 2018 entail uncertainty, and further evaluation may be conducted as part of the 

SIP report required in five years under 40 CFR Section 51.308(g). If reasonable 

progress requirements are not met, New York will submit a revision of its Regional 

Haze SIP with the necessary corrections as prescribed in the Federal rule.

Appendix N, MANE-VU Basis for Reasonable Controls, of this document 

discusses the basis for determining that the measures described in the MANE-VU 

“Ask” are considered to be reasonable. 

9.5.1 Model Performance

CMAQ modeling was conducted for 2002 by cooperative modeling efforts from 

NYSDEC, UMD, NJDEP, Rutgers, VADEP, and NESCAUM and performance for 

PM2.5 species and visibility was examined. Measurements from IMPROVE and 

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

evaluation. These comparisons showed that predicted PM2.5 sulfate and 

measured sulfate were in a good 1:1 linear relationship. Paired organic carbon 

(OC) concentrations exhibited a weak linear distribution. CMAQ tended to 

overestimate elemental carbon (EC) and fine soil concentrations. The emission 

inventory data may be the main cause for the weaker linear relationships between 

prediction and measurement. 

Because sulfate is the dominant PM2.5 species, modeled PM2.5 showed a 

relatively strong near 1:1 linear relationship. Generally, the northern region of the 

area modeled displayed stronger correlations than did the southern region. For 

the MANE-VU region, CMAQ was shown to perform best for PM2.5 sulfate, 

followed by PM2.5, EC, nitrate, OC, and then fine soil. 

Regional haze modeling also required a CMAQ performance evaluation for 

aerosol extinction coefficient (Bext) and the haze index. Modeled daily aerosol 

extinction at each IMPROVE site was calculated following the IMPROVE formula 

with modeled daily PM2.5 species concentration and relative humidity factors from 

IMPROVE. The approaches used here and throughout the analysis have used 

natural background visibility estimates and the haze index following EPA 

Guidance. 
9-20 

A paired comparison between prediction and measurement of daily Bext showed 

a near 1:1 linear relationship. CMAQ prediction of the Bext agreed well with 

IMPROVE observation because CMAQ performed well on sulfate, which 

dominates aerosol extinction. Further, the modeled haze index (HI) was 

calculated based on modeled Bext. A paired comparison between CMAQ 

prediction and IMPROVE measurement for 2002 of HI values at seven Class I 

sites in the eastern U.S.. Acadia and Moosehorn showed the best model 

performance. The poorest model performance occurred at Lye Brook, which is 

the closest area to New York State, and Shenandoah. However, since sulfates 

comprise the largest contribution to visibility impairment, it would be reasonable to 

expect that modeling results would provide good estimates of the effectiveness of 

the control strategies proposed in New York's SIP for both 2002 and the 2018 

planning year. 

A state-specific assessment of the performance of the models that were used is 

not available and would not be meaningful given the role that transport plays over 

very long distances. All modeling was done on a regional basis. However, given 

the good performance of the models as they relate to the impacts of SO2 

emissions on haze, which has been shown to be overwhelmingly the most 

significant, it is possible to infer each states' contributions in a general sense by 

examining the relative emissions in New York to the total for the region. These 

emissions appear in Tables 7-1 through 7-6 which present the relative emissions 

from New York State sources compared to MANE-VU sources in total. 

9.6 Modeling Impacts of BART Controls on Former Non-CAIR Sources in MANE-VU 

Although many states had not completed BART determinations for non-CAIR 

BART-eligible sources at the time regional modeling was conducted, NESCAUM 

did include in the modeling a reasonable estimate of the effect of BART on other 

(non-CAIR) sources within MANE-VU. 

To assess the impacts of the implementation of BART on non-CAIR sources in 

MANE-VU, NESCAUM estimated reductions for eight BART-eligible facilities. A 

survey of state staff indicated that these eight units would likely be controlled 

under BART alone. These states provided potential control technologies and 

levels of control, which were in turn incorporated into the 2018 emission inventory 

projections. 

Table 9-6 lists the emissions for the BART-eligible sources at eight facilities that 

were included in modeling used to set reasonable progress goals. 
9-21 

9.7 Controls Outside of MANE-VU Selected to Meet Reasonable Progress Goals 

The reasonable progress goals shown above represent implementation of the 

statement adopted by MANE-VU on June 20, 2007 and entitled, Statement of the 

Mid-Atlantic/Northeast Visibility Union (MANE-VU) Concerning a Request for a 

Course of Action by States Outside MANE-VU Toward Assuring Reasonable 

Progress (See Appendix S). 

The states outside MANE-VU to whom this request was addressed were identified 

in the MANE-VU Contribution Assessment as those states contributing at least 2 

percent of the sulfates at MANE-VU Class I areas in 2002. This includes the 

following states outside MANE-VU: Georgia, Illinois, Indiana, Kentucky, Michigan, 

North Carolina, Ohio, South Carolina, Tennessee, Virginia, and West Virginia.3 

The MANE-VU June 20, 2007 Statement requested that the above-listed states 

outside MANE-VU pursue the adoption and implementation of the following 

control strategies, as appropriate and necessary: 

a. Timely implementation of BART requirements; 

b. A 90 percent or greater reduction in sulfur dioxide (SO2) emissions from 

each of the electric generating unit (EGU) stacks identified by MANE-VU 

(See Appendix P, List of Top 167 Sources, dated June 20, 2007) as 

reasonably anticipated to cause or contribute to impairment of visibility in 

each mandatory Class I Federal area in the MANE-VU region. If it is 

infeasible to achieve that level of reduction from a unit, alternative 

measures will be pursued in such State; 

c. The application of reasonable controls on non-EGU sources resulting in a 

28 percent reduction in non-EGU SO2 emissions relative to on-the-books, 

on-the-way 2018 projections used in regional haze planning, by 2018, 

which is equivalent to the projected reductions MANE-VU will achieve 

through its low sulfur fuel oil strategy; and 

d. Continued evaluation of other measures including measures to reduce SO2 

and NOx emissions from all coal-burning facilities by 2018 and 

promulgation of new source performance standards for wood combustion. 

These measures and other measures identified will be evaluated during the 

consultation process to determine if they are reasonable. 

 3

In addition, the State of Vermont identified at least one source in the State of 

Wisconsin as a significant contributor to visibility impairment at the Lye Brook Wilderness 

Class I Area.
9-22 

These measures and other measures identified were evaluated prior to and during 

the consultation process and the above course of action was determined to be 

reasonable. Assumptions about the implementation of these measures are 

represented by the inventory and modeling assumptions described in this section. 

As stated above, this long-term strategy to reduce and prevent regional haze will 

allow each state up to 10 years to pursue adoption and implementation of 

reasonable and cost-effective NOx and SO2 control measures as appropriate and 

necessary.

In addition to the above controls in the U.S., the MANE-VU Class I states 

determined that it was reasonable to include anticipated emissions reductions in 

Canada in the modeling used to set reasonable progress goals. Six coal-burning 

EGUs in Canada totaling 6500MW are scheduled to be shut down and replaced 

with nine natural gas turbine units with Selective Catalytic Reduction (SCR) before 

2018. 

See Section 9.5 for a description of how these emissions controls were modeled 

in order to estimate the visibility impact of the MANE-VU “Ask.” 
9-23 

Table 9-6 - Estimated SO2 Emissions from Non-EGU BART-Eligible Facilities Located in New Y

Modeling 

State Facility Name Unit Name SCC Code

Plant ID 

(from the 

MANE-VU 

Inventory)

Point ID (from 

the MANE-VU 

Inventory)

Facility Type

2002 

Emiss

(ton

NY KODAK PARK DIVISION U00015 10200203 8261400205 U00015 Chemical Manufacturer 237NY

LAFARGE 

BUILDING 

MATERIALS INC 

41000 30500706 4012400001 041000 Portland Cement 148
9-24 

9.8 Implementation of MANE-VU’s Low Sulfur Fuel Strategy

The MANE-VU states agreed through consultations to pursue a low sulfur fuel 

strategy within the region. This phased strategy would be implemented in two 

steps. However, both components of the strategy are to be fully implemented by 

2018. 

NESCAUM initially analyzed both steps of the program as separate strategies, but 

it is the combined benefit of implementing the program that is relevant to the 

question of program benefits in 2018. To estimate the total 2018 emissions 

reductions from this strategy, 2018 OTB/OTW SO2 emissions were reduced from 

all MANE-VU non-EGU sources burning #1, #2, #4, #5, or #6 oil. Emissions 

reductions reflected lowering the sulfur content in fuel from its original level to 

0.015 percent for #1 and #2 oil; to 0.25 percent for #4 oil; and to 0.5 percent for #5 

and #6 oil. 

The first phase of the MANE-VU low sulfur fuel strategy requires the lowering of 

fuel-sulfur content in distillate (No. 2 oil) from current levels that range between 

2,000 and 2,300 ppm down to 500 ppm by weight. It also restricts the sale of 

heavier blends of residual oil (No. 4 fuel oil and No. 6 bunker fuels) that have 

sulfur content greater than 0.25 percent sulfur and 0.5 percent sulfur by weight, 

respectively. 

The second phase of the strategy further reduces the fuel-sulfur content of the 

distillate fraction to 15 ppm sulfur by weight. The two phases of the MANE-VU 

low sulfur fuel strategy are to be implemented in sequence with slightly different 

timing for an “inner zone”4 generally corresponding to the I-95 corridor and the 

remainder of MANE-VU. All states, however, have agreed to pursue reductions 

that would take place no later than 2018. Based on the fuel sulfur limits within the 

first phase of the strategy, MANE-VU estimated a decrease of 140,000 tons of 

SO2 emitted from distillate combustion and a decrease of 40,000 tons of SO2 

from residual combustion in MANE-VU. 

The second phase of the MANE-VU low sulfur fuel strategy further reduces the 

sulfur content of distillate from 500 ppm to 15 ppm while keeping the sulfur limits 

on residual oils to 0.25 percent and 0.5 percent for No. 4 and No. 6 oils, 

respectively. By lowering the distillate fuel sulfur limit from 500 ppm to 15 ppm, 

MANE-VU estimates an additional reduction of 27,000 tons of SO2 emissions in 

MANE-VU from distillate combustion in 2018. 

 4 The inner zone includes New Jersey, Delaware, New York City, and potentially 

portions of eastern Pennsylvania. 
9-25 

Figure 9-1 shows the full benefit of the MANE-VU fuel strategies being considered 

relative to the “On The Books/On The Way” baseline. NESCAUM used the 

concentration changes illustrated in Figure 9-1 to estimate the visibility benefits 

for this strategy. Because the fuel sulfur program only affects sources within 

MANE-VU, that region sees the largest PM2.5 reduction and the greatest visibility 

benefits.

Figure 9-1 - Average Change in 24-hr PM2.5 Due to 

Low Sulfur Fuel Strategies Relative to OTB/OTW (ug/m3

)

 

9.9 Impacts of Reducing Emissions of SO2 from 167 EGU Stacks

SO2 emissions from power plants are the single largest sector contributing to the 

visibility impairment experienced in the Northeast’s Class I areas. The SO2 

emissions from power plants continue to dominate the inventory. Sulfate formed 

through atmospheric processes from SO2 emissions are responsible for over half 

the mass and approximately 70-80 percent of the extinction on the worst visibility 

days (NESCAUM’s Contribution Assessment and Conceptual Model). 
9-26 

In order to ensure that EGU controls are targeted at those EGUs with the greatest 

impact on visibility in MANE-VU, a modeling analysis was conducted to determine 

which sources those were. A list of 167 EGU stacks was developed that includes 

the 100 largest impacts at each MANE-VU Class I site during 2002. Emissions 

from the list of 167 EGU stacks can be found in Figure A-2 of Appendix A 

(Appendix W of this document) of the report entitled, Documentation of 2018 

Emissions from Electric Generating Units in the Eastern United States for MANEVU’s Regional Haze Modeling. MANE-VU requested 90 percent control on all 

units emitting from those stacks by 2018 as part of consultations within MANE-VU 

and with other RPOs. 

Preliminary modeling showed that requiring SO2 emissions from these 167 EGU 

stacks to be reduced by 90 percent could reduce 24-hour PM2.5 concentrations. 

NESCAUM modeled 2018 emissions for the 167 EGU stacks in the Northeast, 

Southeast, and Midwest at levels equal to 10 percent of their 2002 emissions. 

NESCAUM used CMAQ to model sulfate concentrations in 2018 after 

implementation of this control program and converted sulfate concentrations to 

PM2.5 concentrations. Figure 9-2 displays the average change in 24-hr PM2.5. 
9-27 

Figure 9-2 - Preliminary Estimate of Average Change 

in 24-hr PM2.5 Due to 90 Percent Reduction in SO2 Emissions 

from 167 EGU Stacks Affecting MANE-VU

Figure 9-2 shows that significant reductions of PM2.5 were predicted for the 

MANE-VU region as well as for portions of the VISTAS and Midwest RPO regions 

as a result of reducing SO2 emissions by 90 percent from 167 EGU stacks 

affecting MANE-VU. 

While these reductions are potentially large, based on consultations with affected 

states, it was determined to be unreasonable to expect that the full 90 percent 

emissions reductions would be achieved by 2018. Therefore, further modeling 

was conducted to assess a more realistic scenario.

MANE-VU’s “Best and Final” modeling is documented in the report 2018 Visibility 

Projections (NESCAUM, March 2008), Appendix V. This modeling estimated 

composite visibility benefits of all strategies within and outside MANE-VU rather 

than the benefits of individual strategies. 
9-28 

9.10 Reducing Non-EGU SO2 Emissions Outside MANE-VU by 28 Percent

In addition to these measures (BART controls within MANE-VU, low sulfur fuel 

within MANE-VU, and controls on specific EGUs), MANE-VU asked neighboring 

RPOs to consider further non-EGU emissions reductions comparable to those 

achieved through MANE-VU’s low sulfur fuel strategies, which are expected to 

achieve a greater than 28 percent reduction in non-EGU SO2 emissions in 2018. 

After consultation with other states and consideration of comments received, the 

MANE-VU Class I States decided that MANE-VU’s Best and Final modeling would 

include implementation of these additional emissions reductions. 

In order to model the impact of this strategy on visibility at MANE-VU Class I 

areas, the following reductions were made to emissions in the VISTAS and MRPO 

regions:

For both Southeast and Midwest States: 

• Coal-Fired ICI Boilers: Emissions were reduced by 60 percent. 

• Oil-Fired ICI boilers: Emissions were reduced by 75 percent. 

• ICI Boilers lacking fuel specification: Emissions were reduced by 50 

percent 

Additional controls required in the Southeastern States: 

• Emissions from Other Area Oil-Combustion sources were reduced by 75 

percent. (Used the same SCCs identified in MANE-VU Oil strategies list.) 

9.11 Implementation of Gas-Turbine EGU Controls in Canada

As requested by the MANE-VU Class I States, for the Best and Final Modeling, 

NESCAUM also removed SO2 emissions from 6500MW of six coal-burning EGUs 

in Canada that are scheduled to be shut down.5

 It is expected that these units will 

be replaced with nine natural gas turbine units with Selective Catalytic Reduction 

(SCR) controls. NESCAUM based estimated emission rates for modeled 

pollutants on a combination of factors, including recommendations from the State 

of New Hampshire, a NYSERDA study, and AP-42 ratios among pollutants. 

Emissions were reduced by more than 144,000 tons per year as a result of this 

measure.

 5

 NESCAUM’s 2018 Visibility Projections report cited a November 2006 paper by 

the Ontario Power Authority, “Ontario’s Integrated power System Plan Discussion Paper 

7: Integrating the Elements—A Preliminary Plan.” 

 See http://www.powerauthority.on.ca/ipsp/Storage/32/2734_DP7_IntegratingTheElements.pdf
9-29 

9.12 Results of Best and Final Modeling

In order to estimate the visibility impacts of the measures discussed above, 

NESCAUM conducted regional modeling using the CMAQ chemical transport 

model. Documentation of this modeling is contained in the report 2018 Visibility 

Projections (NESCAUM, March 2008), Appendix V. Based on currently available 

information and up-to-date modeling tools, this modeling provides an estimate of 

visibility improvement that could be achieved by 2018 through the reasonable 

measures described above based on currently available information and up-todate modeling tools. 

Figures 9-3 through 9-7 show the uniform rate of progress for each MANE-VU 

Class I area as well as the estimated combined visibility benefits of the strategies 

described in Section 9.5 above. All areas are expected to achieve sufficient 

visibility improvement by 2018 to meet or exceed the required improvements 

based on the uniform rate of progress. As a contributing state implementing the 

emissions measures under the “Ask” of the Class I area states, New York will 

therefore meet its obligation under this SIP and the Regional Haze Program. 

Figure 9-3 - Projected Visibility Improvement at Acadia National Park Based 

on 2009 and 2018 Best and Final Projections

0

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9-30 

Figure 9-4 - Projected Visibility Improvement at Brigantine National Wildlife 

Refuge Based on Best and Final Modeling

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9-31 

Figure 9-5 - Projected Visibility Improvement at Great Gulf Wilderness Area 

Based on Best and Final Modeling6

 6

 The estimate for Great Gulf Wilderness Area also serves to provide an estimate 

for the Presidential Range/Dry River Wilderness Area

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9-32 

Figure 9-6 - Projected Visibility Improvement at Lye Brook Wilderness Area 

Based on Best and Final Modeling

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9-33 

Figure 9-7 - Projected Visibility Improvement at Moosehorn National Wildlife 

Refuge and Roosevelt/Campobello International Park 

Based on Best and Final Modeling7

9.13 Comparison to the Clean Air Act 

The control measures that are a part of the “Ask” will result in at least as much 

visibility improvement that is expected from implementation of other CAA 

requirements during the planning period. See Updated Visibility Statistics for the 

MANE-VU Region, Appendix D. 

9.14 Reporting 

Progress will be reported to the EPA every five years in accordance with 40 CFR 

Section 51.308(g). If reasonable progress requirements are not met, New York 

will submit a revision of the haze SIP with the necessary corrections.

 7

 The estimate for Moosehorn National Wildlife Refuge also serves to provide an 

estimate for Roosevelt/Campobello International Park.

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