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 ar ea to establish, for each Cla ss I area within the state, visibility goals (expressed in deciviews ) that provide fo r 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 fo r the most impaired days, and ensure no degradation in visibility for the least impai red 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 improvem ent continues at the rate represented by the reas onable progress goal (RPG).

This SIP covers the first pl anning period which ends in 2018.

Under 40 CFR Section 51.308 (d)(1)(iv) c onsultation is required in developing reasonable progress goals. The rule states:

“In developing each reasonable progre ss goal, the State must consult with those States which may reasonably be anticipated to cause or contribute to visibility impairment in the m andatory 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 im plementation 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 environment al impacts, and remaining useful life). The Class I states also must show that they considered the uniform rate of improvement and the emissi on 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 c onditions if visibility improvement continues at the rate proposed.

9.1 Consultation and Agr eement with Other States’ Goals

The MANE-VU states of New Jersey, Ne w 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 contribut ed to visibility impairment in Class I

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

Class I states asked for New York Stat e’s continued participation in further consultation with these states during t he summer of 2007. New York agreed in9-2 written responses back to these states. Consistent with the R egional Haze Rule requirements, New York State has cons ulted, and continues to consult, with states containing Class I areas that ar e or may be impacted by emission sources within New York State as they estab lished 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 ar eas 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 reasonab le progress goals for the initial period of the SIP (i.e., 2018) as we ll 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 c aused or contributed to regional haze within each state’s Class I areas and requesti ng participation in the consultation process, it was anticipat ed that the Department would receive a similar letter from each of these states (New Jers ey, New Hampshire, Maine and Vermont) advising that the consultation process had resulted in the recommendation that certain, specific measures would be requi red in order to m eet the reasonable progress goals for each Class I area in thes e states. Althoug h 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 Ha mpshire’s consultation letter (Appendix X), is indicative of the meas ures that must be taken.

Except as provided below, the reasonab le progress modeling used by MANE-VU states to establish reasonable progre ss 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 cons ider to be reasonable to implement by 2018 including CAIR, BART, and other federal and state r equirements.

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

meet the Reasonable Pr ogress Goals and long-term strategy requirements developed for New York's regional haze SI P at MANE-VU’s Class I areas. New York commits to satisfying its responsib ilities under the Regi onal Haze Program, the Act, and this SIP.

MANE-VU’s Contribution Assessment (Appendi x A) indicated t hat the dominant contributor to visibility im pairment is SO2. Control of SO2 emissions, therefore, will yield the greatest near-t erm benefit. It has been de termined 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 measures9-3 described above. These are reasonable measures designed to meet our CAA Section 110(a)(2)(D) obligations.

Except as provided below, the reasonab le 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, t hose 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 condi tions to natural visibility conditions, which quantifies the impr ovement 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 requir ed to show that visibility improvements will ultimately meet the 2064 goal. St ates without Class I areas contribute to9-4 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 goa l for each Class I area, both natural conditions and baseline visibility for t he 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) af fected by emissions from New York provide for at least as much visibility im provement by 2018 as would be achieved by the uniform rate of progress shown above.

9.2 Reasonable Progr ess Goals for Class I Areas

In accordance with the requirements of 40 CFR Section 51. 308(d)(1), this Regional Haze SIP addresses the necessa ry measures that New York State

must take to meet the r easonable progress goals for each Class I area located in MANE-VU for the period of the implement ation 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 Visibil ity Conditions, Considerations and Proposed Approach to

the Calculation of Baseline and Natural Visi bility Conditions at MANE-VU Class I Areas,”
NESCAUM, December 20069-5 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) Deciviewimprovement 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 12.29-6 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 visi bility for the 5-year period from 2000 through 2004 were calculated in conf ormance 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 Progr ess Under the Regional

Haze Rule (EPA-454/B-03-004, Septem ber 2003) as updated by the alternative method for calculating r egional haze recommended by the IMPROVE Steering

Committee.

To determine the RPG in deciviews, MA NE-VU conducted modeling with certain control measure assumptions. The c ontrol measures reflected in these

2 “Baseline and Natural Visibility C onditions, 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, contri buting 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 stat e up to 10 years to pursue adoption and implementation of reasonabl e and cost-effective NOx and SO2 control measures as appropriate and necessary.

9.2.1 Consideration of Ot her Air Quality Requirements

40 CFR Section 51.308 (d)(1)(vi) of EPA’s R egional Haze Rule requires that reasonable progress goals represent at leas t the visibility improvement expected from implementation of other Clean Air Act progr ams 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 pr ograms required by the Clean Air Act. Further information may be found in those sect ions of this SIP

and in the documentation fo r the MANE-VU modeling.

9.2.2 Rationale for Dete rmining Reasonable Controls

40 CFR 51.308(d)(1)(i)(A) of EPA’s Region al Haze Rule requires that, in establishing reasonable progress goals fo r each Class I area, the state must consider the costs of compliance, the ti me 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 we re taken into consideration in setting

the RPGs. These factors are sometime s termed the “four st atutory factors,”

since their consideration is required by the Clean Air Act.

MANE-VU conducted a Contribution Asse ssment (Appendix A) and developed a conceptual model that showed the dominant contributor to visibility impairment at all MANE-VU Class I areas during all seas ons in the base year was particulate

sulfate formed from emissions of SO2. While other pol lutants, including organic carbon, will need to be addressed in order to achieve the national visibility goals, MANE-VU’s contribution assessment sugges ted that an early emphasis on SO2 would yield the greatest near-term benefit. Therefore, it is reasonable to

conclude that the additional measures c onsidered in setting reasonable progress goals require reductions in SO2 emissions.

The MANE-VU Contribution Assessment i ndicates that emissions from within9-8 MANE-VU in 2002 were responsible for appr oximately 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 document ed the source categories most responsible for visibility degradation at MA NE-VU Class I Areas. As described in Section 10, Long Term Strategy, there wa s a collaborative effort between the Ozone Transport Commission and MANE-VU to evaluate a large number of potential control measures. Several meas ures that would reduce SO2 emissions were identified for further study.

These efforts led to production of t he MANE-VU report by MACTEC Federal Programs, Inc., “ Assessment of Reasonable Progr ess for Regional Haze in

MANE-VU Class I Areas ,” Final, July 9, 2007, otherwise known as the Reasonable Progress Report (A ppendix J). This report provides an analysis of the four statutory fa ctors for five major source ca tegories: electrical generating units (EGUs); industrial, commercial, and institutional (ICI) boilers; cement and lime kilns; heating oil combustion; and re sidential 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 Result s from Four-Factor Analysis of Different Source Categories

Source Category Primary Regional

Haze
Pollutant Control Measure(s) A verage Cost in

2006 dollars

(per ton of pollutant
reduction ) Compliance
Timeframe Energy and
Non-Air Quality
Environmental Impacts Remaining

Useful Life

Electric Generating

Units SO 2 Switch to a lo w -sulfur coal (generally <1% sulfur); switch to natural gas (virtually 0% sulfur); coal cleaning; flue gas desulfurization (FGD), including wet, spray-dry, or
dr

y

. $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 SO 2 Switch to a lo w -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
dr

y

. $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 SO 2 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 SO 2 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
inducemen t $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 f our-factor analyses presented in the Reasonable Progress Report, consulted with one another about possible control9-10 measures, and concluded by adopting t he statements known as the MANE-VU “Ask.” These statements identify the c ontrol measures that would be pursued toward improving visibility in the regi on. 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 Retr ofit 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, stat es must establish baselines from which reasonable progress will be measured. The progress sought is in visibility improvement. However, emission reduction s are effectively used as a surrogate for this progress, with visibility improvement assessed over the first five years of the implementation of the haz e SIP. If mid-course adjustments are appropriate at that time, the SIP will be revised to pr ovide for any necessary corrections. The baseline year for emissions reductions used by MANE-VU is 2002.

Sulfates have been identified as the majo r 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 e ffort, 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 Electr ic Generating Units (EGUs);

$ Point and area source industrial, comme rcial and institutional boilers (ICI boilers);

$ Cement kilns;

$ Lime kilns;

$ The use of heating oil; and

$ Residential wood combustion.

In assessing each of these categorie s, MACTEC conducted an analysis of economic and environmental impacts of pot ential 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 wa s 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 qualit y environmental impacts; and 4. Remaining useful lif e 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 MA NE-VU as being necessary to meet the reasonable progress goal r equirements. These measur es 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 abov e in Tables 9-2a and 9-2b represent implementation of the regi onal strategy adopted by MANE-VU on June 20, 2007 entitled, Statement of the Mid-Atlantic/Nor theast 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 implem entation of the following “emission management” strategi es, as appropriate and necessary:9-12 a. Timely implementation of BART requirements, and

b. A 90 percent or greater reduction in sulfur diox ide (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 cont ribute 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 sulf ur by weight (500 ppm) by no later than 2012, ii. #4 residual oil to 0.25 percent sulf ur by weight by no later than
2012, iii. #6 oil to 0.3 – 0.5 percent sulf ur 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 t he outer zone states (t he remainder of the MANE-VU region) to reduce the sulfur content of:

i. Distillate oil to 0.05 percent sulf ur 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 measur es including energy efficiency, alternative clean fuels, and other measures to reduce SO2 and

NOx emissions from all coal-burni ng facilities by 2018 and new source performance standards for wood combusti on. 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 im plementation 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 esti mate the visibility im pact 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 severa l states that contain Class I areas. Through the collaborative effort described above, these Class I states have

identified control measur es that should be applied in order to meet the Reasonable Progress Goal s out until 2018. These measures include the application of Best Available Retrofit Technology (BART) to eligible facilities as expeditiously as practicable, but no late r than January 1, 2013, sulfate reductions from specific source sectors defined in t he Clean Air Act, a low-sulfur oil strategy for all sectors (commercial, industrial, and residential), an EGU strategy that targets a 90% sulfate reduc tion from each of the sta cks 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 anticipat es meeting these goals as follows:

a. Timely implementat ion of BART requirements

New York is in the process of pr omulgating 6 NYCRR Part 249 which will contain the requirements fo r 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 expe cted to be completed by May 2010.

After promulgation is completed, BART requirements will be applied in New York to eligible sources in accordance with feder al requirements, including the Class I areas’ requested control measures.

b. Ninety percent or gr eater reduction in sulfur di oxide (SO2) emissions from the 167 electric generating unit (EGU) stacks.

A 90 percent or greater r eduction in sulfur dioxi de (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 or9-14 contribute to impairment of visibili ty 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 measur es will be pursued in such State.

Table 9-4 below identifies the facilitie s 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 fr om 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 descr ibed 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 reduc e emissions significantly, approaching the required 90%. As such, in aggregate, it is expected that the necessary

reductions will be achieved to meet th is 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 fr om BART controls are 19,942 TPY.

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

• The total emissions being modeled a fter 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 HUNTLEY 1 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 HUNTLEY 1 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

DUNKIRK 1 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: 1 Consent order requires NOx and SO2 emissions r eductions by 2013. Controls not yet determined.9-17 c. Low sulfur fuel oil strategy in New York

A low sulfur fuel oil reduction strat egy will be implemented to reduce the sulfur content to specific limit s 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 t hese measures is as follows:

Proposal in State Regi ster: July 1, 2011 Package to Environmental Board: October 1, 2011 File Regulation with the Secret ary 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 approv e the SIP within a year, the schedule is subject to change.

d. Continued evaluat ion of other measures

The evaluation of other control m easures, including energy efficiency, alternative clean fuels, and other measures to reduce SO2 and NOx emissions from all coal-burning fa cilities by 2018 and new source performance standards for wood combus tion, will be continued. This is expected to take place on an ongoing basis, and will be more formally assessed during the five-year reasse ssment of the effectiveness of the regional haze SIP required under 40 CF R Section 51.308(g). For example,

MANE-VU considered how to best deal with residential wood combustion and outdoor wood boilers. Although nei ther have significant sulfate emissions, both of these source categor ies 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 precurso rs to some of the pollutants that cause regional haze and, as such, this r eduction will also have a positive impact on the impairment of visibilit y in Class I areas as well as others. Although these measures are not part of New York’s co mmitments for the purposes of this SIP,9-18 additional VOC control meas ures 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 OT B/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 Cle an Air Visibility Rule requires that in establishing reasonable progress goals fo r 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 a ffected sources, and the SIP must include a demonstration showing how these factor s were taken into consideration in setting the goal. These factors are someti mes 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 emissi ons from New York is presented in Appendix N, MANE-VU Basis for Reasonable Controls , of this document for

reference.

Preliminary modeling wa s 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 Pr ogress Goals: Model Performance Evaluation, Pollution Apportionme nt, and Control Measure Benefits (February 2008, Appendix R).

NESCAUM also conducted additional re vised 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 requirement s 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 es timates 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 exami ned. Measurements from IMPROVE and STN networks were paired with model pr edictions by location and time for evaluation. These comparisons show ed that predicted PM 2.5 sulfate and measured sulfate were in a good 1:1 li near 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 PM 2.5 species, modeled PM2.5 showed a relatively strong near 1:1 linear relationshi p. Generally, the nor thern region of the area modeled displayed str onger 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 coeffici ent (Bext) and the haze i ndex. Modeled daily aerosol

extinction at each IMPROVE site was ca lculated following the IMPROVE formula with modeled daily PM2.5 species concentra tion and relative humidity factors from IMPROVE. The approaches used here and throughout the analysis have used natural background visibility estima tes 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 pr ediction of the Bext agreed well with
IMPROVE observation because CMAQ performed well on su lfate, which

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

calculated based on modeled Bext. A paired comparison between CMAQ prediction and IMPROVE meas urement 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 perform ance occurred at Lye Brook, which is the closest area to New York State, and Shenandoah. However, since sulfates comprise the largest contribution to visibi lity impairment, it would be reasonable to expect that modeling results would provi de good estimates of the effectiveness of the control strategies proposed in Ne w 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 gi ven 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 show n to be overwhelmingly the most significant, it is possible to infer each states' contribut ions in a general sense by examining the relative emissions in New Yo rk 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 compar ed 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 th e effect of BART on other (non-CAIR) sources within MANE-VU.

To assess the impacts of the implement ation of BART on non-CAIR sources in MANE-VU, NESCAUM estimated reductions fo r eight BART-eligible facilities. A survey of state staff indicated that t hese eight units would likely be controlled under BART alone. These states provi ded 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-e ligible sources at eight facilities that were included in modeling used to set reasonable progress goals.9-21 9.7 Controls Outside of MANE-VU Sele cted 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 Uni on (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 th is 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 Cla ss I areas in 2002. This includes the following states outside MANE-VU: Georgia, Illinois, Indiana, Kentucky, Michigan, North Carolina, Ohio, South Carolina, T ennessee, Virginia, and West Virginia. 3

The MANE-VU June 20, 2007 Statement req uested that the above-listed states outside MANE-VU pursue the adoption and implementation of the following control strategies, as appropriate and necessary:

a. Timely implementatio n of BART requirements;

b. A 90 percent or greater reduction in sulfur diox ide (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 cont ribute 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 contro ls on non-EGU sources resulting in a 28 percent reduction in non-EGU SO2 emi ssions relative to on-the-books, on-the-way 2018 projections used in regional haze planning, by 2018, which is equivalent to the projec ted reductions MANE-VU will achieve through its low sulfur f uel 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 perform ance standards for wood combustion.

These measures and other measures i dentified will be evaluated during the consultation process to determi ne if they are reasonable.

3 In addition, the State of Ve rmont identified at least one source in the State of Wisconsin as a significant contributor to visi bility impairment at t he Lye Brook Wilderness

Class I Area.9-22 These measures and other measures identif ied were evaluated prior to and during the consultation process and the above c ourse of action was determined to be reasonable. Assumptions about the impl ementation of these measures are represented by the inventor y 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 im plementation of

reasonable and cost-effective NOx and SO2 c ontrol 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 in clude anticipated emissions reductions in Canada in the modeling used to set reas onable 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 Se lective Catalytic Reduction (SCR) before

2018.

See Section 9.5 for a descrip tion of how these emission s controls were modeled

in order to estimate the visibi lity impact of the MANE-VU “Ask.”9-23Table 9-6 - Estimated SO2 Emissions from Non-EGU BART-Eligible Facilities Located in New York Used in FinalModelingStateFacility NameUnitNameSCCCodePlant ID(from theMANE-VUInventory)Point ID (fromthe MANE-VUInventory)Facility Type2002 SO2Emissions(tons)2018 SO2Emissions(tons)NYKODAK PARKDIVISIONU00015 10200203 8261400205 U00015ChemicalManufacturer23798 14216NYLAFARGEBUILDINGMATERIALS INC41000 30500706 4012400001 041000PortlandCement14800 44409-24 9.8 Implementation of MA NE-VU’s Low Sulfur Fuel Strategy

The MANE-VU states agreed th rough consultations to pursue a low sulfur fuel strategy within the region. This phased strategy would be implemented in two steps. However, both compone nts of the strategy are to be fully implemented by

2018.

NESCAUM initially analyzed both steps of the program as separ ate 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 SO 2 emissions were reduced from all MANE-VU non-EGU sources burning #1, #2, #4, #5, or #6 oil. Emissions reductions reflected lowering the sulfur cont ent in fuel from its original level to 0.015 percent for #1 and #2 oil; to 0.25 perc ent 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 le vels that range between 2,000 and 2,300 ppm down to 500 ppm by weigh t. 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 su lfur 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. T he two phases of the MANE-VU low sulfur fuel strategy are to be implemented in sequ ence with slightly different timing for an “inner zone” 4 generally corresponding to the I-95 corridor and the remainder of MANE-VU. All states, how ever, 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 es timated a decrease of 140,000 tons of

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

from residual combustion in MANE-VU.

The second phase of the MANE-VU low sulf ur 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 f uel 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, De laware, New York City, and potentially portions of eastern Pennsylvania.9-25 Figure 9-1 shows the full benef it of the MANE-VU fuel st rategies being considered

relative to the “On The Books/On T he Way” baseline. NESCAUM used the concentration changes illustrated in Figure 9- 1 to estimate the visibility benefits for this strategy. Because the fuel su lfur program only affects sources within MANE-VU, that region sees the largest PM 2.5 reduction and the greatest visibility

benefits.

Figure 9-1 - Average Change in 24-hr PM 2.5 Due to Low Sulfur Fuel Strategies Relative to OTB/OTW (ug/m 3 )

9.9 Impacts of Reducing Emissi ons of SO2 from 167 EGU Stacks

SO2 emissions from power plants are the si ngle largest sector contributing to the visibility impairment experienced in t he Northeast’s Class I areas. The SO2 emissions from power plants continue to dominate the inv entory. 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 Asse ssment and Conceptual Model).9-26 In order to ensure that EGU controls are targeted at th ose EGUs with the greatest impact on visibility in MANE-VU, a mode ling 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 show ed 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 t he 167 EGU stacks in the Northeast, Southeast, and Midwest at levels equal to 10 percent of thei r 2002 emissions.
NESCAUM used CMAQ to model sulfate concentrations in 2018 after implementation of this control program and converted sulfate concentrations to

PM 2.5 concentrations. Figure 9-2 displa ys the average change in 24-hr PM2.5.9-27 Figure 9-2 - Preliminary Esti mate of Average Change

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

from 167 EGU Stacks A ffecting MANE-VU

Figure 9-2 shows that significant reductions of PM 2.5 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 la rge, 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” modelin g is documented in the report 2018 Visibility Projections (NESCAUM, March 2008), Appendix V. This modeling estimated composite visibility benefits of all stra tegies within and outside MANE-VU rather than the benefits of individual strategies.9-28 9.10 Reducing Non-EG U SO2 Emissions Outside MANE-VU by 28 Percent

In addition to these measures (BART cont rols within MANE-VU, low sulfur fuel within MANE-VU, and controls on specif ic EGUs), MANE-V U asked neighboring

RPOs to consider further non-EGU emi ssions reductions comparable to those achieved through MANE-VU’s low sulfur f uel strategies, which are expected to achieve a greater than 28 per cent reduction in non-EGU SO2 emissions in 2018.

After consultation with other states and c onsideration of comments received, the

MANE-VU Class I States decided that MA NE-VU’s Best and Final modeling would include implementation of these additional emissions reductions.

In order to model the impac t of this strategy on vi sibility 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 specificat ion: 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 identif ied in MANE-VU Oil strategies list.)

9.11 Implementation of Gas-Turb ine EGU Controls in Canada

As requested by the MANE-VU Class I Stat es, 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 esti mated emission rates for modeled pollutants on a combination of factors, including recommendations from the State of New Hampshire, a NY SERDA study, and AP-42 rati os 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 In tegrated power System Plan Discussion Paper 7: Integrating the Element s—A Preliminary Plan.”

See http://www.powerauthority.on.ca/ipsp/Stor age/32/2734_DP7_IntegratingTheElements.pdf9-29 9.12 Results of Be st and Final Modeling

In order to estimate th e visibility impacts of t he measures discussed above, NESCAUM conducted regional modeling us ing the CMAQ chemical transport

model. Documentation of this m odeling is contained in the report 2018 Visibility Projections (NESCAUM, March 2008), Appendix V. Based on currently available information and up-to-date modeling tools, th is modeling provides an estimate of visibility improvement t hat could be achieved by 2018 through the reasonable

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

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

Class I area as well as the estimated combi ned visibility benefits of the strategies

described in Section 9.5 above. All ar eas 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 stat e implementing the

emissions measures under t he “Ask” of the Class I ar ea states, New York will therefore meet its obligat ion under this SIP and the Regional Haze Program.

Figure 9-3 - Projected Visi bility Improvement at A cadia National Park Based on 2009 and 2018 Best and Final Projections

0 5 10 15 20 25 30

1 9 8 5 1 9 9 0 1 9 9 5 2 0 0 0 2 0 0 5 2 0

1 0 2 0

1 5 2 0 2 0 2 0 2 5 2 0 3 0 2 0 3 5 2 0 4 0 2 0 4 5 2 0 5 0 2 0 5 5 2 0 6 0 2 0 6 5
Yea r D e c i v e w s 20% Worst Observed

20% Best Observed

20% Worst Baseline

20% Best Baseline Uniform Progress No Degradation
CMAQ 20% Worst
CMAQ 20% Best

20% Best 'Natural'9-30 Figure 9-4 - Projected Visibility Impro vement at Brigantine National Wildlife Refuge Based on Best and Final Modeling

0 5 10 15 20 25 30 35

1 9 8 5 1 9 9 0 1 9 9 5 2 0 0 0 2 0 0 5 2 0

1 0 2 0

1 5 2 0 2 0 2 0 2 5 2 0 3 0 2 0 3 5 2 0 4 0 2 0 4 5 2 0 5 0 2 0 5 5 2 0 6 0 2 0 6 5
Yea r D e c i v e w s 20% Worst Observed

20% Best Observed

20% Worst Baseline

20% Best Baseline Uniform Progress No Degradation
CMAQ 20% Worst
CMAQ 20% Best

20% Best 'Natural'9-31 Figure 9-5 - Projected Visi bility Improvement at Great Gulf Wilderness Area Based on Best and Final Modeling 6

6 The estimate for Great Gulf Wilderness Area also serves to provide an estimate for the Presidential Range/ Dry River Wilderness Area 0 5 10 15 20 25 30

1 9 8 5 1 9 9 0 1 9 9 5 2 0 0 0 2 0 0 5 2 0

1 0 2 0

1 5 2 0 2 0 2 0 2 5 2 0 3 0 2 0 3 5 2 0 4 0 2 0 4 5 2 0 5 0 2 0 5 5 2 0 6 0 2 0 6 5

Y ea r D e c i v e w s 20% Worst Observed

20% Best Observed

20% Worst Baseline

20% Best Baseline Uniform Progress No Degradation

CMAQ 20% Worst
CMAQ 20% Best

20% Best 'Natural'9-32 Figure 9-6 - Projected Visi bility Improvement at Lye Brook Wilderness Area Based on Best and Final Modeling

0 5 10 15 20 25 30

1 9 8 5 1 9 9 0 1 9 9 5 2 0 0 0 2 0 0 5 2 0

1 0 2 0

1 5 2 0 2 0 2 0 2 5 2 0 3 0 2 0 3 5 2 0 4 0 2 0 4 5 2 0 5 0 2 0 5 5 2 0 6 0 2 0 6 5
Yea r D e c i v e w s 20% Worst Observed

20% Best Observed

20% Worst Baseline

20% Best Baseline Uniform Progress No Degradation
CMAQ 20% Worst
CMAQ 20% Best

20% Best 'Natural'9-33 Figure 9-7 - Projected Visi bility Improvement at Mo osehorn National Wildlife Refuge and Roosevelt/Campobello International Park Based on Best and Final Modeling 7

9.13 Comparison to the Clean Air Act

The control measures that ar e 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 reas onable progress requirement s are not met, New York

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

7 The estimate for Moosehorn National Wild life Refuge also serves to provide an

estimate for Roosevelt/Cam pobello International Park. 0 5 10 15 20 25

1 9 8 5 1 9 9 0 1 9 9 5 2 0 0 0 2 0 0 5 2 0

1 0 2 0

1 5 2 0 2 0 2 0 2 5 2 0 3 0 2 0 3 5 2 0 4 0 2 0 4 5 2 0 5 0 2 0 5 5 2 0 6 0 2 0 6 5

Yea r D e c i v e w s 20% Worst Observed

20% Best Observed

20% Worst Baseline

20% Best Baseline Uniform Progress No Degradation
CMAQ 20% Worst
CMAQ 20% Best

20% Best 'Natural'