NH Regional Haze 5-Year Progress Report 

ATTACHMENT A – Acronyms and Abbreviations

BART Best Available Retrofit Technology 

bbl barrel (of oil)

BLM Bureau of Land Management

BOTW beyond-on-the-way

CAA Clean Air Act 

CAIR Clean Air Interstate Rule

CAMD Clean Air Markets Division

CEMS continuous emissions monitoring system

CENRAP Central Regional Air Planning Association 

CFR Code of Federal Regulations

CSAPR Cross-State Air Pollution Rule

EGU electricity generating unit 

EPA US Environmental Protection Agency 

ERTAC Eastern Regional Technical Advisory Committee

FGD flue gas desulfurization

FLM federal land manager 

FS US Forest Service

FWS US Fish and Wildlife Service

hr hour

IMPROVE Interagency Monitoring of Protected Visual Environments

LAC light-absorbing carbon

lb pound

MANE-VU Mid-Atlantic/Northeast Visibility Union 

MAR marine air rail

MARAMA Mid-Atlantic Regional Air Management Association 

MATS Mercury and Air Toxics Standards

MMBtu million British thermal units

MOVES Motor Vehicle Emissions Simulator

MRPO Midwest Regional Planning Organization 

MW megawatt

NAAQS national ambient air quality standard(s)

NESCAUM Northeast States for Coordinated Air Use Management 

NHDES New Hampshire Department of Environmental Services

NMIM National Mobile Inventory Model

NOx nitrogen oxides

NPS National Park Service 

NSPS new source performance standard(s)

OCM organic carbon mass

ORISPL Office of Regulatory Information Systems Plant Location

OTB/OTW on-the-books/on-the-way

OTC Ozone Transport Commission 

PM particulate matter 

PM2.5 particulate matter of diameter 2.5 micrometers or less 

ppm parts per million

PSD Prevention of Significant Deterioration

PSNH Public Service of New Hampshire

RPG reasonable progress goal

RPO regional planning organization 

RACT reasonably available control technology

RATA relative accuracy test audit

SIP state implementation plan 

SO2 sulfur dioxide 

TSD technical support document

VISTAS Visibility Improvement State and Tribal Association of the Southeast 

VOC volatile organic compounds

WRAP Western Regional Air Partnership
NH Regional Haze 5-Year Progress Report

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NH Regional Haze 5-Year Progress Report

ATTACHMENT B

Tracking Visibility Progress, 2004-2011

http://www.nescaum.org/documents/manevu-trends-2004-2011-report-final-20130430.pdf
NH Regional Haze 5-Year Progress Report

This page is intentionally left blank.
Tracking Visibility Progress

2004-2011

Prepared by

NESCAUM

for the

Mid-Atlantic/Northeast Visibility Union (MANE-VU)

April 30, 2013

Revised May 24, 2013
Members of Northeast States for Coordinated Air Use Management

Arthur Marin, Executive Director

Northeast States for Coordinated Air Use Management

Anne Gobin, Bureau Chief

Connecticut Department of Energy and Environmental Protection, Bureau of Air Management

Marc Cone, Bureau Director

Maine Department of Environmental Protection, Bureau of Air Quality

Christine Kirby, Division Director

Massachusetts Department of Environmental Protection, Bureau of Waste Prevention

Craig Wright, Acting Director

New Hampshire Department of Environmental Services, Air Resources Division

William O’Sullivan, Director

New Jersey Department of Environmental Protection, Office of Air Quality Management

David Shaw, Director

New York Department of Environmental Conservation, Division of Air Resources

Douglas L. McVay, Chief

Rhode Island Department of Environmental Management, Office of Air Resources

Richard A. Valentinetti, Director

Vermont Department of Environmental Conservation, Air Pollution Control Division
ii

Tracking Visibility Progress

2004-2011

Prepared by

NESCAUM

for the 

Mid-Atlantic/Northeast Visibility Union (MANE-VU)

April 30, 2013

Revised May 24, 2013
iii

TRACKING VISIBILITY PROGRESS

2004-2011

Project Manager

Paul Miller

Principal Contributor

Leiran Biton
iv

Acknowledgments

NESCAUM could not have completed this work without the IMPROVE Program and the 

long-term commitment of the National Park Service and other federal partners to 

maintain visibility monitoring networks and the VIEWS data system. NESCAUM also 

acknowledges the funding for this work through USEPA agreement number XA96309001 to the Ozone Transport Commission in support of MANE-VU. Finally, special 

thanks to Tom Downs with the Maine Department of Environmental Protection for his 

assistance in compiling observational data. NESCAUM is solely responsible for the 

content of this report and any errors it may contain.

Printed: May 2013
v

TABLE OF CONTENTS

Acknowledgments.............................................................................................................. iv

Executive Summary......................................................................................................... viii

1. Introduction................................................................................................................ 1-1

1.1. Background...................................................................................................... 1-1

2. Process for Tracking Progress ................................................................................... 2-1

2.1. Long Term Goals and Natural Visibility ......................................................... 2-1

2.2. Reasonable Progress Goals.............................................................................. 2-2

2.3. Measurement and Data Support....................................................................... 2-3

3. Results........................................................................................................................ 3-1

3.1. Haze Index Trends........................................................................................... 3-1

3.2. Constituent Light Extinction Trends................................................................ 3-9

3.3. Conclusions on Visibility Progress................................................................ 3-23

4. Discussion.................................................................................................................. 4-1

5. References.................................................................................................................. 5-1

Appendix A: Tracking Progress Data for Class I Areas in and Adjacent to the MANE-VU 

Region
vi

FIGURES

Figure 1-1. Class I Areas of the MANE-VU Region...................................................... 1-2

Figure 3-1. Annual Haze Index Levels at Acadia National Park.................................... 3-2

Figure 3-2. Annual Haze Index Levels at Moosehorn Wilderness Area ........................ 3-3

Figure 3-3. Annual Haze Index Levels at Great Gulf Wilderness Area ......................... 3-4

Figure 3-4. Annual Haze Index Levels at Lye Brook Wilderness Area ......................... 3-5

Figure 3-5. Annual Haze Index Levels at Brigantine Wilderness Area ......................... 3-6

Figure 3-6. Annual Haze Index Levels at Dolly Sods Wilderness Area ........................ 3-7

Figure 3-7. Annual Haze Index Levels at Shenandoah National Park ........................... 3-8

Figure 3-8. Individual Constituent Contribution to Annual Haze Index Levels at 

Acadia National Park on 20 Percent Best and Worst Visibility Days ................ 3-11

Figure 3-9. Individual Constituent Contribution to Annual Haze Index Levels at 

Moosehorn Wilderness Area on 20 Percent Best and Worst Visibility Days..... 3-12

Figure 3-10. Individual Constituent Contribution to Annual Haze Index Levels at 

Great Gulf Wilderness Area on 20 Percent Best and Worst Visibility Days...... 3-13

Figure 3-11. Individual Constituent Contribution to Annual Haze Index Levels at 

Lye Brook Wilderness Area on 20 Percent Best and Worst Visibility Days...... 3-14

Figure 3-12. Individual Constituent Contribution to Annual Haze Index Levels at 

Brigantine Wilderness Area on 20 Percent Best and Worst Visibility Days...... 3-15

Figure 3-13. Individual Constituent Contribution to Annual Haze Index Levels at 

Dolly Sods Wilderness Area on 20 Percent Best and Worst Visibility Days..... 3-16

Figure 3-14. Individual Constituent Contribution to Annual Haze Index Levels at 

Shenandoah National Park on 20 Percent Best and Worst Visibility Days........ 3-17

Figure 3-15. Range of Observed and Estimated Natural Light Extinction for 

Select Individual Constituents at Acadia National Park on 20 Percent Best 

and Worst Visibility Days................................................................................... 3-18

Figure 3-16. Range of Observed and Estimated Natural Light Extinction for 

Select Individual Constituents at Moosehorn Wilderness Area on 20 

Percent Best and Worst Visibility Days.............................................................. 3-19

Figure 3-17. Range of Observed and Estimated Natural Light Extinction for 

Select Individual Constituents at Great Gulf Wilderness Area on 20 Percent 

Best and Worst Visibility Days........................................................................... 3-20

Figure 3-18. Range of Observed and Estimated Natural Light Extinction for 

Select Individual Constituents at Lye Brook Wilderness Area on 20 Percent 

Best and Worst Visibility Days........................................................................... 3-21

Figure 3-19. Range of Observed and Estimated Natural Light Extinction for 

Select Individual Constituents at Brigantine Wilderness Area on 20 Percent 

Best and Worst Visibility Days........................................................................... 3-22
vii

TABLES

Table 1-1. Members of the Mid-Atlantic/Northeast Visibility Union (MANE-VU)...... 1-1

Table 2-1. Natural Visibility Conditions for Class I Areas in and Adjacent to the 

MANE-VU Region ............................................................................................... 2-1

Table 2-2. 2018 Goals for Class I Areas in or Adjacent to the MANE-VU Region ...... 2-2

Table A-1. Tracking Progress Data for Class I Areas in and Adjacent to the 

MANE-VU Region (dv)....................................................................................... A-2
Executive Summary

In this report, we present visibility trends at federal “Class I areas” in the MidAtlantic/Northeast Visibility Union (MANE-VU) region that are subject to the US 

Environmental Protection Agency’s (USEPA’s) Regional Haze Rule (RHR). This 

analysis was performed to determine the extent of progress in meeting short-term and 

long-term visibility goals under the RHR.

This technical document provides an analysis of visibility data collected at the 

Class I areas, starting in the historic baseline period of 2000-2004 through 2007-2011, the 

most recent five-year period with available data. 

The results of this analysis show the following:

 There are definite downward trends in overall haze levels at the Class I 

areas in and adjacent to the MANE-VU region. 

 Based on rolling-five year averages demonstrating progress since the 

2000-2004 baseline period, the MANE-VU Class I areas appear to be on 

track to meet their 2018 Reasonable Progress Goals (RPGs) for both best 

and worst visibility days. 

 The trends are mainly driven by large reductions in sulfate light extinction, 

and to a lesser extent, nitrate light extinction. 

 Levels of organic carbon mass (OCM) and light absorbing carbon (LAC) 

appear to be approaching natural background levels at most of the MANEVU Class I areas. 

 In some cases, the levels set by 2018 RPGs have already been met, and 

progress beyond those goals appears achievable. 

 Though the Brigantine Wilderness Area is on track to meet its 2018 RPGs, 

challenges remain. Sulfate light extinction levels are higher at this site 

than at others across the region. Additional sulfate reductions would be a 

significant driver in reducing overall haze levels at Brigantine.
Tracking Visibility Progress, 2004-2011 Page 1-1

1. INTRODUCTION

1.1. Background

Haze, or reduced visibility, occurs when ambient particulate matter and gases

scatter or absorb light (“light extinction”) that would otherwise reach an observer. The 

particles responsible for regional haze are produced naturally, from windblown dust, 

forest fires, and aerosolized sea salt; and by human-caused pollution from vehicles, 

power plants, and other combustion and dust-generating activities. Haze-forming 

particles can also cause serious health effects in the lungs and cardiopulmonary system, 

potentially leading to premature death. Some particle constituents contribute to acidic 

deposition and other environmental harms. 

In 1999, the US Environmental Protection Agency (USEPA) issued a rule under 

Section 169A of the Clean Air Act (Visibility Protection for the Federal Class I Areas) to 

address human-caused regional haze: the Regional Haze Rule (RHR) [64 FR 35614 (July 

1, 1999)]. The RHR is designed to improve visibility at certain national parks and 

wilderness areas (Class I areas) on the haziest days while not exacerbating haze on the 

clearest days. The RHR requires states to submit state implementation plans (SIPs) to 

USEPA every ten years, setting interim progress goals and strategies consistent with the 

long-term national visibility goal of achieving natural conditions at Class I areas by 2064. 

States submitted their first haze SIPs to USEPA beginning in 2008. States are 

additionally required to track their progress against their historic baseline period1in 

achieving reductions in regional haze, submitting reports every five years, and to adjust 

their emissions management strategies accordingly.

The Mid-Atlantic/Northeast Visibility Union (MANE-VU) was formed to support 

visibility planning efforts in the mid-Atlantic and northeastern portion of the country, and 

includes the members listed in Table 1-1. The seven Class I areas in the MANE-VU 

region are shown in Figure 1-1. This document also includes information for two Class I 

areas that are adjacent to the MANE-VU region: the Dolly Sods Wilderness Area in West 

Virginia and Shenandoah National Park in Virginia. The purpose of this report is to 

 

1 The title of this and earlier trends reports use 2004 as the base year because the trend is based on rolling 

averages of 5-year periods, and 2004 was the end of the initial 5-year period used as the baseline.

Table 1-1. Members of the Mid-Atlantic/Northeast Visibility Union (MANE-VU)

Connecticut Pennsylvania

Delaware Penobscot Indian Nation

District of Columbia Rhode Island

Maine St. Regis Mohawk Tribe

Maryland Vermont

Massachusetts National Park Service

New Hampshire U.S. EPA

New Jersey U.S. Fish and Wildlife Service

New York U.S. Forest Service

Source: MANE-VU Board Members, http://www.otcair.org/manevu/members.asp.
Tracking Visibility Progress, 2004-2011 Page 1-2

support MANE-VU states in meeting the tracking progress requirement of the RHR.

While this report provides readers with a basic background on regional haze, it 

does not include in-depth discussion of topics covered in previous reports. For a broader 

understanding of these topics, readers should visit the NESCAUM regional haze 

documents archive, located at the following web address:

http://www.nescaum.org/topics/regional-haze.

In the documents archive, readers may find the following of particular interest in 

understanding regional haze in the MANE-VU region:

 Regional Haze and Visibility in the Northeast and Mid-Atlantic States (2001)

 2002: A Year in Review (2004)

 Contributions to Regional Haze in the Northeast and Mid-Atlantic United States

(2006)

 Public Health Benefits of Reducing Ground-level Ozone and Fine Particulate 

Matter in the Northeast U.S. (2008)

 MANE-VU Modeling for Reasonable Progress Goals (2008)

 2018 Visibility Projections (2008)

 Tracking Visibility Progress, 2004-2008 (2010)

 Contribution of Non-Sulfate Aerosols to MANE-VU Regional Haze (2012)

Figure 1-1. Class I Areas of the MANE-VU Region
Tracking Visibility Progress, 2004-2011 Page 1-3

 The Nature of the Fine Particle and Regional Haze Air Quality Problems in the 

MANE-VU Region: A Conceptual Description (Updated July 31, 2012)
Tracking Visibility Progress, 2004-2011 Page 2-1

2. PROCESS FOR TRACKING PROGRESS

2.1. Long Term Goals and Natural Visibility

Even in the absence of emissions from human activities, some level of light 

extinction occurs from natural causes. This “natural haze” represents the best expectation 

for long-term progress at Class I areas, and is the goal for these areas by 2064. 

The USEPA (2003a) has guidance for calculating natural haze levels based on 

measurements of particulate constituents at Class I areas during a baseline period. States 

combine measurements of several parameters to calculate a “Haze Index” in deciview 

(dv) units based on estimates of light extinction. A fuller explanation of tracking progress 

procedures is presented in a 2003 USEPA guidance document for tracking progress 

(USEPA 2003b; hereafter, “the Guidance”), though readers should note that the 

calculation for estimating total light extinction has since been updated. Details on the 

revised IMPROVE algorithm used to estimate light extinction are presented elsewhere 

(e.g., NESCAUM 2010).

Natural haze levels are calculated for both the least impaired (i.e., clearest or 

“best”) days and the most impaired (i.e., haziest or “worst”) days, because changing 

natural processes lead to variability in natural visibility. Natural visibility levels on least 

and most impaired (i.e., best and worst) days for the MANE-VU and adjacent Class I 

Table 2-1. Natural Visibility Conditions for Class I Areas in and Adjacent to the 

MANE-VU Region

Class I Area

State

Abbr.

Best Days

(dv)

Worst 

Days (dv)

Acadia National Park ME 4.66 12.43

Moosehorn Wilderness Area ME 5.01 12.01

Roosevelt Campobello International Park* ME - -

Great Gulf Wilderness Area NH 3.73 11.99

Presidential Range/Dry River Wilderness

Area*

NH - -

Lye Brook Wilderness Area VT 2.79 11.73

Brigantine Wilderness Area NJ 5.51 12.24

Dolly Sods Wilderness Area† WV 3.63 10.39

Shenandoah National Park† VA 3.14 11.35

Note: The Class I areas are arranged with the areas located in the MANE-VU region 

presented first, followed by those adjacent to MANE-VU.

* Natural haze values are not calculated for areas without baseline monitoring data.

Visibility for the Presidential Range/Dry River Wilderness Area and Roosevelt 

Campobello International Park are represented by the IMPROVE monitors for Great 

Gulf and Moosehorn, respectively.

Source: IMPROVE 2011 (IMPROVE Natural Haze Levels II version 2 workbook).

† Class I area adjacent to the MANE-VU region.
Tracking Visibility Progress, 2004-2011 Page 2-2

areas are presented in Table 2-1. Achievement of these goals through constant annual 

incremental improvement in the Haze Index (in dv) such that natural conditions will be 

reached by 2064 is termed a “uniform rate of progress.” Natural background haze levels 

are not available for some Class I areas without monitoring data, i.e., Presidential 

Range/Dry River Wilderness Area and Roosevelt Campobello International Park.

2.2. Reasonable Progress Goals

The RHR requires states to evaluate current regional haze conditions at Class I 

areas subject to the rule relative to conditions during a historic baseline period. The 

baseline period is the five-year period from 2000 through 2004. The state haze SIPs 

established reasonable progress goals (RPGs) for reduction of regional haze through 

2018. Comparison between the five-year average Haze Index in 2018 (a back average of 

the previous five years’ annual Haze Index values) and the baseline Haze Index will 

determine whether a state has met its 2018 RPG.

A state sets RPGs for the 20 percent most impaired (i.e., the haziest or “worst”) 

days and for the 20 percent least impaired (i.e., clearest or “best”) days. The RPGs are 

designed to at least ensure no degradation for best-day visibility and achievement of 

uniform rate of progress for worst-day visibility. In most cases, states in the MANE-VU 

region have adopted RPGs that achieve lower Haze Index values by 2018 than would be 

achieved using either the “no degradation” and “uniform rate of progress” rates for best 

and worst days, respectively. Table 2-2 presents the best- and worst-day RPGs adopted 

Table 2-2. 2018 Goals for Class I Areas in or Adjacent to the MANE-VU Region

Class I Area

State

Abbr.

Best Days Worst Days

No 

Degradation 

(dv)

Reasonable 

Progress 

Goal (dv)

Uniform 

Rate of 

Progress 

(dv)

Reasonable 

Progress 

Goal (dv)

Acadia National Park ME 8.8 8.3 20.4 19.4

Moosehorn Wilderness Area ME 9.2 8.6 19.4 19.0

Roosevelt Campobello International Park ME 9.2 8.6 19.4 19.0

Great Gulf Wilderness Area NH 7.7 7.2 20.3 19.1

Presidential Range/Dry River Wilderness 

Area NH 7.7 7.2 20.3 19.1

Lye Brook Wilderness Area VT 6.4 5.5 21.5 20.9

Brigantine Wilderness Area NJ 14.3 14.3 25.1 25.1

Dolly Sods Wilderness Area† WV 12.3 11.1 24.7 21.7

Shenandoah National Park† VA 10.9 8.7 25.1 21.9

Note: The Class I areas are arranged with the areas located in the MANE-VU region presented first, 

followed by those adjacent to MANE-VU.

† Class I area adjacent to the MANE-VU region.

Sources: Maine: 76 FR 73956-73982; New Hampshire: 77 FR 11809-11826; New Jersey: 76 FR 49711-

49724; Vermont: 77 FR 11914-11928; Virginia: 77 FR 3691-3711; West Virginia: 76 FR 41158-41177.
Tracking Visibility Progress, 2004-2011 Page 2-3

by states for each Class I area in or adjacent to the MANE-VU region per state haze SIPs.

2.3. Measurement and Data Support

The Haze Index is calculated using light extinction estimates based on measured 

concentrations of particulate matter (PM) species. Measurements are taken at a network 

of sites in the Interagency Monitoring of Protected Visual Environments (IMPROVE) 

program at or near Class I areas. IMPROVE is the result of coordination between the 

National Park Service, the Fish and Wildlife Service, the Bureau of Land Management, 

the Forest Service, and USEPA. IMPROVE has operated 17 sites within the MANE-VU 

region since 2002. 

The Visibility Information Exchange Web System (VIEWS) team develops and 

maintains the IMPROVE website in addition to its other activities related to maintenance 

of air quality monitoring databases. Using the data from IMPROVE, the VIEWS team 

calculates and regularly posts updated metrics for tracking visibility across the country at 

the national parks and wilderness areas subject to the RHR. VIEWS is hosted at the 

Colorado State University’s Cooperative Institute for Research in the Atmosphere 

(CIRA).

Another resource, the Federal Land Manager Database (FED), is an extensive 

database of environmental data and an integrated suite of online tools and resources to 

help Federal Land Managers assess and analyze the air quality and visibility in federally

protected lands such as National Parks, National Forests, and Wilderness Areas.

For this analysis, we used data from IMPROVE (2011) downloaded through 

VIEWS for both the natural haze levels (calculated using the revised IMPROVE 

algorithm) and daily values, including patched values,

2

for 2000 through 2010. For 2011, 

we used unpatched data obtained from FED. We analyzed the individual missing 

constituent data for 2011 using the patching methodology described in the Guidance and 

determined that patching was unnecessary for all sites in and adjacent to the MANE-VU 

region for this analysis.

 

2

“Patching” is a procedure for replacing missing values for individual or multiple measured PM 

constituents with appropriate values, per the Guidance.
Tracking Visibility Progress, 2004-2011 Page 3-1

3. RESULTS

We analyzed total Haze Index and individual constituent light extinction annual 

results for each site in or adjacent to the MANE-VU region for years between 2000 and 

2011. The following sections describe the results of this analysis. Section 3.1 provides 

results for the total Haze Index for each site and discusses trends and progress toward 

short-term goals. Section 3.2 provides individual constituent analysis and trends for each 

site over the time period in the context of regional emissions reduction efforts and 

continued regional and federal policy directions. Finally, Section 3.3 summarizes 

conclusions based on these results. Results indicate consistent improvement in regional 

haze on the best and worst visibility days across the region.

3.1. Haze Index Trends

Figure 3-1 (page 3-2) through Figure 3-7 (page 3-8) present the annual Haze 

Index on the 20 percent most and least impaired days at MANE-VU and adjacent Class I 

areas between 2000 and 2011 in the context of short- and long-term visibility goals. The 

figures are arranged with the areas located in the MANE-VU region presented first, 

followed by those adjacent to MANE-VU. Table A-1 in Appendix A presents these data 

numerically.

Annual average best and worst visibility day Haze Index values are represented 

by blue and purple diamonds, respectively. Five-year back annual averages are 

represented by solid red (worst) and blue (best) lines. Red (worst) and black (best) plus 

signs represent the 2018 RPGs described in the state haze SIP. The red (worst) and black 

(best) dotted lines represent the glidepaths to meet 2018 RPGs. Red (worst) and black 

(best) dashed lines represent the glidepaths to meet long-term natural visibility goals; the 

worst-day glidepath is also called the “uniform rate of progress” line, and the best-day 

glidepath is also called the “no degradation” line.3The grey region denotes the range of 

20-percent best to worst haze levels expected to occur under natural conditions. Thus, the 

uniform rate of progress line intersects with highest portion of the grey area in 2064.

These figures indicate that haze levels on the best and worst days from 2000 

through 2011 have dropped across the entire region. Trends evident in our last report 

(NESCAUM 2010) for annual average haze levels on best and worst days through 2008 

have largely continued through 2010. In 2011, most of the areas experienced around the 

same or slightly higher levels of haze on both best and worst days as compared to 2010. 

The steep drop in Haze Index values for the 20 percent worst days, therefore, appears to 

have occurred primarily during the period between 2007 and 2010 for these areas.

 

3

For the Brigantine and Dolly Sods Wilderness Areas, whose haze levels on the 20 percent best days 

during the 2000 to 2004 baseline period were higher than estimated natural conditions on the 20 percent 

worst days, the no degradation line (representing the long-term best-day goal) is higher than the uniform 

rate of progress line (representing the long-term worst-day goal) at dates approaching 2064. This 

nonsensical situation by 2064 is an artifact of technical guidance and only represents stated haze level 

goals, not anticipated results.
Tracking Visibility Progress, 2004-2011 Page 3-2

Figure 3-1. Annual Haze Index Levels at Acadia National Park
Tracking Visibility Progress, 2004-2011 Page 3-3

Figure 3-2. Annual Haze Index Levels at Moosehorn Wilderness Area
Tracking Visibility Progress, 2004-2011 Page 3-4

Figure 3-3. Annual Haze Index Levels at Great Gulf Wilderness Area
Tracking Visibility Progress, 2004-2011 Page 3-5

Figure 3-4. Annual Haze Index Levels at Lye Brook Wilderness Area
Tracking Visibility Progress, 2004-2011 Page 3-6

Figure 3-5. Annual Haze Index Levels at Brigantine Wilderness Area
Tracking Visibility Progress, 2004-2011 Page 3-7

Figure 3-6. Annual Haze Index Levels at Dolly Sods Wilderness Area
Tracking Visibility Progress, 2004-2011 Page 3-8

Figure 3-7. Annual Haze Index Levels at Shenandoah National Park
Tracking Visibility Progress, 2004-2011 Page 3-9

Comparison of the five-year annual average haze index to the glidepaths for the 

2018 SIP commitments show that all areas in and adjacent to the MANE-VU region are 

on pace to meet those commitments. In fact, the 2018 RPGs will be met if 5-year average 

levels for best and worst days are maintained at Acadia National Park and at the Great 

Gulf, Lye Brook, and Moosehorn Wilderness Areas. However, the small uptick in annual 

average haze levels in 2011 for most areas in the MANE-VU region demonstrates that

efforts are still needed to ensure that 2018 RPGs will be met and to prevent backsliding.

The small relative increase for 2011 over the previous several years is almost certainly 

due, at least in part, to special and converging circumstances: the economic downturn

followed by slow recovery, unusual meteorology, and the rapid shift toward natural gas.

At Brigantine Wilderness Area and both Class I areas adjacent to the MANE-VU 

region, best-day visibility levels are already below 2018 RPGs, but worst-day visibility

levels require additional progress to meet the short-term goals.

3.2. Constituent Light Extinction Trends

In addition to analyzing trends in overall visibility changes at the sites, we also 

examined the data for changes in individual PM constituent contributions to visibility 

impairment. Figure 3-8 through Figure 3-14 present the annual Haze Index by constituent 

on the 20 percent least and most impaired days at MANE-VU and adjacent Class I areas 

between 2000 and 2011 in the context of RPGs. The figures are arranged with the areas 

located in the MANE-VU region presented first, followed by those adjacent to MANEVU.

These figures show individual constituent values as stacked bar charts for sulfate, 

nitrate, organic carbon mass (OCM), light absorbing carbon (LAC), soil, coarse mass, sea 

salt, and Rayleigh extinction levels on best (left, “a”) and worst (right, “b”) days. The 

total of the stacked bars represent annual Haze Index values, and are marked by circles 

connected by a thin black line. The thick black line represents five-year back annual 

averages from 2004 to 2011. The 2018 RPG from the state haze SIP is marked with a 

black plus sign. Two red lines descend from the 2004 five-year back average (i.e., the 

baseline value): the red dotted line represents the glidepath to the 2018 RPG; and the red 

dashed line represents the glidepath to the 2064 natural visibility goal, or the “uniform 

rate of progress” line.

These figures confirm that large reductions in overall Haze Index values on the 

20 percent worst days are primarily due to decreases in sulfate visibility impacts at 

MANE-VU Class I areas. Steady decreases in sulfate and nitrate contributions have also 

reduced overall haze levels on the least impaired days. These decreases occurred mainly 

from 2005 through 2011 at most of the studied areas, though in some locations (e.g.,

Dolly Sods Wilderness Area, Shenandoah National Park), the contribution from sulfate 

stopped its decline in 2009 and held steady or increased on the worst days through 2011.

Despite the reduced contribution from sulfate on the worst days at most of the 

MANE-VU Class I areas, the overall level of haze has remained largely unchanged since 

about 2009 on the worst days due to increases in contributions from sea salt and organic 

carbon mass, depending on the site. At Brigantine, the contribution from coarse mass in 

2011 was unusually high, indicating a possible anomaly for that year (Pietarinen 2013). 
Tracking Visibility Progress, 2004-2011 Page 3-10

This increase in coarse mass contribution offset reductions in both nitrate and sulfate 

levels from the preceding years. Contribution from OCM appears to be highly variable 

from year to year at most sites. For instance, high OCM extinction levels at Brigantine 

and Lye Brook Wilderness Areas in 2002, and at Great Gulf Wilderness Area in 2011 on 

the worst days, undercut declines in contributions from sulfate to raise overall haze levels 

for those years.

Sulfate remains the most significant contributor to light extinction at all Class I 

areas on the most impaired days in and adjacent to the MANE-VU region, followed by 

OCM and nitrate. For the most part, light extinction from soil and sea salt, which help 

indicate the extent to which natural haze processes contribute to overall haze levels, are 

insignificant when compared to extinction from sulfate and nitrate. Based on these 

figures, continued progress in sulfate and nitrate levels appears to be driving the trend in 

overall improvement in worst- and best-day haze level reductions.

To examine the individual constituent trends more closely, we plotted the range of 

individual light extinction on best and worst days from 2000 through 2011 at the Class I 

areas against the estimated light extinction under natural conditions. Figure 3-15 through

Figure 3-19 show the range of light extinction levels at the MANE-VU Class I areas 

(areas adjacent to the MANE-VU region are excluded from this analysis for simplicity) 

as compared to natural light extinction for selected constituents. Estimated natural light 

extinction is represented in each chart by the lighter grey band, and observed extinction 

by the other band. For the case of the carbonaceous species, OCM and LAC, the green

band is observed OCM and the dark grey band is observed LAC. Note that the 

observations do not represent the range of the highest and lowest 20 percent light 

extinction levels for those constituents; rather, they represent the range of constituent 

light extinction levels on the 20 percent least and most impaired visibility days. For Great 

Gulf Wilderness Area, where observations were missing in 2009 and 2010, 2011 

observations are presented as a broad range rather than a single data point for ease of 

visualization, but note that this is a visual distortion.

It is clear from these charts that levels of extinction from sulfate have dropped

significantly since 2002 at all the MANE-VU Class I areas, although still remaining at 

levels much higher than the estimated natural range at all sites. Extinction due to nitrate 

has also dropped steadily, and at several sites is approaching natural levels on the best 

days. At Brigantine Wilderness Area, extinction due to nitrate remains considerably 

higher than the natural baseline. At Acadia National Park, levels of extinction due to 

carbonaceous constituents and coarse mass appear to be approximately at natural levels. 

At Great Gulf, Lye Brook, and Moosehorn Wilderness Areas, coarse mass extinction is 

approximately at natural levels, and carbonaceous matter has dropped from levels slightly 

above natural into the natural range. Prior peaks in carbonaceous matter extinction at 

these sites were driven by OCM levels. At Brigantine Wilderness Area, carbonaceous 

matter has been holding steadily above natural levels with little observable trend 

downward, and coarse mass light extinction levels also remain above natural levels, 

though the 2011 peak in coarse mass light extinction may be a result of construction 

activity near the monitor location (Pietarinen 2013).
Tracking Visibility Progress, 2004-2011 Page 3-11

Figure 3-8. Individual Constituent Contribution to Annual Haze Index Levels at Acadia National Park on 20 Percent Best and 

Worst Visibility Days

(a) 20% Best Days (b) 20% Worst Days
Tracking Visibility Progress, 2004-2011 Page 3-12

Figure 3-9. Individual Constituent Contribution to Annual Haze Index Levels at Moosehorn Wilderness Area on 20 Percent 

Best and Worst Visibility Days

(a) 20% Best Days (b) 20% Worst Days
Tracking Visibility Progress, 2004-2011 Page 3-13

Figure 3-10. Individual Constituent Contribution to Annual Haze Index Levels at Great Gulf Wilderness Area on 20 Percent 

Best and Worst Visibility Days

(a) 20% Best Days (b) 20% Worst Days
Tracking Visibility Progress, 2004-2011 Page 3-14

Figure 3-11. Individual Constituent Contribution to Annual Haze Index Levels at Lye Brook Wilderness Area on 20 Percent 

Best and Worst Visibility Days

(a) 20% Best Days (b) 20% Worst Days
Tracking Visibility Progress, 2004-2011 Page 3-15

Figure 3-12. Individual Constituent Contribution to Annual Haze Index Levels at Brigantine Wilderness Area on 20 Percent 

Best and Worst Visibility Days

(a) 20% Best Days (b) 20% Worst Days
Tracking Visibility Progress, 2004-2011 Page 3-16

Figure 3-13. Individual Constituent Contribution to Annual Haze Index Levels at Dolly Sods Wilderness Area on 20 Percent 

Best and Worst Visibility Days

(a) 20% Best Days (b) 20% Worst Days
Tracking Visibility Progress, 2004-2011 Page 3-17

Figure 3-14. Individual Constituent Contribution to Annual Haze Index Levels at Shenandoah National Park on 20 Percent 

Best and Worst Visibility Days

(a) 20% Best Days (b) 20% Worst Days
Tracking Visibility Progress, 2004-2011 Page 3-18

Figure 3-15. Range of Observed and Estimated Natural Light Extinction for Select Individual Constituents at Acadia 

National Park on 20 Percent Best and Worst Visibility Days

Notes: Light extinction from (a) sulfate, (b) nitrate, (c) carbonaceous matter (i.e., organic carbon mass or OCM and light 

absorbing carbon or LAC), and (d) coarse mass, alongside estimated natural light extinction from those constituents.
Tracking Visibility Progress, 2004-2011 Page 3-19

Figure 3-16. Range of Observed and Estimated Natural Light Extinction for Select Individual Constituents at Moosehorn 

Wilderness Area on 20 Percent Best and Worst Visibility Days

Notes: Light extinction from (a) sulfate, (b) nitrate, (c) carbonaceous matter (i.e., organic carbon mass or OCM and light 

absorbing carbon or LAC), and (d) coarse mass, alongside estimated natural light extinction from those constituents.
Tracking Visibility Progress, 2004-2011 Page 3-20

Figure 3-17. Range of Observed and Estimated Natural Light Extinction for Select Individual Constituents at Great Gulf 

Wilderness Area on 20 Percent Best and Worst Visibility Days

Notes: Light extinction from (a) sulfate, (b) nitrate, (c) carbonaceous matter (i.e., organic carbon mass or OCM and light 

absorbing carbon or LAC), and (d) coarse mass, alongside estimated natural light extinction from those constituents.
Tracking Visibility Progress, 2004-2011 Page 3-21

Figure 3-18. Range of Observed and Estimated Natural Light Extinction for Select Individual Constituents at Lye Brook 

Wilderness Area on 20 Percent Best and Worst Visibility Days

Notes: Light extinction from (a) sulfate, (b) nitrate, (c) carbonaceous matter (i.e., organic carbon mass or OCM and light 

absorbing carbon or LAC), and (d) coarse mass, alongside estimated natural light extinction from those constituents.
Tracking Visibility Progress, 2004-2011 Page 3-22

Figure 3-19. Range of Observed and Estimated Natural Light Extinction for Select Individual Constituents at Brigantine 

Wilderness Area on 20 Percent Best and Worst Visibility Days

Notes: Light extinction from (a) sulfate, (b) nitrate, (c) carbonaceous matter (i.e., organic carbon mass or OCM and light 

absorbing carbon or LAC), and (d) coarse mass, alongside estimated natural light extinction from those constituents.
Tracking Visibility Progress, 2004-2011 Page 3-23

3.3. Conclusions on Visibility Progress

Despite variability in the year-to-year data, there are definite downward trends in 

overall haze levels at the Class I areas in and adjacent to the MANE-VU region. Based on 

rolling five-year averages demonstrating progress since the 2000-2004 baseline period, 

the MANE-VU Class I areas appear to be on track to meet their 2018 RPGs for both best 

and worst visibility days. The trends are mainly driven by large reductions in sulfate light 

extinction, and to a lesser extent, nitrate light extinction. Levels of carbonaceous matter 

(OCM and LAC) appear to be approaching natural levels at most of the MANE-VU 

Class I areas. In some cases, the levels set by these goals have already been met, and 

progress beyond the 2018 RPGs appears achievable. Though it is on track to meet its 

2018 RPGs, challenges remain for the Brigantine Wilderness Area. Sulfate light 

extinction levels are higher at this site than at others across the region, and continued 

sulfate reductions would be a significant driver in continuing to improve visibility at this 

site.
Tracking Visibility Progress, 2004-2011 Page 4-1

4. DISCUSSION

Reductions in air pollution continue to bring down levels of fine particulate matter 

in the eastern United States, which in turn are leading to improved visibility at federally 

protected Class I areas within and adjacent to the MANE-VU region. Since our last report 

(NESCAUM 2010), significant improvements in visibility at the MANE-VU Class I sites 

have been observed, and these changes have been largely driven by reductions in sulfate 

levels. Levels of nitrates and carbonaceous PM are also decreasing. 

Large emission reductions of nitrogen oxides (NOx) and sulfur dioxide (SO2) 

across the region in response to regional emission reduction requirements for power 

plants is likely a principal driver for these visibility improvements. Further reductions 

over the next several years should occur if the power sector continues to control or phase 

out coal plants across the eastern United States in response to competitive pressures from

natural gas generation, overall reduced electricity demand, and more stringent 

requirements to reduce emissions of air toxics (e.g., acid gases, toxic metals).

In addition to addressing emissions from power plants, states across the Northeast 

have enacted or are in process of enacting low sulfur content requirements for fuel oils, 

which cover home heating oil (distillate) and residual oils (#4 and #6). At the federal 

level, USEPA has proposed the Tier 3 motor vehicle program that includes lowering

sulfur content in gasoline. While gasoline combustion is a minor source of SO2

emissions, the Tier 3 fuel requirements would significantly reduce NOx emissions from 

the existing fleet of on-road gasoline vehicles by reducing sulfur poisoning of the catalyst 

in catalytic converters, thus improving control technology performance. This would lead 

to lower nitrate levels, most notably during colder weather months when nitrates are more 

thermally stable. In warmer weather months, NOx promotes ground-level ozone

formation, which in turn can enhance formation of visibility-limiting secondary organic 

aerosols (Carleton et al. 2010). Therefore, lower levels of NOx as a result of Tier 3 can 

also improve visibility by reducing ozone formation that leads to carbonaceous PM.

In summary, the visibility data examined in this report demonstrate that broad, 

regional efforts to reduce emissions of visibility-impairing pollutants are having a 

beneficial effect at the region’s Class I areas. The most recent IMPROVE data indicate 

that the states continue to be on track to meet their 2018 reasonable progress goals for 

improved visibility. Further progress may occur through additional pollution reductions 

achievable under recently adopted or proposed regulatory programs.
Tracking Visibility Progress, 2004-2011 Page 5-1

5. REFERENCES

Carleton, A.G., R.W. Pinder, P.V. Bhave, and G.A. Pouliot. 2010. To What Extent Can 

Biogenic SOA be Controlled? 44 Environ. Sci. Technol. 3376-3380, doi:

10.1021/es903506b.

IMPROVE. 2011. IMPROVE and RHR Summary Data. Available at: 

http://vista.cira.colostate.edu/improve/Data/IMPROVE/summary_data.htm

NESCAUM. 2010. Tracking Visibility Progress, 2004-2008 (2010). MANE-VU 

Technical Memorandum, May 12, 2010. Available at 

http://www.nescaum.org/documents/tracking-progress-final-05-12-10.pdf

Pietarinen, C. 2013. Conversation with Charles Pietarinen, Chief of the Bureau of Air 

Monitoring at the New Jersey Department of Environmental Protection on March 

11, 2013. Mr. Pietarinen indicated that construction activity at the Brigantine 

Visitor’s Center, which is very close to the monitor, may have affected the 

monitoring site in recent years. Prescribed burns may also be having an influence

at the site.

US Environmental Protection Agency (USEPA). 2003a. Guidance for Estimating Natural 

Visibility Conditions Under the Regional Haze Rule. Research Triangle Park: 

Office of Air Quality Planning and Standards, September 2003. EPA-454/B-03-

005.

US Environmental Protection Agency (USEPA). 2003b. Guidance for Tracking Progress 

Under the Regional Haze Rule. Research Triangle Park: Office of Air Quality 

Planning and Standards, September 2003. EPA-454/B-03-004.
Tracking Visibility Progress, 2004-2011 Page A-1

Appendix A: Tracking Progress Data for Class I 

Areas in and Adjacent to the MANE-VU Region
Tracking Visibility Progress, 2004-2011 Page A-2

Appendix A: Tracking Progress Data for Class I Areas in and 

Adjacent to the MANE-VU Region

Tracking progress data for sites in the MANE-VU region are presented in Table 

A-1, and for sites adjacent to it in Table A-2. 

Table A-1. Tracking Progress Data for Class I Areas in and Adjacent to the MANEVU Region (dv)

Class I Area Year

Best Days Worst Days

Haze Index, 

Annual

Haze Index, 5-

Year Rolling

Haze Index, 

Annual

Haze Index, 5-

Year Rolling

Acadia National Park 2000 8.90 - 21.64 -

2001 8.87 - 23.28 -

2002 8.77 - 23.91 -

2003 8.77 - 23.65 -

2004 8.56 8.78 21.98 22.89

2005 7.58 8.51 23.01 23.17

2006 8.17 8.37 23.37 23.19

2007 8.21 8.26 21.74 22.75

2008 7.76 8.06 20.21 22.06

2009 6.92 7.73 18.93 21.45

2010 6.57 7.53 18.16 20.48

2011 7.35 7.36 18.80 19.57

Moosehorn Wilderness 

Area

2000 8.94 - 20.63 -

2001 9.31 - 22.14 -

2002 9.12 - 23.07 -

2003 9.48 - 22.50 -

2004 8.93 9.16 20.28 21.72

2005 7.99 8.97 22.36 22.07

2006 8.60 8.82 21.55 21.95

2007 7.79 8.56 19.24 21.19

2008 7.75 8.21 18.73 20.43

2009 6.83 7.79 17.71 19.92

2010 5.85 7.37 17.09 18.87

2011 6.84 7.01 17.07 17.97

Great Gulf Wilderness 

Area

2000 - -

2001 8.26 - 23.29 -

2002 7.77 - 24.84 -

2003 6.94 - 21.59 -

2004 7.68 7.66 21.56 22.82

2005 6.90 7.51 21.53 22.56

2006 6.43 7.14 21.12 22.13

2007 6.86 6.96 21.35 21.43

2008 6.20 6.81 16.78 20.47

2009 * 6.60 * 20.19

2010 * 6.50 * 19.75

2011 6.15 6.40 18.96 19.03

Symbols: “-” = not applicable; “*” = missing data; “†” = Class I Area adjacent to the MANE-VU region

Table continued on next page.
Tracking Visibility Progress, 2004-2011 Page A-3

Table A-1. Tracking Progress Data for Class I Areas in and Adjacent to the MANEVU Region (dv), continued

Best Days Worst Days

Class I Area Year

Haze Index, 

Annual

Haze Index, 5-

Year Rolling

Haze Index, 

Annual

Haze Index, 5-

Year Rolling

Lye Brook Wilderness 

Area

2000 6.49 - 23.45 -

2001 6.47 - 26.33 -

2002 6.43 - 25.52 -

2003 5.83 - 24.02 -

2004 6.61 6.37 22.91 24.45

2005 5.74 6.22 26.04 24.96

2006 5.24 5.97 22.31 24.16

2007 5.68 5.82 25.25 24.11

2008 * 5.82 * 24.13

2009 4.11 5.19 18.44 23.01

2010 3.96 4.75 19.88 21.47

2011 5.28 4.76 19.47 20.76

Brigantine Wilderness 

Area

2000 14.26 - 28.95 -

2001 13.83 - 28.38 -

2002 14.83 - 29.31 -

2003 14.39 - 29.79 -

2004 14.36 14.33 28.59 29.01

2005 14.61 14.40 29.62 29.14

2006 15.35 14.71 28.50 29.16

2007 12.74 14.29 26.91 28.68

2008 * 14.26 * 28.41

2009 12.78 13.87 24.25 27.32

2010 11.70 13.14 25.22 26.22

2011 12.78 12.50 25.78 25.54

Dolly Sods Wilderness 

Area†

2000 12.96 - 29.03 -

2001 13.30 - 28.24 -

2002 11.91 - 28.47 -

2003 11.54 - 29.73 -

2004 11.67 12.28 29.76 29.05

2005 12.09 12.10 30.89 29.42

2006 10.57 11.56 29.80 29.73

2007 10.27 11.23 29.52 29.94

2008 9.44 10.81 25.39 29.07

2009 8.70 10.21 22.17 27.55

2010 9.62 9.72 23.94 26.16

2011 8.67 9.34 24.44 25.09

Shenandoah National 2000 11.08 - 28.53 -

Park† 2001 13.21 - 29.21 -

2002 11.49 - 30.54 -

2003 9.48 - 28.94 -

2004 9.37 10.93 29.32 29.31

2005 10.48 10.81 30.75 29.75

2006 10.59 10.28 29.30 29.77

2007 11.13 10.21 28.79 29.42

2008 8.16 9.95 25.65 28.76

2009 8.23 9.72 21.81 27.26

2010 9.67 9.56 23.44 25.80

2011 7.80 9.00 23.42 24.62

Symbols: “-” = not applicable; “*” = missing data; “†” = Class I Area adjacent to the MANE-VU region
NH Regional Haze 5-Year Progress Report

ATTACHMENT C

Overview of State and Federal Actions Relative to MANE-VU Asks
NH Regional Haze 5-Year Progress Report

This page is intentionally left blank.
1 

Memorandum

Date: March 28, 2013 

To: MANE-VU 

From: Paul Miller, NESCAUM 

Re: Overview of state and federal actions relative to MANE-VU Asks 

This memorandum provides a summary of certain elements in regional haze state 

implementation plans (SIPs) within and outside the Mid-Atlantic/Northeast Visibility 

(MANE-VU) regional planning area.1 The SIPs covered are either from members of the 

MANE-VU regional planning organization (RPO), or from states outside the MANE-VU 

region that were identified as having emissions contributing 2% or more to sulfate levels 

at MANE-VU Class 1 areas. 

The elements reviewed in each regional haze SIP were in the context of requests from 

MANE-VU in 2007 that certain measures, or their equivalents, be adopted within each 

jurisdiction by 2018 (referred to as the “MANE-VU Asks”). MANE-VU deemed these 

measures as appropriate for making reasonable progress towards achieving the national 

goal of natural background visibility in Class 1 areas by 2064. The MANE-VU Asks 

differed in some respects between the MANE-VU members and states outside of the 

MANE-VU region, but were intended to encompass comparable sulfur dioxide (SO2) 

measures across all states. The specific elements of the MANE-VU Asks for inside and 

outside the MANE-VU region are given below according to two groupings of SIPs from 

inside and outside the MANE-VU region. 

A common Ask element inside and outside the MANE-VU region was for a 90% or 

greater SO2 emissions reduction by 2018 relative to 2002 from 167 electric generating 

unit (EGU) stacks. MANE-VU identified these specific stacks through modeling as 

having the largest impacts on visibility in its Class 1 areas among all modeled EGUs. 

This Ask element included flexibility for achieving the 90% reduction through alternative 

measures if not feasible at the stack. 

This summary provides a “snap shot” of SO2 emissions in 2011 at the individual stacks 

on the 167 EGU list. To provide additional context of state-wide reductions from 

 

1

 NESCAUM thanks the following people for helpful assistance in reviewing and commenting on the state 

summaries: Robert Betterton, WV Department of Environmental Protection; James Boylan, GA 

Department of Natural Resources; John Hornback, SESARM; Wendy Jacobs, CT Department of Energy 

and Environmental Protection; Joseph Jakuta, OTC; Rob Kaleel, LADCO; Glenn Keith, MA Department of 

Environmental Protection; Martin Luther, KY Division for Air Quality; Charles Martone, NH Department 

of Environmental Services; Julie McDill, MARAMA; Doris McLeod, VA Department of Environmental 

Quality; Anne McWilliams, EPA Region 1; Albert Pearce, GA Department of Natural Resources; John 

Sipple, DE Department of Natural Resources and Environmental Control; Roger Thunell, MD Department 

of the Environment. 
2 

potential “alternative measures,” we also use EPA’s Acid Rain Program data to compare 

overall state-wide SO2 reductions occurring in 2011 relative to 2002 against the requested 

amount from a state’s stacks on the 167 EGU stack list. The comparison uses reported 

emissions from the Acid Rain Program rather than from the Clean Air Interstate Rule 

(CAIR) because not all states receiving a MANE-VU Ask are covered by CAIR. In 

addition, emissions reporting under CAIR started several years after the 2002 MANE-VU 

Ask baseline. A state-level comparison of 2011 SO2 emissions reported in the Acid Rain 

Program and in the CAIR program found that reported SO2 emissions in both programs 

were within about 5% for most states. 

In addition to the MANE-VU Asks for states, MANE-VU also presented a federal ask to 

the U.S. Environmental Protection Agency (EPA) for additional national SO2 reductions 

from power plants. The current status of federal efforts is summarized in the third section 

of this memorandum. 

1. INSIDE MANE-VU REGION 

For the MANE-VU members, the “MANE-VU Ask” requested the following actions: 

• Timely implementation of BART requirements; and 

• 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: 

distillate oil to 0.05% sulfur by weight (500 ppm) by no later than 2012, of #4 

residual oil to 0.25% sulfur by weight by no later than 2012, of #6 residual oil to 

0.3 – 0.5% sulfur by weight by no later than 2012, and to further reduce the sulfur 

content of distillate oil to 15 ppm by 2016; and 

• A low sulfur fuel oil strategy in the outer zone States (the remainder of the 

MANE-VU region) to reduce the sulfur content of distillate oil to 0.05% sulfur by 

weight (500 ppm) by no later than 2014, of #4 residual oil to 0.25 – 0.5% sulfur 

by weight by no later than 2018, and of #6 residual oil to no greater than 0.5% 

sulfur by weight by no later than 2018, and to further reduce the sulfur content of 

distillate oil to 15 ppm by 2018, depending on supply availability; and 

• A 90% or greater reduction in sulfur dioxide (SO2) emissions from each of the 

top 100 electric generating units (EGUs) identified by MANE-VU (comprising a 

total of 167 stacks) as reasonably anticipated to cause or contribute to impairment 

of visibility in each mandatory Class 1 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 

• Continued evaluation of other control measures including energy efficiency, 

alternative clean fuels, and other measures to reduce SO2 and nitrogen oxide 

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

performance standards for wood combustion. These measures and other measures 
3 

identified will be evaluated during the consultation process to determine if they 

are reasonable and cost-effective. 

Connecticut 

Submittal Date of Regional Haze SIP 

November 18, 2009; February 24, 2012; March 12, 2012; November 23, 2012 

Haze SIP Status as of January 24, 2013 

EPA proposed approval, 77 FR 17367 (March 26, 2012); EPA supplemental proposed 

approval, 78 FR 5158 (January 24, 2013); final by April 26, 2013 (under extended 

consent decree).2

BART Requirements 

Connecticut identified an initial list of ten BART-eligible sources. Three BART-eligible 

sources were subsequently capped by consent order at below BART-eligible levels, 

removing them from the list. Connecticut determined that its existing rules achieved 

greater reductions from its remaining BART-eligible sources than from application of 

BART alone. 

Low Sulfur Oil Strategy Inner Zone 

Does not apply. 

Low Sulfur Oil Strategy Outer Zone 

Connecticut adopted low sulfur fuel oil rules and statute but implementation of the statute 

is contingent upon adoption of rules by Massachusetts (enacted), New York (enacted), 

and Rhode Island (not yet proposed). 

90% SO2 reduction of 167 EGU stacks 

Does not have listed stack. 

Evaluation of other control measures 

Connecticut agreed to continue evaluating other possible control measures consistent 

with the MANE-VU Ask, including investigating success of other state programs 

regulating outdoor wood burning furnaces, and adoption of the California Low Emission 

Vehicle (CA LEV) program revisions for mobile sources. 

Delaware 

Submittal Date of Regional Haze SIP 

September 25, 2008 

Haze SIP Status as of December 18, 2012 

EPA final approval, 76 FR 42557 (July 19, 2011) 

BART Requirements 

 

2

 Communication from David Conroy, EPA Region 1 (December 18, 2012). 
4 

Delaware identified four EGUs and one steel mill as BART-eligible sources. Delaware 

established enforceable caps for the steel mill to limit emissions below BART-eligible 

levels. Delaware also considers that in the aggregate, DE Regulation 1146 achieves 

greater reductions from its EGUs than would be achieved by applying presumptive 

BART on the BART-eligible EGUs. 

Low Sulfur Oil Strategy Inner Zone 

Delaware has not yet adopted low sulfur fuel strategy, but considers equivalent 

reductions met by including SO2 reductions from all Delaware EGUs (in excess of 90% 

reductions). 

Low Sulfur Oil Strategy Outer Zone 

Does not apply. 

90% SO2 reduction of 167 EGU stacks 

Delaware has five stacks at two power plants among the MANE-VU 167 EGU stacks list. 

Delaware indicated that the 90% reduction in SO2 from the Edge Moor Unit 5 and Indian 

River Units 1-4 was relative to a baseline of calendar year 2002 actual SO2 mass 

emissions levels from those units. Based on the actual 2002 SO2 mass emissions from 

the subject Delaware EGUs, and applying the 90% reduction factor, Delaware 

determined that the actual SO2 reduction obligation for those units was 19,909 tons/year. 

However, Delaware’s analysis indicated that it was not feasible to achieve an SO2 mass 

emissions reduction of 19,909 tons/year from Edge Moor Unit 5 and Indian River Units 

1-4 alone. Alternatively, in the 2008 Visibility SIP document Delaware indicated that 

SO2 emissions reductions from all of the EGU units affected by Delaware’s 7 DE Admin 

Code 1146, Electric Generating Unit (EGU) Multi-Pollutant Regulation, would exceed 

19,909 tons of annual SO2 reductions. Delaware indicated that the SO2 emissions 

reductions achieved by 7 DE Admin Code 1146 demonstrated that Delaware had met its 

obligation. Subsequent to the promulgation of 7 DE Admin Code 1146 (and Delaware’s 

2008 SIP submittal), units subject to the regulation have come into compliance with the 

regulation in 2009 and 2012 (phase-in), or have come into compliance with consent 

decrees and permanent, federally enforceable permit conditions related to the regulation. 

Beginning in 2011, the annual SO2 emission reductions of 21,906 tpy have exceeded the 

2018 target level of 19,909 tpy (7 years early). This is consistent with reported emissions 

in the Acid Rain Program. 

Evaluation of other control measures 

Delaware is evaluating diversity of fuels for energy needs, electricity conservation 

programs, and efficient energy infrastructure, along with encouraging new energy 

efficient product makers and promoting renewables, among other measures. 

District of Columbia3

Submittal Date of Regional Haze SIP 

 

3

 The District of Columbia contributes less than 0.1 μg/m3 or 2% sulfate at nearby Class 1 areas, so its 

long-term strategy consists of adopting the control measures in the MANE-VU “on-the-books/on-the-way” 

scenario and meeting the BART requirements. 
5 

October 27, 2011 

Haze SIP Status as of December 18, 2012 

EPA final approval, 77 FR 5191 (February 2, 2012) 

BART Requirements 

The District of Columbia has two BART-eligible sources that were to shut down by 

December 17, 2012. 

Low Sulfur Oil Strategy Inner Zone 

Does not apply. 

Low Sulfur Oil Strategy Outer Zone 

No rule proposed. 

90% SO2 reduction of 167 EGU stacks 

Does not have listed stack. 

Evaluation of other control measures 

The District of Columbia plans to continue to pursue adoption of MANE-VU measures in 

“beyond-on-the-way” (BOTW) and “best and final” scenarios by 2018, as appropriate 

and necessary. 

Maine 

Submittal Date of Regional Haze SIP 

December 9, 2010; supplemented September 14, 2011, November 9, 2011 

Haze SIP Status as of December 18, 2012 

EPA final approval, 77 FR 24385 (April 24, 2012) 

BART Requirements 

Maine identified 10 BART-eligible sources, and determined all 10 were subject to 

BART. In 2007, ME legislature adopted BART requirements and deadlines. BART 

controls must be installed and operating by January 1, 2013 and either (1) require low 

sulfur oil (1% or less) or (2) be equivalent to a unit-specific 50% reduction in sulfur 

emissions from baseline. Three BART sources capped out under permit limits. Maine 

determined that existing controls and lower sulfur oil (where applicable) satisfied BART 

for the remaining sources. 

Low Sulfur Oil Strategy Inner Zone 

Does not apply. 

Low Sulfur Oil Strategy Outer Zone 

Legislation passed. Distillate = 50 ppm in 2016; 15 ppm in 2018. #6 Fuel - 0.5% in 

2018. 
6 

90% SO2 reduction of 167 EGU stacks 

Maine has one stack on MANE-VU 167 stacks list. Maine determined it was not costeffective to add controls to the unit, and will use lower sulfur fuel to comply by 2013. 

Low sulfur fuel will get an 84% reduction. In 2011, the unit had SO2 emissions 76% 

lower than its 2002 levels, and greater than 90% lower when including additional SO2

reductions from other units at the same power plant. EPA Acid Rain Program data 

indicate that state-wide SO2 reductions in 2011 exceeded the MANE-VU Ask amount by 

48%. 

Evaluation of other control measures 

Maine has adopted rules on outdoor wood and pellet boilers, an outdoor wood boiler 

replacement and buy-back program, and a wood stove replacement buy-back program. 

Maryland 

Submittal Date of Regional Haze SIP 

February 13, 2012 

Haze SIP Status as of December 18, 2012 

EPA final approval, 77 FR 39938 (July 6, 2012). 

BART Requirements 

Maryland identified four EGUs and three non-EGUs as BART-eligible. Of the three nonEGUs, one was determined to not be a BART source based on start up date, one had 

existing and future selective non-catalytic reduction (SNCR) controls considered to 

satisfy BART, and one had additional requirements put in place to satisfy BART. For 

EGU BART-eligible sources, Maryland accepted existing controls and measures as 

satisfying BART on all units. 

Low Sulfur Oil Strategy Inner Zone 

Does not apply. 

Low Sulfur Oil Strategy Outer Zone 

No rule proposed. Maryland committed to pursuing a low sulfur fuel oil strategy as 

apporpriate and necessary. 

90% SO2 reduction of 167 EGU stacks 

Maryland has nine stacks (12 units) at six power plants listed among the MANE-VU 167 

stacks. Maryland’s approach to the 90% MANE-VU Ask from its listed stacks is to use 

the state’s Healthy Air Act (HAA) as approved in its SIP. Maryland operated from a 

total emissions baseline for the state’s EGU units identified by the MANE-VU Ask. 

Maryland arrived at the total emissions needed to satisfy the Ask by totaling the 2002 

base year emissions for the state’s units on the 167 list and multiplying by 90%. This 

number is 211,892 tpy of SO2. In 2011, Maryland achieved 208,941 tpy of reductions 

from the units in question and an additional 6,671 tpy from units regulated by the HAA 

but not included in the MANE-VU Ask. Maryland states that the Maryland HAA is 
7 

obtaining SO2 reductions in excess of the 90% MANE-VU Ask before 2018. This is 

consistent with reported emissions in the Acid Rain Program. 

Evaluation of other control measures 

Maryland committed to evaluating other measures per MANE-VU Ask. Maryland also 

cited the Maryland Strategic Energy Investment Fund as a funding source for renewables 

and energy efficiency. 

Massachusetts 

Submittal Date of Regional Haze SIP 

December 30, 2011; supplemented August 9, 2012; August 28, 2012 

Haze SIP Status as of December 18, 2012 

EPA final approval signed in September 2012; FR notice pending.4

BART Requirements 

Massachusetts identifed nine power plants and eight non-EGUs as BART-eligible, and 

subsequently subject to BART. Seven BART sources were determined to have de 

minimis impacts and did not justify controls. Massachusetts adopted an Alternative to 

BART program achieving greater emissions reductions than source-by-source BART for 

EGUs (permit restriction, cap, retirement, low sulfur fuel). Massachusetts determined 

additional SO2 control for one non-EGU BART source was not cost-effective and would 

have minimal impact on visibility. Volatile organic compounds (VOCs) from three 

petroleum storage facilities were addressed under Massachusetts’ ozone SIPs rather than 

BART. 

Low Sulfur Oil Strategy Inner Zone 

Does not apply. 

Low Sulfur Oil Strategy Outer Zone 

Massachusetts adopted rules for 15 ppm sulfur #2 oil, and 0.5% sulfur by weight for #4 

and #6 residual oils by 2018. 

90% SO2 reduction of 167 EGU stacks 

Massachusetts has 10 stacks at five power plants on the MANE-VU 167 stacks list. 

Massachusetts estimates that based on its Alternative to BART, EPA’s Mercury and Air 

Toxics Standards (MATS), and EGU closures, 2018 EGU SO2 emissions will be 87% 

lower than 2002 emissions. In 2011, seven stacks had SO2 emissions more than 90% 

lower than 2002 levels when including plant-wide emission reductions at the stacks. The 

remaining three stacks were 50-80% lower in 2011. EPA Acid Rain Program data 

indicate that state-wide SO2 reductions in 2011 were 94% of the MANE-VU Ask amount. 

Evaluation of other control measures 

 

4

 Communication from David Conroy, EPA Region 1 (December 18, 2012). 
8 

Massachusetts is implementing controls on outdoor wood-fired boilers. Massachusetts 

will pursue other reasonable and cost-effective measures as needed. 

New Hampshire 

Submittal Date of Regional Haze SIP 

January 29, 2010; supplemented January 14, 2011; August 26, 2011 

Haze SIP Status as of December 18, 2012 

EPA final approval, 77 FR 50602 (August 22, 2012) 

BART Requirements 

New Hampshire has two BART-eligible sources: Merrimack Unit 2 and Newington Unit 

1, and both are included in the MANE-VU 167 stacks list. Control measures for these 

sources are described below in the 167 EGU stacks section. New Hampshire adopted 

BART in New Hampshire rule Env-A 2300: Mitigation of Regional Haze; effective date 

January 8, 2011. 

Low Sulfur Oil Strategy Inner Zone 

Does not apply. 

Low Sulfur Oil Strategy Outer Zone 

New Hampshire made commitment to continue evaluating strategy. No rule proposed. 

90% SO2 reduction of 167 EGU stacks 

New Hampshire has three stacks at two power plants listed among the MANE-VU 167 

stacks. 

Merrimack Unit 1: No specific SO2 limit given in haze SIP. Page 118 of the New 

Hampshire regional haze SIP indicates Merrimack Unit 1 required by rule to reduce 

mercury by 80% with flue gas desulfurization (FGD) that has an expected 90% minimum 

co-benefit in SO2 reduction. 2011 SO2 emissions were 17% below 2002 levels. 

Merrimack Unit 2: Requires FGD operated at maximum sustainable reduction rate, but 

not less than 90% calendar month average, to be accomplished by July 1, 2013. 2011 

SO2 emissions were 32% below 2002 levels. 

New Hampshire expects that controls at the Merrimack units will exceed the 90% 

MANE-VU Ask request. 

Newington Unit 1: Requires an SO2 limit of 0.50 lb/MMBtu by July 1, 2013; 2002 rate 

was 1.08 lb/MMBtu. 2011 SO2 emissions were 94% below 2002 levels, in part due to 

lower utilization. New Hampshire determined that an enforceable 90% MANE-VU Ask 

reduction at this unit was not reasonable at this time. 

EPA Acid Rain Program data indicate that state-wide SO2 reductions in 2011 were 60% 

of the MANE-VU Ask amount. 
9 

Evaluation of other control measures 

New Hampshire is seeking alternative measures for Newington Unit 1, including >90% 

SO2 reduction at Merrimack Station, possible additional controls on other coal-burning 

units, and use of low sulfur fuel oil (p. 27 and Long Term Strategy, NH haze SIP). 

New Jersey 

Submittal Date of Regional Haze SIP 

July 28, 2009; supplemented December 9, 2010; March 2, 2011; December 7, 2011 

Haze SIP Status as of December 18, 2012 

EPA final approval, 77 FR 19 (January 3, 2012) 

BART Requirements 

New Jersey identified four refineries and one EGU (Hudson) as BART-eligible and 

subject to BART. New Jersey believes that the state’s adopted rules in its 8-hour ozone 

and PM2.5 SIPs along with consent decrees to address NOx, SO2, and particulate matter 

(PM) at these sources will likely address BART.5 New Jersey did not rely on CAIR for 

the Hudson EGU (also a 167 EGU stack). 

Low Sulfur Oil Strategy Inner Zone 

The New Jersey regional haze SIP stated an intent to propose and adopt low sulfur rules 

in accordance with the MANE-VU Ask. Current rule N.J.A.C. 7:27-9 already meets #6 

fuel oil sulfur levels in parts of state. New Jersey proposed a low sulfur fuel oil rule on 

April 4, 2011. The rule now is in effect and will meet MANE-VU Ask sulfur levels by 

July 1, 2016. 

Low Sulfur Oil Strategy Outer Zone 

Does not apply. 

90% SO2 reduction of 167 EGU stacks 

New Jersey has four stacks among the MANE-VU 167 stacks list. New Jersey indicates 

that existing orders on all four will result in more than a 90% SO2 reduction by December 

15, 2012. All four New Jersey stacks had 2011 SO2 emissions more than 90% below 

2002 levels. This is consistent with reported emissions in the Acid Rain Program. 

Evaluation of other control measures 

New Jersey cites draft Energy Master Planning as including ways to increase energy 

efficiency. It also cites the state’s Global Warming Response Act signed in 2007 that 

will decrease greenhouse gases, which will help reduce haze pollutants. New Jersey lists 

a number of other measures under consideration that would address fugitive dust, open 

burning, residential wood burning, VOCs, and diesel exhaust. 

New York 

 

5

 One refinery (Hess Port Reading) has since announced plans to shut down by the end of February 2013.
10 

Submittal Date of Regional Haze SIP 

March 15, 2010; supplemented August 2, 2010; April 16, 2012; July 2, 2012 

Haze SIP Status as of December 18, 2012 

EPA partial approval 17 BART sources/partial disapproval 2 BART sources, 77 FR 

51915 (August 28, 2012) 

BART Requirements 

New York required source-specific analysis of all BART-eligible sources. BARTeligible EGUs under CAIR were not exempted from BART analysis. EPA approved 17 

source-specific SIP revisions for New York’s BART sources, and issued FIPs for 2 

additional BART sources. 

Low Sulfur Oil Strategy Inner Zone 

New York committed to adopting low sulfur fuel oil rules under 6 NYCRR Part 225, and 

adopted the rules subsequent to the state’s regional haze SIP submittal. A 15 ppm 

heating oil requirement became effective in 2012. The remaining distillates’ effective 

date is in 2014. 

Low Sulfur Oil Strategy Outer Zone 

Does not apply. 

90% SO2 reduction of 167 EGU stacks 

New York has 11 stacks listed among the MANE-VU 167 stacks list. With the exception 

of the Oswego unit, all listed New York stacks were expected to either shut down or be 

controlled in range of 80-95% for SO2. In the aggregate, accounting for shutdowns, 

controls, and new EGUs, New York expects to achieve the 90% MANE-VU Ask. 2011 

SO2 emissions at most of the state’s listed stacks were at or approaching levels more than 

90% below 2002 emissions at the individual stack, or were greater than 90% below when 

including SO2 reductions/shutdowns at other units at the same facility. EPA Acid Rain 

Program data indicate that state-wide SO2 reductions in 2011 exceeded the MANE-VU 

Ask amount by 27%. 

Evaluation of other control measures 

New York was to continue evaluating energy efficiency, alternative clean fuels, and other 

measures to reduce NOx and SO2 at all coal-burning facilities, and new source 

performance standards for wood combustion. New York was also pursuing VOC 

measures under its ozone SIPs. 

Pennsylvania 

Submittal Date of Regional Haze SIP 

December 20, 2010 

Haze SIP Status as of December 18, 2012 

EPA limited approval, 77 FR 41279 (July 13, 2012); EPA limited disapproval with FIP to 

replace CAIR with CSAPR, 77 FR 33642 (June 7, 2012)
11 

BART Requirements 

Pennsylvania accepted CAIR as BART for EGU NOx and SO2. Pennsylvania made 

BART determinations for EGU particulate matter (PM) and all non-EGU BART-eligible 

sources that did not elect to be not BART-eligible through permit limitations. 

Pennsylvania determined that existing controls at all BART-eligible sources met BART 

requirements. 

Low Sulfur Oil Strategy Inner Zone 

Pennsylvania committed to a low sulfur fuel strategy not less stringent than the outer 

zone MANE-VU Ask, based on supply concerns. It proposed a rule in September 2010, 

with a full effective date by 2016. 

Low Sulfur Oil Strategy Outer Zone 

Does not apply. 

90% SO2 reduction of 167 EGU stacks 

Pennsylvania has 15 stacks among the MANE-VU 167 stacks. In 2011, SO2 emissions at 

2 of the 15 stacks were more than 90% below 2002 levels. The remaining 13 stacks all 

had lower 2011 SO2 emissions than in 2002 at levels less than a 90% reduction. EPA 

Acid Rain Program data indicate that state-wide SO2 reductions in 2011 equaled the 

MANE-VU Ask amount. 

Evaluation of other control measures 

Pennsylvania lists a number of measures being undertaken in on-going programs that can 

address haze, including refinery consent decrees, rulemakings on cement kilns and glass 

furnaces, and state energy initiatives to address peak demand days, and promote 

renewables, energy efficiency, and energy conservation. 

Rhode Island 

Submittal Date of Regional Haze SIP 

August 7, 2009 

Haze SIP Status as of December 18, 2012 

EPA final approval, 77 FR 30214 (May 22, 2012) 

BART Requirements 

Does not have BART-eligible sources. 

Low Sulfur Oil Strategy Inner Zone 

Does not apply. 

Low Sulfur Oil Strategy Outer Zone 

Rhode Island made a SIP commitment to adopt a low sulfur rule consistent with the 

MANE-VU Ask for the outer zone. A rule has not yet been proposed as of December 18, 

2012. 
12 

90% SO2 reduction of 167 EGU stacks 

Does not have listed stack. 

Evaluation of other control measures 

Rhode Island stated an intent to adopt all reasonable control measures as expeditiously as 

practicable consistent with state law within 10 year planning period. It cited a possible 

state law to address outdoor wood boilers. 

Vermont 

Submittal Date of Regional Haze SIP 

August 26, 2009; supplemented January 3, 2012 

Haze SIP Status as of December 18, 2012 

EPA final approval, 77 FR 30212 (May 22, 2012) 

BART Requirements 

Does not have BART-eligible sources. 

Low Sulfur Oil Strategy Inner Zone 

Does not apply. 

Low Sulfur Oil Strategy Outer Zone 

Vermont adopted low sulfur fuel oil requirements in the “Vermont Energy Act of 2011.” 

Full implementation wil be by July 1, 2018. 

90% SO2 reduction of 167 EGU stacks 

Does not have listed stack. 

Evaluation of other control measures 

Vermont stated an intent to continue investigating cleaner sources of energy. 
13 

2. OUTSIDE MANE-VU REGION

For states outside the MANE-VU region, the “MANE-VU Ask” requested: 

• Timely implementation of BART requirements; 

• A 90% or greater reduction in sulfur dioxide (SO2) emissions from each of the top 

100 electric generating units (comprising a total of 167 stacks) impacting any 

mandatory Class 1 Federal area in the MANE-VU region, or an equivalent SO2

reduction from alternative measures within each State; 

• The application of reasonable controls on non-EGU sources resulting in a 28% 

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; 

• Continued evaluation of other measures including measures to reduce SO2 and 

nitrogen oxide (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 through consultation 

processes to determine if they are reasonable. 

Georgia6

Submittal Date of Regional Haze SIP 

February 11, 2010; supplemented September 19, 2010 

Haze SIP Status as of December 18, 2012 

EPA limited approval, 77 FR 38501 (June 28, 2012); EPA limited disapproval with FIP 

to replace CAIR with CSAPR, 77 FR 33642 (June 7, 2012) 

BART Requirements 

Georgia accepted CAIR as BART for EGU NOx and SO2. Georgia identified 24 BARTeligible sources, which included EGUs for PM only, and accepted exemption 

 

6

 When contacted by MANE-VU states before the release of the “MANE-VU Ask” letters, The Georgia 

Environmental Protection Division (Georgia EPD) had the following response to those states: 

Georgia EPD is a member of the VISTAS Regional Planning Organization. Based on VISTAS 

SO2 emissions sensitivity modeling for 2009 and VISTAS SO2 Area of Influence (AOI) work for 

2018, we have concluded that Georgia does not reasonably contribute to visibility impairment at 

[MANE-VU] Class I Area[s]. Furthermore, it should be noted that Georgia EPD is currently in 

the process of requiring 95% SO2 controls to be installed on the seven largest coal fired power 

plants in Georgia. Not all of these controls were accounted for in the SO2 emissions sensitivity 

modeling or the SO2 AOI work; therefore, Georgia’s contributions to [MANE-VU] Class I areas 

in these analyses will be a conservative upper bound leading to our conclusion that Georgia EGU 

and non-EGU SO2 sources do not reasonably contribute to visibility impairment at [MANE-VU 

Class I Areas]. 
14 

demonstrations from 22 of the 24 BART-eligible sources based on a 0.5 dv contribution 

threshold. A paper facility was required to use natural gas in one boiler. All other 

available BART control options were deemed not cost effective. The second BART 

facility was an EGU (Bowen), and no available BART control options for PM were 

deemed cost effective. 

90% SO2 reduction of 167 EGU stacks 

Georgia has five stacks at two power plants listed in the MANE-VU Ask. Four of the 

stacks carry emissions from Bowen Units 1 through 4. The fifth stack carries the 

combined emissions from Harllee Branch Units 3 and 4. Georgia Rule 391-3-1-

.02(2)(uuu) requires 95% removal of SO2 from Bowen Units 1- 4 no later than January 1, 

2012, and from Harllee Branch Units 1 – 4 no later than January 1, 2016.7 Since the 

filing of the Georgia haze SIP, Georgia Power Company has filed requests to 

decommission Harllee Branch Units 1 and 2 in 2013 and Units 3 and 4 in 2015. In 2011, 

SO2 emissions from the four units at Bowen were greater than 90% below 2002 

emissions, with 2011 emissions at the Harllee Branch units about 25% below 2002 levels. 

EPA Acid Rain Program data indicate that state-wide SO2 reductions in 2011 exceeded 

the MANE-VU Ask amount by 73%. 

28% SO2 reduction in non-EGU emissions 

Georgia required lower SO2 permit limits for eight emissions units at five non-EGU 

facilities based on four-factor analysis. Georgia also required lower SO2 permit 

emissions rates for two emissions units at one non-EGU facility for the purpose of BART 

exemption. Overall, 8,223 tons of SO2 reductions are required between 2012 and 2018, 

which is approximately 15% of 2002 non-EGU facility SO2 emissions.7

Evaluation of other control measures 

No additional measures listed for further evaluation. 

Illinois 

Submittal Date of Regional Haze SIP 

June 24, 2011 

Haze SIP Status as of December 18, 2012 

EPA final approval, 77 FR 39943 (July 6, 2012) 

BART Requirements 

Ilinois identified nine EGUs and two refineries as subject to BART. Illinois did not rely 

on CAIR for BART, and applied standards more stringent than CAIR to affected EGUs. 

Illinois considers federal consent decrees for the two refineries as BART for NOx and 

SO2. 

90% SO2 reduction of 167 EGU stacks 

 

7

 Communication from Georgia EPD – Air Protection Branch (March 5, 2013). 
15 

Illinois has one stack listed among the MANE-VU 167 stacks. The identified stack at 

Ameren-Coffeen has selective catalytic reduction (SCR) that will operate year-round, and 

a wet scrubber to comply with Illinois’ multi-pollutant standards. Illinois states that the 

level of control required on the power plant will satisfy the MANE-VU Ask. In 2011, 

SO2 emissions at the Ameren-Coffeen stack were more than 90% less than 2002 levels. 

EPA Acid Rain Program data indicate that state-wide SO2 reductions in 2011 exceeded 

the MANE-VU Ask amount by 267%. 

28% SO2 reduction in non-EGU emissions 

Illinois expects on-the-books federal and state control measures will achieve sufficient 

reductions to satisfy MANE-VU Ask. Reductions not quantified. 

Evaluation of other control measures 

No additional measures listed for further evaluation. 

Indiana 

Submittal Date of Regional Haze SIP 

January 14, 2011; March 10, 2011 

Haze SIP Status as of December 18, 2012 

EPA limited approval, 77 FR 34218 (June 11, 2012); EPA limited disapproval with FIP 

to replace CAIR with CSAPR, 77 FR 33642 (June 7, 2012) 

BART Requirements 

Indiana identified 32 BART-eligible sources, which included EGUs. Initial analysis 

determined four non-EGU facilities and nine power plants were subject to BART. Of the 

four non-EGU BART sources, Indiana determined three were exempt based on additional 

modeling, and required BART measures on the fourth. For the power plants, Indiana 

accepted CAIR as BART for NOx and SO2, and determined one EGU remained subject 

to BART for PM only (Alcoa Boiler 4). Indiana adopted a BART rule in 2010 for the 

EGU with a PM emission rate of 0.1 lb/MMBtu using an ESP. 

90% SO2 reduction of 167 EGU stacks 

Indiana has 15 stacks at 9 power plants listed in the MANE-VU Ask; most of these stacks 

have or will have post-combustion emission controls (i.e., scrubbers). In 2011, 9 of the 

15 listed stacks had SO2 emissions more than 90% below 2002 levels. Another three 

stacks had decreases less than 90% relative to 2002. 2011 emissions at Clifty Creek (two 

stacks) increased, with about a doubling over 2002 emissions. The Rockport stack was 

about 7% higher in 2011 over 2002. EPA Acid Rain Program data indicate that statewide SO2 reductions in 2011 were 86% of the MANE-VU Ask amount. 

28% SO2 reduction in non-EGU emissions 

No additional measures identified. Indiana noted other existing federal requirements 

(e.g., low sulfur diesel) would result in additional reductions. 

Evaluation of other control measures 
16 

No additional measures listed for further evaluation. 

Kentucky 

Submittal Date of Regional Haze SIP 

June 25, 2008; revised May 28, 2010 

Haze SIP Status as of December 18, 2012 

EPA limited approval, 77 FR 19098 (March 30, 2012); EPA limited disapproval with FIP 

to replace CAIR with CSAPR, 77 FR 33642 (June 7, 2012) 

BART Requirements 

Kentucky accepted CAIR as BART for EGU NOx and SO2. Kentucky identified 26 

BART-eligible sources of which 21 were exempted based on further analysis of impacts. 

BART analysis of five EGUs as subject to BART for PM provided for installing controls 

for visibility improvements. 

90% SO2 reduction of 167 EGU stacks 

Kentucky has 10 stacks at 8 power plants on the MANE-VU 167 stacks list, comprising 

14 units. Kentucky indicates that 13 of the 14 units (93%) have or will have SO2 controls 

in 2015, including a unit which may instead opt to retire. The one remaining unit has 

plans to retire or to convert to natural gas by the federal Utility Mercury and Air Toxics 

Standards (MATS) deadline.8 Kentucky believes that these controls more than 

adequately address MANE-VU’s request. Of the ten stacks on the MANE-VU list, five 

had 2011 emissions more than 90% below 2002 levels at the plant level. Two other 

stacks had 2011 emissions more than 80% below 2002 levels, and one stack was 5% 

below 2002 levels. The remaining two stacks had 2011 emissions 1% and 49% higher 

than in 2002, of which respectively, one announced plans to retire, convert to natural gas, 

or install scrubbers, and the other has announced plans to replace the existing scrubber by 

the federal MATS deadline. This source also has plans to upgrade (replace or modify) 

two other existing scrubbers for the source’s three non-167 Ask units.8

 EPA Acid Rain 

Program data indicate that state-wide SO2 reductions in 2011 exceeded the MANE-VU 

Ask amount by 2%. 

28% SO2 reduction in non-EGU emissions 

Kentucky believes that the significant existing and expected EGU emission controls more 

than adequately address MANE-VU’s non-EGU emission control requests. 

Evaluation of other control measures 

Open burning regulation referenced, but not included in modeling. 

Michigan 

Submittal Date of Regional Haze SIP 

November 5, 2010 

 

8

 Communication from the Kentucky Division for Air Quality (March 8, 2013). 
17 

Haze SIP Status as of December 18, 2012 

EPA partial approval with FIP for two BART sources, 77 FR 71533 (December 3, 2012); 

EPA limited disapproval with FIP to replace CAIR with CSAPR, 77 FR 33642 (June 7, 

2012) 

BART Requirements 

Michigan stated that CAIR addresses BART for EGUs. Michigan identified 35 nonEGUs as BART-eligible, and reduced the number of BART-eligible sources to six based 

on emissions and distance from Class 1 areas. Of the remaining six, one shut down and 

Michigan accepted mostly existing measures along with a few additional requirements as 

BART for the remaining sources. EPA determined Michigan failed to address two 

BART sources and issued a FIP. 

90% SO2 reduction of 167 EGU stacks 

Michigan has five stacks at four facilities among the MANE-VU 167 list. Of the five 

listed stacks in Michigan, two had 2011 SO2 emissions more than 90% below 2002 

levels, and the remaining three had SO2 emissions 2%-20% below 2002 levels. EPA 

Acid Rain Program data indicate that state-wide SO2 reductions in 2011 exceeded the 

MANE-VU Ask amount by 3%. 

28% SO2 reduction in non-EGU emissions 

Michigan did not include additional measures beyond “on the books” requirements. 

Michigan listed potential reductions from its Renewable Energy Portfolio requirements, 

Mercury/multi-pollutants rules, PM2.5 and ozone SIPs, and greenhouse gas programs. 

Reductions were not quantified. 

Evaluation of other control measures 

No additional measures listed for further evaluation. 

North Carolina 

Submittal Date of Regional Haze SIP 

December 17, 2007 

Haze SIP Status as of December 18, 2012 

EPA limited approval, 77 FR 38185 (June 27, 2012); EPA limited disapproval with 

additional time given to revise SIP for CAIR deficiency, 77 FR 33642 (June 7, 2012) 

BART Requirements 

North Carolina accepted CAIR as BART for EGU NOx and SO2 in addition to EGU 

requirements under the North Carolina Clean Smokestacks Act. North Carolina 

identified 17 BART-eligible sources. Of those, 15 were exempted based on further 

analysis. North Carolina determined that no additional controls were required at the 

BART-subject facilities. 

90% SO2 reduction of 167 EGU stacks 
18 

North Carolina has 12 stacks at 7 power plants in the MANE-VU 167 stacks list. Under 

the North Carolina Clean Smokestacks Act, 11 of those EGUs were controlled. 

Additionally, scrubbers are expected on 3 EGUs not identified by MANE-VU. North 

Carolina believes that these reductions satisfy the MANE-VU Ask. In 2011, 9 of the 12 

EGUs had SO2 emissions more than 90% lower than in 2002, and a 10th EGU retired in 

2012. The remaining 2 EGUs had 2011 emissions 54% and 74% lower in 2011 than 

2002 on a facility-wide basis. EPA Acid Rain Program data indicate that state-wide SO2

reductions in 2011 exceeded the MANE-VU Ask amount by 34%. 

28% SO2 reduction in non-EGU emissions 

North Carolina indicated it believed that under the North Carolina Clean Smokestacks 

Act, additional reductions from EGUs not on the 167 list would satisfy the MANE-VU 

Ask. No additional non-EGU measures beyond existing and previously planned 

requirements were noted. 

Evaluation of other control measures 

Dust, methane, and ammonia controls from some non-EGU sector sources. 

Ohio 

Submittal Date of Regional Haze SIP 

March 11, 2011 

Haze SIP Status as of December 18, 2012 

EPA limited approval, 77 FR 39177 (July 2, 2012); EPA limited disapproval with FIP to 

replace CAIR with CSAPR, 77 FR 33642 (June 7, 2012)

BART Requirements 

Ohio identified 18 generating stations with 37 units as BART-eligible, and accepted 

CAIR as BART for NOx and SO2. Ohio also determined that PM emissions from all 

BART-eligible EGUs did not contribute to visibility impairment above the 0.5 dv level at 

any Class 1 area, thus would not be subject to BART. Ohio identified 12 non-EGUs as 

BART-eligible. Ohio determined with additional modeling that it had one non-EGU 

source subject to BART. The source will implement an energy efficiency program as an 

alternative to BART that includes additional SO2 controls or shut-downs. 

90% SO2 reduction of 167 EGU stacks 

Ohio has 28 stacks at 15 power plants among the MANE-VU 167 EGU stacks list. Ohio 

listed a number of planned controls since 2002 in the context of the MANE-VU Ask. In 

2011, 16 of the 28 EGU stacks had SO2 emissions more than 90% below 2002 levels on a 

facility-wide basis. An additional seven EGU stacks indicated plans to install controls, 

convert to natural gas, or shut down prior to 2018. Another three EGU stacks had 2011 

SO2 emissions between approximately10-60% below 2002 levels. The remaining two 

EGU stacks increased emissions in 2011 relative to 2002, with one stack (Kyger Creek) 

doubling emissions, while planning to install scrubbers by mid-2012. EPA Acid Rain 

Program data indicate that state-wide SO2 reductions in 2011 were 61% of the MANEVU Ask amount. 
19 

28% SO2 reduction in non-EGU emissions 

No additional non-EGU measures listed. Ohio believes on-the-books measures are 

currently sufficient to meet reasonable progress in MANE-VU. 

Evaluation of other control measures 

In response to MANE-VU Ask, Ohio believes on-the-books measures are currently 

sufficient to meet reasonable progress goals, and its emission sources have relatively 

insignificant impacts on MANE-VU Class 1 areas. No additional measures listed for 

further evaluation. 

South Carolina9

Submittal Date of Regional Haze SIP 

December 17, 2007 

Haze SIP Status as of December 18, 2012 

EPA limited approval, 77 FR 38509 (June 28, 2012); EPA limited disapproval with FIP 

to replace CAIR with CSAPR, 77 FR 33642 (June 7, 2012) 

BART Requirements 

South Carolina accepted CAIR as BART for EGU NOx and SO2. South Carolina 

identified 21 BART-eligible sources, including six EGUs for PM only. Of these 21 

sources, 19 demonstrated exemptions to BART, including 4 of the 6 EGUs (for PM 

only). South Carolina determined no additional controls were needed on the remaining 

subject-to-BART sources. 

90% SO2 reduction of 167 EGU stacks 

South Carolina has six stacks at four power plants listed in the MANE-VU 167 stacks 

list. In 2011, four stacks had SO2 emissions that were approximately 90% below 2002 

levels. The remaining two stacks were more than 70% below 2002 levels, with 

announced plans to retire at a date yet to be determined. EPA Acid Rain Program data 

indicate that state-wide SO2 reductions in 2011 exceeded the MANE-VU Ask amount by 

43%. 

28% SO2 reduction in non-EGU emissions 

None listed. 

Evaluation of other control measures 

No additional measures listed for further evaluation. 

Tennessee 

Submittal Date of Regional Haze SIP 

 

9

 In its response to consultation requests from New Jersey and New Hampshire, South Carolina indicated it 

did not believe the state’s emissions reasonably contributed to visibility impairment at Class 1 areas in the 

MANE-VU region. 
20 

April 4, 2008; revised May 14, 2012 

Haze SIP Status as of December 18, 2012 

EPA limited approval with no action on Eastman BART, 77 FR (April 24, 2012); EPA 

approval Eastman BART, 77 FR 70689 (November 27, 2012); EPA limited disapproval 

with FIP to replace CAIR with CSAPR, 77 FR 33642 (June 7, 2012) 

BART Requirements 

Tennessee accepted CAIR as BART for EGU NOx and SO2. Tennessee identified twelve 

operating BART-eligible sources, including two EGUs (for PM only), with eight 

subsequently exempted based on demonstrations that they did not cause or contribute to 

visibility impairment at any Class 1 area, including one of the two EGUs (Bull Run). The 

four subject-to-BART sources had additional BART limitations put into permits, with no 

additional controls required at the remaining EGU (Cumberland). 

90% SO2 reduction of 167 EGU stacks 

Tennessee has five stacks at four power plants on the MANE-VU 167 list. The 

Tennessee Valley Authority (TVA) controlled or expects to control Kingston 1 & 2 and 

John Sevier. TVA plans to control Gallatin if needed to meet its CAIR obligations or to 

achieve possible more stringent proposed national ambient air quality standards, and 

repower or shut down Johnsonville by the next review period in 2018. In 2011, SO2

emissions at one stack (Sevier) were more than 90% lower than in 2002 when including 

plant-wide reductions. The other four stacks had SO2 emissions lower than in 2002 in the 

range of 40-70%. EPA Acid Rain Program data indicate that state-wide SO2 reductions 

in 2011 exceeded the MANE-VU Ask amount by 6%. 

28% SO2 reduction in non-EGU emissions 

Tennessee does not believe MANE-VU’s request is justified for the state’s emissions. 

Tennessee believes that MANE-VU’s 2018 modeling in its technical support document 

for the August 2007 meeting did not prove that the state’s non-EGU emissions were 

adversely impacting any of the Class 1 areas in the MANE-VU region. 

Evaluation of other control measures 

MANE-VU did not identify TVA Bull Run as part of 167 stacks, which is getting 

scrubbers and is located closer to Great Smoky Mountains than Johnsonville and 

Gallatin. 

Virginia 

Submittal Date of Regional Haze SIP 

Main plan and narrative: October 4, 2010. Permits: June 17, 2008; March 6, 2009; 

January 14, 2010. Revisions: November 19, 2010; May 6, 2011; December 21, 2012 

Haze SIP Status as of December 18, 2012 

EPA limited approval, 77 FR 35287 (June 13, 2012); EPA limited disapproval with FIP 

to replace CAIR with CSAPR, 77 FR 33642 (June 7, 2012) 
21 

BART Requirements 

Virginia accepted CAIR as BART for EGU NOx and SO2. Virginia has four EGU units 

that are BART eligible for PM: Units 5 and 6 at Chesterfield Power Station (ORIS 3797), 

Unit 5 at Possum Point Power Station (ORIS 3804), and Unit 3 at Yorktown Power 

Station (ORIS 3809). Units 5 and 6 at Chesterfield are coal-fired boilers. Both are 

controlled by SCR, wet FGD, and ESPs. Unit 6 is also controlled by a polishing 

baghouse. Unit 3 at Yorktown and Unit 5 at Possum Point are residual oil-fired units. 

Economic models such as IPM predicted the retirement of residual oil fired units; 

however, the most recent Integrated Resource Plan filed by Dominion did not suggest 

that these units will be retired. These residual oil-fired units are infrequently utilized.10

Virginia identified 13 facilities having a total of 72 BART-eligible units. Ten facilities 

with BART-eligible units were exempted from BART based on modeling. The three 

remaining subject-to-BART sources were O-N Minerals (Chemstone)-Strasburg, Georgia 

Pacific-Big Island, and Meadwestvaco-Covington. 

The units at O-N Minerals (Chemstone)-Strasburg that are subject to BART are the rotary 

kiln (U5) and the calcimatic kiln (U12). The calcimatic kiln was permanently retired. 

The rotary kiln was retrofitted with an SO2 CEMs for continuous monitoring of exhaust 

gases as part of the BART requirements. Beginning in 2010, the kiln was required to 

meet an SO2 limitation of 0.29 lbs/ton stone feed. 

The units subject to BART at Georgia Pacific-Big Island are two coal-fired boilers, #4 

and #5. Boiler #4 was permanently retired. For BART, Boiler #5 was required to retrofit 

with FGD. 

Units at Meadwestvaco-Covington that are subject to BART are Boiler #9, a coal-fired 

unit; Boiler #10, a predominantly natural gas-fired unit; Recovery Furnace #1; and Smelt 

Dissolving Tank #1. Emissions are predominantly from Boiler #9. This unit’s BART 

determination required the upgrade of the existing FGD system for increased removal 

efficiency. 

90% SO2 reduction of 167 EGU stacks 

Virginia has eight stacks at four power plants listed among the MANE-VU 167 stacks. 

Virginia estimates that based on federal consent decrees, knowledge of owner control 

program estimates, and IPM projections, these units will reduce SO2 emissions 

approximately 82% by 2018 from 2002 levels. In 2011, five listed stacks had SO2

emissions approximately 90% below 2002 levels. The other three stacks had 40%-60% 

lower emissions, and two of these three had announced plans to retire or convert to 

natural gas prior to 2018. EPA Acid Rain Program data indicate that state-wide SO2

reductions in 2011 exceeded the MANE-VU Ask amount by 28%. 

28% SO2 reduction in non-EGU emissions 

 

10 Communication from VA DEQ, February 4, 2013. 
22 

Virginia notes that enforceable SO2 reductions at two EGUs not on the MANE-VU Ask 

167 list and additional reductions at one non-EGU industrial source would meet the 

MANE-VU Ask request by 2018. 

Evaluation of other control measures 

Included in the Virginia Regional Haze SIP was a commitment to finalize a reasonable 

progress review focusing on SO2 emissions for Meadwestvaco Covington’s Stack 25, the 

main power house boiler stack. This stack had calculated visibility impacts, as described 

in the Virginia Regional Haze SIP, on multiple Class 1 areas. The reasonable progress 

determination was submitted to EPA as a SIP revision on May 6, 2011. The units 

exhausting to Stack #25 are Boilers 6, 7, 8, and 9. Boilers 6 and 9 are predominantly coal 

fired units. Boilers 7 and 8 may burn coal as well as biomass and are generally fired on 

biomass. The reasonable progress determination resulted in the permitted limit of the 

stack being reduced from just over 8,000 tpy of SO2 to approximately 6,800 tpy of SO2 , 

representing a decrease of more than 1,200 tons of SO2 annually. 

West Virginia 

Submittal Date of Regional Haze SIP 

June 18, 2008 

Haze SIP Status as of December 18, 2012 

EPA limited approval, 77 FR 16937 (March 23, 2012); EPA limited disapproval with FIP 

to replace CAIR with CSAPR, 77 FR 33642 (June 7, 2012) 

BART Requirements 

West Virginia identified 22 BART-eligible sources, including 7 EGUs, with 19 able to 

demonstrate exemptions. West Virginia accepted CAIR as BART for EGU NOx and 

SO2, with all BART-eligible EGUs installing scrubbers and NOx controls. For PM, only 

one of the seven EGUs demonstrated it significantly contributed to visibility impairment 

at a Class 1 area. The subject to BART sources have or will shut down, or had an 

emission rate lowered using existing controls. 

90% SO2 reduction of 167 EGU stacks 

West Virginia has 14 stacks at 10 power plants in the MANE-VU 167 stack list, and 

expects all stacks to have at least 90% control efficiency by 2018. In 2011, nine stacks 

had SO2 emissions more than 90% below 2002 levels. The remaining five stacks had 

2011 SO2 emissions 35%-70% below 2002 levels, with three of the five stacks 

announcing plans to retire prior to 2018.11 EPA Acid Rain Program data indicate that 

state-wide SO2 reductions in 2011 were 99% of the MANE-VU Ask amount. 

28% SO2 reduction in non-EGU emissions 

 

11 The two stacks at Pleasants are equipped with wet scrubbers with an SO2 removal efficiency of greater 

than 90%. In 2007, Pleasants replaced its stacks, eliminating the 15% bypass that had been used for stack 

gas reheat, and is now scrubbing 100% of the flue gas. The elimination of the bypass allowed for the 70% 

reduction in emissions from 2002 levels (communication from WV DEP, January 10, 2013) 
23 

West Virginia believes that additional SO2 controls and unit shutdowns at EGUs not 

among the MANE-VU 167 stacks list satisfy the MANE-VU Ask. No additional nonEGU measures were noted. 

Evaluation of other control measures 

No additional measures listed for further evaluation. 

Wisconsin12

Submittal Date of Regional Haze SIP 

January 18, 2012; supplemented June 7, 2012 

Haze SIP Status as of 12/18/12 

EPA final approval, 77 FR 46952 (August 7, 2012) 

BART Requirements 

Wisconsin identified four non-EGUs as BART-eligible, and one of the four subsequently 

determined as subject to BART. Wisconsin drafted an admistrative order for the BART 

source to cap NOx and SO2 emissions from several boilers. Wisconsin accepted 

CAIR/CSAPR as BART for EGU NOx and SO2, and determined existing controls and 

permit limits satisfied BART for EGU PM. 

90% SO2 reduction of 167 EGU stacks 

Does not have listed stack. 

28% SO2 reduction in non-EGU emissions 

None listed. 

Evaluation of other control measures 

Wisconsin plans to evaluate potential measures on agricultural ammonia sources post2018. Wisconsin will also continue to evaluate potential additional reductions from ICI 

boilers, reciprocating internal combustion engines and turbines, and mobile sources, as 

needed to meet reasonable progress goals. 

 

 

12 Wisconsin does not have a listed 167 EGU stack, but Vermont listed it among the states identified as 

having at least a 2% modeled sulfate impact at a MANE-VU Class 1 area, and as a state to be invited to the 

MANE-VU consultation process (letter from Justin Johnson, VT DEC, July 17, 2007; in MANE-VU InterRPO Consultation Briefing Book, 2007, at pp. 16-18). The Wisconsin haze SIP does not indicate it 

received a MANE-VU Ask. 
24 

3. U.S. EPA 

For additional national measures, the federal “MANE-VU Ask” requested “that EPA 

work with the eastern Regional Planning Organizations to develop a proposal for 

tightening the CAIR program to achieve an additional 18% reduction in SO2 [from power 

plants13] by no later than 2018.” 

While EPA has not developed a new proposal with the RPOs in response to the MANEVU Ask, it has sought to implement two new rules since CAIR requiring greater SO2

reductions from power plants by 2018. The projected reductions from these rules can be 

placed in the context of the reduction request in the MANE-VU Ask to EPA. 

The first rule was the Cross-State Air Pollution Rule (CSAPR), also known as the 

Transport Rule, which was finalized in August 2011, then subsequently vacated by the 

D.C. Circuit in August 2012. Although no longer in effect, it was an effort by EPA that 

would have resulted in additional SO2 reductions from EGUs beyond CAIR. The second 

rule is EPA’s Utility Mercury and Air Toxics Standards (Utility MATS) finalized in 

February 2012. While this rule’s focus is on air toxics, EPA projected additional 

significant SO2 reductions from EGUs beyond CSAPR (and by inference CAIR as well) 

as a co-benefit from additional controls needed to meet the new air toxics standards. The 

potential additional reductions of each rule are summarized in the following sections. 

Cross-State Air Pollution Rule

A straightforward accounting of additional EGU SO2 reductions from CSAPR compared 

to CAIR is not possible due to differences in the states covered under the two rules, and 

differences in the reduced scope of emissions trading allowed under CSAPR relative to 

CAIR. At a basic level, the overall emission caps under each program can be compared 

and are shown in the table below, with accompanying caveats as noted. Also note that 

the full implementation of CAIR is in 2015, while CSAPR would have imposed its final 

cap by 2014. 

Program SO2 cap (million tons annually) 

CAIR 2.6 (2015)* 

CSAPR 2.4 (2014)** 

CSAPR % reduction beyond CAIR -7.6% 

* Due to EGUs’ ability to use banked allowances under CAIR, EPA estimated actual SO2 emissions in 

2015 would be 4.1 million tons. 

**EPA provided a “variability limit” that is a fixed percentage above each state’s emissions budget to

allow for year-to-year fluctuations in electricity generation. Therefore, the state “budget” may be 

 

13 Bracketed text is not in original. The MANE-VU Ask to EPA does not explicitly mention power plants 

in the quoted text, but the preceding paragraphs in its request to EPA indicate that the focus of the 

additional 18% SO2 reductions is on power plants. 
25 

exceeded in any given year within the variability limit, resulting in emissions above the overall program 

cap to a limited extent. 

Utility Mercury and Air Toxics Standards

The Utility MATS address air toxics emitted by fossil fuel power plants, but EPA 

estimated that the projected controls needed to be installed on affected EGUs would 

result in an additional 41% reduction in SO2 emissions beyond CSAPR nationally.14

 

A listing of states and DC covered by the MANE-VU Ask is given in the following table, 

which shows EPA’s projected EGU SO2 emissions in a 2017 future baseline case that 

assumes CSAPR is in place and a 2017 MATS future control case.15 The table indicates 

that while the overall regional SO2 reduction beyond CSAPR resulting from Utility 

MATS among the MANE-VU Ask states is less than the relative national reduction, the 

regional reduction of 24% still exceeds the MANE-VU Ask to EPA of 18%. The 24% 

additional reduction in EGU SO2 emissions would also be a conservative minimum 

relative to CAIR, as it allows more emissions than CSAPR. 

State 2017 future baseline 

EGU SO2 (tons)15

2017 MATS future 

control case EGU 

SO2 (tons)15

CT 3,581 1,400 

DE 2,835 4,160 

DC 5 0 

GA 96,712 78,197 

IL 118,217 103,867 

IN 200,969 156,781 

KY 116,927 125,430 

ME 2,564 1,372 

MD 29,786 18,091 

MA 15,133 5,033 

MI 163,168 82,834 

NH 6,719 2,102 

NJ 9,042 6,404 

NY 14,653 28,174 

NC 71,113 59,551 

OH 180,935 139,208 

PA 126,316 93,606 

RI 0 0 

SC 103,694 40,901 

 

14 EPA Fact Sheet: Mercury and Air Toxics Standards, Benefits and Costs of Cleaning Up Toxic Air 

Pollution from Power Plants, December 21, 2011. Available at 

http://www.epa.gov/airquality/powerplanttoxics/pdfs/20111221MATSimpactsfs.pdf (accessed January 2, 

2013). 

15 U.S. EPA, Regulatory Impact Analysis for the Final Mercury and Air Toxics Standards, EPA-452/R-11-

011, December 2011 (Table 5A-12). 
26 

TN 33,080 42,666 

VT 264 264 

VA 51,004 33,704 

WV 84,344 66,857 

WI 50,777 28,322 

Subtotal MANE-VU Ask States only 1,478,257 1,117,524 

MATS % reduction beyond CSAPR --- -24% 
NH Regional Haze 5-Year Progress Report

ATTACHMENT D

Regional Emissions Trends Analysis for MANE-VU States
NH Regional Haze 5-Year Progress Report

This page is intentionally left blank.
Regional Emissions Trends Analysis for MANEVU States 

Technical Support Document 

Revision 3 

Prepared by: 

Mid-Atlantic Regional Air Management Association (MARAMA) 

8600 LaSalle Road, Suite 636 

Towson, MD 21286 

(443) 901-1882 

March 22, 2013 
Acknowledgements 

Funds for this project were provided by MARAMA’s Memorandum of Agreement with the 

Ozone Transport Commission (OTC), which is funded by USEPA grant agreement 

XA96309001. The purpose of that Memorandum of Agreement is to support the Mid-Atlantic / 

Northeast Visibility Union (MANE-VU) in developing programs to control regional haze or 

visibility impairment in the Northeast and Mid-Atlantic states. 

About MARAMA 

The Mid-Atlantic Regional Air Management Association, Inc. is a voluntary, non-profit 

association of ten state and local air pollution control agencies. MARAMA's mission is to 

strengthen the skills and capabilities of member agencies and to help them work together to 

prevent and reduce air pollution in the Mid-Atlantic Region. MARAMA provides cost-effective 

approaches to regional collaboration by pooling resources to develop and analyze data, share 

ideas, and train staff to implement common requirements. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page i 

Table of Contents 

1.0 INTRODUCTION ................................................................................................................................................. 1

1.1 THE PURPOSE OF THIS EMISSION TREND ANAYSIS ............................................................................................. 1

1.2 REPORT ORGANIZATION .................................................................................................................................. 1

2.0 METHODOLOGY AND DATA SOURCES ....................................................................................................... 2

2.1 GEOGRAPHIC AND TEMPORAL RESOLUTION .................................................................................................... 2

2.2 POLLUTANTS .................................................................................................................................................... 2

2.3 SOURCE CATEGORIES ....................................................................................................................................... 2

2.4 DATA FORMATS ............................................................................................................................................... 3

2.5 DATA SOURCES ................................................................................................................................................ 3

2.5.1 The 2002 Base Inventory with Projections to 2018 Version 3.3 ............................................................ 4

2.5.2 The 2007 Base Inventory with Projections to 2017 and 2020 ............................................................... 5

2.5.3 The 2010 Clean Air Markets Division (CAMD) Reported Emissions .................................................... 6

2.6 ANTHROPOGENIC VERSUS BIOGENIC EMISSIONS ............................................................................................. 7

2.7 CONSISTENCY OF DATA SOURCES ................................................................................................................... 8

2.7.1 Consistency across Inventories .............................................................................................................. 8

2.7.2 Changes in Energy Information Agency (EIA) Growth Factors ............................................................ 8

2.8 REGIONAL NATURE OF THE ANALYSIS ........................................................................................................... 11

2.9 QUALITY ASSURANCE .................................................................................................................................... 11

3.0 AREA SOURCES ................................................................................................................................................ 12

3.1 BACKGROUND ................................................................................................................................................ 12

3.2 ISSUES WITH AREA SECTOR DATA SETS ........................................................................................................ 12

3.2.1 Transport Fraction .............................................................................................................................. 12

3.2.2 Inconsistencies between area data sources ......................................................................................... 12

3.2.3 State Specific Issues ............................................................................................................................. 14

3.2.3.1 District of Columbia ........................................................................................................................................ 14

3.2.3.2 New Jersey ...................................................................................................................................................... 14

3.3 OBSERVED REGIONAL AREA SOURCE TRENDS .............................................................................................. 15

3.3.1 Nitrogen Oxides (NOX) ........................................................................................................................ 15

3.3.2 Sulfur Dioxide (SO2) ............................................................................................................................ 15

3.3.3 Fine Particulate (PM2.5 – Direct) ........................................................................................................ 16

3.3.4 Volatile Organic Compounds (VOC) ................................................................................................... 16

4.0 POINT SOURCES ............................................................................................................................................... 18

4.1 BACKGROUND ................................................................................................................................................ 18

4.2 ISSUES ENCOUNTERED WITH THE POINT SECTOR DATA SETS ........................................................................ 18

4.2.1 Splitting the EGU and nonEGU files ................................................................................................... 18

4.2.2 EGU point source growth .................................................................................................................... 19

4.2.3 Missing Data from EGU Units ............................................................................................................ 19

4.2.1 Missing Data from NonEGU Units ...................................................................................................... 20

4.2.2 Condensable Particulate Matter Emissions Factor ............................................................................. 20

4.2.3 Transport Fraction .............................................................................................................................. 21
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page ii 

4.2.1 New Jersey 2002 PM2.5 ...................................................................................................................... 21

4.3 OBSERVED REGIONAL POINT SOURCE TRENDS .............................................................................................. 21

4.3.1 Nitrogen Oxides (NOX) ........................................................................................................................ 21

4.3.2 Sulfur Dioxide (SO2) ............................................................................................................................ 22

4.3.3 Fine Particulate (PM2.5-Direct) ........................................................................................................... 22

4.3.4 Volatile Organic Compounds (VOC) ................................................................................................... 23

5.0 NONROAD MOBILE SOURCES INCLUDED IN NMIM ............................................................................. 23

5.1 BACKGROUND ................................................................................................................................................ 23

5.2 ISSUES ENCOUNTERED WITH NONROAD SECTOR DATA SETS......................................................................... 24

5.2.1 2002 inventory NonRoad Modeling ..................................................................................................... 24

5.2.2 2007 inventory NonRoad modeling ..................................................................................................... 24

5.2.3 SCCs Included in Non-Road Sector ..................................................................................................... 25

5.2.4 Future Year Emissions Projection ....................................................................................................... 25

5.3 OBSERVED REGIONAL NONROAD SECTOR TRENDS........................................................................................ 29

5.3.1 Nitrogen Oxides (NOX) ........................................................................................................................ 29

5.3.2 Sulfur Dioxide (SO2) ............................................................................................................................ 29

5.3.3 Fine Particulate (PM2.5 – Direct) ........................................................................................................ 29

5.3.4 Volatile Organic Compounds (VOC) ................................................................................................... 30

6.0 MARINE VESSELS, AIRPORTS, AND RAILROADS .................................................................................. 31

6.1 BACKGROUND ................................................................................................................................................ 31

6.2 ISSUES ENCOUNTERED WITH MAR SECTOR DATA SETS ................................................................................ 31

6.3 OBSERVED REGIONAL MAR SECTOR TREND ................................................................................................. 32

6.3.1 Nitrogen Oxides (NOX) ........................................................................................................................ 32

6.3.2 Sulfur Dioxide (SO2) ............................................................................................................................ 32

6.3.3 Fine Particulate (PM2.5 – Direct) ........................................................................................................ 33

6.3.4 Volatile Organic Compounds (VOC) ................................................................................................... 33

7.0 ONROAD MOBILE SOURCES ........................................................................................................................ 34

7.1 BACKGROUND ................................................................................................................................................ 34

7.2 ISSUES WITH MOBILE SECTOR DATA SETS ..................................................................................................... 35

7.2.1 2002 and 2018 inventory ..................................................................................................................... 35

7.2.2 2007 and 2020 inventory ..................................................................................................................... 35

7.3 OBSERVED REGIONAL ONROAD MOBILE SECTOR TREND .............................................................................. 36

7.3.1 Nitrogen Oxides (NOX) ........................................................................................................................ 36

7.3.2 Sulfur Dioxide (SO2) ............................................................................................................................ 37

7.3.3 Fine Particulate (PM2.5 – Direct) ........................................................................................................ 37

7.3.4 Volatile organic compounds (VOC) ..................................................................................................... 37

8.0 EMISSION SUMMARIES ................................................................................................................................. 38

9.0 ELECTRONIC FILES ........................................................................................................................................ 53

10.0 REFERENCES .................................................................................................................................................. 54
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page iii 

List of Appendices 

Appendix A List of Participants on the State Review Committee 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page iv 

List of Exhibits 

EXHIBIT 2.1 – DATA SOURCES BY SECTOR

EXHIBIT 2.2 – BIOGENIC VERSUS ANTHROPOGENIC VOC EMISSIONS

EXHIBIT 2.3 – CHANGE BETWEEN 2008 AND 2020 OF THE ENERGY INFORMATION AGENCY PROJECTION OF COAL 

CONSUMPTION FOR ENERGY GENERATION.

EXHIBIT 2.4 – CHANGE BETWEEN 2008 AND 2020 OF THE ENERGY INFORMATION AGENCY PROJECTION OF 

PETROLEUM CONSUMPTION FOR ENERGY GENERATION.

EXHIBIT 2.5 – CHANGE BETWEEN 2008 AND 2020 OF THE ENERGY INFORMATION AGENCY PROJECTION OF 

NATURAL GAS CONSUMPTION FOR ENERGY GENERATION.

EXHIBIT 3.1 – RESIDENTIAL WOOD EMISSIONS OF PM2.5 FROM THE 2002 VERSUS THE 2007 INVENTORY SUITE.

EXHIBIT 3.2 –AREA SOURCE - AIR POLLUTION EMISSIONS BETWEEN 2002 AND 2020

EXHIBIT 3.3 –NUMBER 2 FUEL OIL SO2 EMISSIONS TREND FOR MANE VU STATE 2002 TO 2020

EXHIBIT 3.4 –RESIDENTIAL WOOD COMBUSTION – DIFFERENCE BETWEEN 2002 AND 2007 INVENTORY SUITES

EXHIBIT 4.1 – EGU POINT SOURCE - AIR POLLUTION EMISSIONS BETWEEN 2002 AND 2020

EXHIBIT 4.2 –NON-EGU POINT - AIR POLLUTION EMISSIONS BETWEEN 2002 AND 2020

EXHIBIT 5.1 NONROAD CONTROL PROGRAMS INCLUDED IN 2007 INVENTORY SUITE

EXHIBIT 5.2 – REGIONAL NONROAD SOURCE - EMISSIONS BETWEEN 2002 AND 2020

EXHIBIT 6.1 – REGIONAL MAR SOURCES - AIR POLLUTION EMISSIONS BETWEEN 2002 AND 2020

EXHIBIT 7.1 – REGIONAL MOBILE ONROAD SOURCES - AIR POLLUTION EMISSIONS BETWEEN 2002 AND 2020

EXHIBIT 8.1 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 REGIONAL 

SUMMARY

EXHIBIT 8.2 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 CONNECTICUT

EXHIBIT 8.3 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 DELAWARE

EXHIBIT 8.4 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 DISTRICT OF 

COLUMBIA

EXHIBIT 8.5 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 MAINE

EXHIBIT 8.6 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 MARYLAND

EXHIBIT 8.7 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 MASSACHUSETTS

EXHIBIT 8.8 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 NEW HAMPSHIRE

EXHIBIT 8.9 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 NEW JERSEY

EXHIBIT 8.10 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 NEW YORK

EXHIBIT 8.11 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 PENNSYLVANIA

EXHIBIT 8.12 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 RHODE ISLAND

EXHIBIT 8.13 ANNUAL AIR POLLUTANT EMISSION TRENDS BY SECTOR BETWEEN 2002 AND 2020 VERMONT

EXHIBIT 9.1 EMISSION INVENTORY DATA FILES
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page v 

Acronyms and Abbreviations 

Acronym Description 

AEO Annual Energy Outlook 

APU Auxiliary Power Unit 

BEIS Biogenic Emissions Inventory System 

BOTW Beyond on the way 

CAA Clean Air Act 

CMAQ Community Multi-scale Air Quality Modeling System 

CAMD Clean Air Markets Division (USEPA) 

CEM Continuous emission monitoring 

CAIR Clean Air Interstate Rule 

CMV Commercial marine vessel 

CO Carbon monoxide 

CSAPR Cross-State Air Pollution Rule 

EGU Electric generating unit 

EIA Energy Information Agency 

ERTAC Eastern Regional Technical Advisory Committee

FIPS Federal Information Processing Standard 

GSE Ground support equipment 

IPM Integrated Planning Model 

MANE-VU Mid-Atlantic/Northeast Visibility Union 

MAR Marine, airport, rail 

MARAMA Mid-Atlantic Regional Air Management Association 

MEGAN Model of Emissions of Gases and Aerosols from Nature 

MOBILE6 USEPA model used to estimate onroad mobile emissions, now outdated 

MOVES Motor Vehicle Emissions Simulator model 

NAAQS National Ambient Air Quality Standards 

NCD National County Database 

NEI National Emission Inventory 

NESCAUM Northeast States for Coordinated Air Use Management 

NIF3.0 NEI Input Format Version 3.0 

NMIM National Mobile Input Model 

NONROAD USEPA model used to estimate off-road mobile emissions 

NOx Oxides of nitrogen 

OTB/OTW On the books/On the way 

ORL One-record-per-line (SMOKE format) 

OTAQ Office of Transportation and Air Quality (USEPA) 

OTC Ozone Transport Commission 

PFC Portable fuel container 

PM-CON Primary PM, condensable portion only ( < 1 micron) 

PM-FIL Primary PM, Filterable portion only 

PM-PRI Primary PM, includes filterable and condensable 

PM-PRI= PM-FIL + PM-CON 

PM25-FIL Primary PM2.5, filterable portion only 

PM25-PRI Primary PM2.5, includes filterable and condensable 

PM25-PRI= PM25-FIL + PM-CON 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page vi 

Acronym Description 

QAPP Quality Assurance Project Plan 

RPO Regional Planning Organization 

RWC Residential wood combustion 

SIP State Implementation Plan 

SCC Source classification code 

SMOKE Sparse Matrix Operator Kernel Emissions 

SO2 Sulfur dioxide 

TSD Technical Support Document 

USEPA U.S. Environmental Protection Agency 

VMT Vehicle miles traveled 

VOC Volatile organic compounds 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 1 

1.0 INTRODUCTION 

This technical support document (TSD) explains the data sources and methods for 

analyzing the anthropogenic pollutant emissions trends since 2002 in the Mid-Atlantic / 

Northeast Visibility Union (MANE-VU) region. Results of the analysis are presented. The 

MANE-VU region includes Connecticut, Delaware, the District of Columbia, Maine, 

Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode 

Island and Vermont. 

1.1 THE PURPOSE OF THIS EMISSION TREND ANAYSIS 

States are required to submit a periodic report every five years beginning five years after 

submittal of the initial regional haze SIP. The Environmental Protection Agency’s (EPA) 

regional haze rule requires states to prepare 

“An analysis tracking the change over the past 5 years in emissions of pollutants 

contributing to visibility impairment from all sources and activities within the 

State. Emissions changes should be identified by type of source or activity. The 

analysis must be based on the most recent updated emissions inventory, with 

estimates projected forward, to account for emissions changes during the 

applicable 5-year period.” 

To support MANE-VU states’ preparation of their progress reports, the change in 

emissions in the region is evaluated. Reductions are evaluated by sector and state. It is 

anticipated that MANE-VU member states will use this report in conjunction with other 

information developed by Northeast States for Coordinated Air Use Management (`), the 

Ozone Transport Commission (OTC) and the MANE-VU member states to develop their 

first five-year progress report. 

1.2 REPORT ORGANIZATION 

Section 2 describes the methodology and data sources used to analyze emission trends. 

Sections 3 to 7 provide a detailed approach for each inventory sector: area sources; point 

sources; nonroad mobile sources included in the NMIM model; other nonroad mobile 

sources (marine vessels, aircraft, and railroad locomotives); and onroad mobile sources. 

Section 8 provides emission trend summaries. Section 9 provides the file name and a 

description of the electronic files developed as part of this project. References are 

provided in Section 10. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 2 

2.0 METHODOLOGY AND DATA SOURCES 

2.1 GEOGRAPHIC AND TEMPORAL RESOLUTION 

The geographic area for the inventory trend analysis is the MANE VU states including: 

Connecticut, Delaware, District of Columbia, Maine, Maryland, Massachusetts, New 

Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, and Vermont. 

The temporal resolution is annual. 

2.2 POLLUTANTS 

In other work, the OTC has established that SO2 is the most important pollutant driving 

fine particle ambient concentrations and visibility impairment in the northeastern United 

States. (NESCAUM 2006a) However, other pollutants also play a role. Therefore, this 

study includes an analysis of emission changes for the following pollutants: oxides of 

nitrogen (NOx), sulfur dioxide (SO2), volatile organic compounds (VOC) and particulate

matter less than 2.5 microns in size (PM2.5). 

Where Clean Air Market’s Division (CAMD) data is used, only NOx, and SO2 emission 

data is available so only those two pollutants are compared. The fine particulate species in 

the inventory are categorized as particles with an aerodynamic diameter less than or equal 

to a nominal 2.5 micrometers (PM2.5-PRI), which includes both condensable (PM-CON) 

and filterable particles (PM2.5-FIL). 

2.3 SOURCE CATEGORIES 

The trend in emission is analyzed for the following inventory sector: 

• EGU Point Sources are units that generate electric power and sell most of that 

power to the electrical grid. 

• NonEGU Point Sources are individual industrial, commercial, and institutional 

facilities. 

• Stationary Area Sources are facilities that in and of themselves are quite small, 

but in aggregate may contribute significant emissions. Examples include small 

industrial/commercial facilities, residential heating furnaces, VOCs volatizing from 

house painting or consumer products, gasoline service stations, and agricultural 

fertilizer/pesticide application sites. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 3 

• Non-road Mobile Sources are vehicles and equipment that are operated off public 

roadways. This includes equipment such as forklifts, lawn and garden equipment, 

and portable generators. Marine, air, and rail sources are not included in this 

sector. 

• Marine Air Rail (MAR) Sources include marine vessels, airplanes, and railroad 

locomotives (MAR). 

• On-road Mobile Sources include cars, trucks, buses, and other vehicles that 

operate on public roadways. 

Biogenic/geogenic emissions are included in modeling, but are not considered to change 

over time. For the purposes of the Clean Air Act, biogenic emissions do not need to be 

considered in determining progress to meeting the State’s visibility goals as only 

anthropogenic air pollution affecting visibility is addressed. In general, this trend analysis 

does not include any consideration of biogenic emissions. One exception is a discussion of 

biogenic emissions of VOC, which predominate in many rural environments. 

2.4 DATA FORMATS 

Besides this report, easy-to-review spreadsheets were prepared for each inventory sector 

that provides a more detailed look at the emissions for each year analyzed. State-level 

tabular and graphical summaries are also available. These are stored on the MARAMA 

FTP server, as described in Section 9, Electronic Files. 

2.5 DATA SOURCES 

A variety of data sources were integrated to produce the emissions trends reported in this 

document. These include two inventory suites prepared by MARAMA as inputs to the 

OTC multi-pollutant regional air quality modeling. Each inventory suite includes a base 

year and estimates of future year emissions. Within a given suite, the base year emissions 

are “actual” emissions from a year that was in the recent past at the time that the inventory 

suite was prepared. They are either measured values or estimates based on measured 

activity data. Examples of activity data include county population or numbers of cars 

registered in a county. Future year emissions key off the base year with growth and 

control factors applied to the base year emissions. Logically, the future year estimates 

include all of the assumptions and emissions estimation methodologies used for the 

associated base year. As a result, future years estimated in one suite may not align well 

with future years from a different suite because different growth and control assumptions, 

models, and methodologies were used from one suite to another. The two inventory suites 

included in this study are: 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 4 

• 2002 base with projections to 2018 (MANE-VU 2006; MANE-VU 2007) 

• 2007 base with projections to 2017 and 2020 (MANE-VU 2011a & b) 

As will be discussed further below, the two suites underwent multiple renditions to 

incorporate comments and improvements. 

Besides these inventory suites, an additional source of data integrated into the analysis is 

the 2010 Clean Air Markets Division (CAMD) actual emissions (CAMD 2010). Exhibit 

2.1 shows the data sources, including specific inventory versions that were accessed for 

this project and how each data sources is used in the emissions trends analysis. 

Exhibit 2.1 – Data Sources by Sector 

2002 Actual 2007 Actual 2010 Actual 2017 Projected 2018 Projected 2020 Projected

EGU Point MANE-VU V3.3 MARAMA V3 CAMD ** MARAMA V3 * MANE-VU V3.3 MARAMA V3 *

NonEGU Point MANE-VU V3.3 MARAMA V3 --- MARAMA V3 MANE-VU V3.3 MARAMA V3

Mobile MANE-VU V3.3 MARAMA V2 --- --- MANE-VU V3.3 MARAMA V3 *

Area MANE-VU V3.3 MARAMA V3 --- MARAMA V3 MANE-VU V3.3 MARAMA V3

Nonroad (NMIM) MANE-VU V3.3 MARAMA V3 --- MARAMA V3 MANE-VU V3.3 MARAMA V3

MAR MANE-VU V3.3 MARAMA V3 --- MARAMA V3 MANE-VU V3.3 MARAMA V3

* Not currently complete. Will be included if complete in time for use in this 

project 

** To the extent crosswalk matching of units allows. 

The following sections provide more details on each of the data sources included in this 

study. 

2.5.1 The 2002 Base Inventory with Projections to 2018 Version 3.3 

The 2002 modeling inventory suite was prepared by MARAMA and finalized in 2006. 

Future year projections based on the base year 2002 inventory were prepared for 2009 and 

2018. Two scenarios for the future year were prepared as follows: 

On the Books /On the Way (OTB/OTW) – These projections reflect a scenario 

accounting for all in-place controls that were fully adopted into federal or 

individual state regulations or SIPs. This includes the anticipated effect of the 

Clean Air Interstate Rule (CAIR). Modelers often refer to this scenario as the 

"future base case". 

Beyond On the Way (BOTW) - These projections reflect a scenario accounting for 

all measures in the OTB/OTW scenario and also additional controls that states 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 5 

commit to adopt as part of the SIP process. Modelers often refer to this scenario as 

the "future control case". The BOTW projection to 2018 was used by MANE VU 

states air quality modeling to support certain PM, ozone and visibility SIPs. 

The Beyond on the Way (BOTW) projection for 2018 was used for this emissions trend 

analysis because this scenario was used in OTC regional photochemical air quality 

modeling to develop reasonable progress goals for visibility State Implementation Plans 

(SIP). 

Several versions of the 2002 inventory suite were prepared. With each subsequent version 

improvements were made to the emissions estimation. The last and best version is called 

Version 3.3. This is the version that was used in air quality modeling and is also used in 

this emission trend analysis. 

Details of the approach taken to prepare the 2002 modeling suite are found in the 

documentation for the base year (MANE-VU 2006) and future projections (MANE-VU 

2007). 

2.5.2 The 2007 Base Inventory with Projections to 2017 and 2020 

The 2007 modeling inventory suite used in this analysis was prepared by MARAMA and 

finalized in 2012. (MANE-VU 2011a). Future year projections from base year 2007 were 

prepared for 2017 and 2020 (MANE-VU 2011b) for all sectors except the electric 

generation. In addition only a 2020 onroad future projection was prepared. The 2007 

inventory suite was used by MANE VU states in photochemical air quality screening 

modeling in 2011 and 2012. 

Electric Generating Units (EGU) emissions are only available for the base year, 2007. For 

preliminary modeling purposes, provisional EGU estimates were developed for future year 

2020 based on the CSAPR caps (now abolished). High quality future year modeling 

inventories for EGUs are currently being developed under a separate effort lead by the 

Eastern Regional Technical Advisory Committee (ERTAC). These are not yet available 

for this study. 

Onroad emissions are only available for base year 2007 and future year 2020. Use of the 

MOVES model proved so resource intensive that no funds were available to develop a 

2017 onroad inventory. Under a separate effort, NESCAUM developed a 2007 onroad 

inventory using the MOVES model to support air quality modeling (NESCAUM 2011). 

Those runs were further revised by the Virginia Department of Environmental Quality to 

adjust for the height at which temperature was measured. This adjusted run (Version 2) 

was used in OTC Level 3 screening modeling and also in this analysis. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Two scenarios for the future year were prepared as follows: 

On the Books /On the Way (OTB/OTW) – This projection reflects a scenario 

accounting for controls that are fully adopted into federal or individual state 

regulations or SIPs. Also included in this scenario were some proposed (but not 

final) control programs that are reasonably anticipated by states to result in post2007 emission reductions. Finally, low sulfur fuel rules were included in this 

inventory for New Jersey, Maryland and New York. 

OTC Control Measures – This suite of projections reflect a scenario accounting 

for all measures in the OTB/OTW scenario and, in addition, the application of nine 

control measures for which the OTC has developed model rules. This scenario is 

not addressed in this document. 

For this emission trend analysis, the OTB/OTW projection for 2017 and 2020 was used. 

As noted above, EGU emissions were not prepared for either of these projection scenarios. 

Several versions of the 2007 inventory suite were prepared. With each subsequent version, 

improvements were made to the emissions estimation. The last and best version is called 

Version 3.3 which was used in OTC Level 3 screening photochemical air quality modeling 

and also in this emission trend analysis. 

Details of the approach taken to prepare the 2007 modeling suite are found in the 

documentation for the base year (MANE-VU 2011a) and future projections (MANE-VU 

2011b) 

2.5.3 The 2010 Clean Air Markets Division (CAMD) Reported Emissions 

CAMD collects emissions of NOx, SO2 and heat input (HI) from large point sources in 

order to implement the emissions cap and trade program under the Acid Rain Control 

Program, the NOx Budget Trading Program, or the Clean Air Interstate Rule found in 

Volume 40 Part 75 of the Code of Federal Regulations (CFR). These rules require hourly 

reporting of SO2 and NOX emissions from each participating unit. Most of the CAMD 

units are traditional power plants that sell electricity to the electrical grid (EGUs). There 

are, however, other types of units that report to CAMD that are not considered to be EGUs, 

such as petroleum refineries and cement kilns. For this report, only the EGU data was 

used. The annual unit level CAMD NOX and SO2 emissions files for 2010 were 

downloaded for use in this project. (CAMD2010) 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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2.6 ANTHROPOGENIC VERSUS BIOGENIC EMISSIONS 

In general, this report deals only with anthropogenic emissions. However, biogenic VOC 

emissions are significant, particularly in rural areas where they can be many times the 

anthropogenic contribution. This can be seen comparing biogenic and anthropogenic VOC 

emissions for a rural state like Vermont where biogenic emissions are four times 

anthropogenic emissions, with an urban jurisdiction like the District of Columbia where, 

conversely, anthropogenic emissions are five times biogenic. Thus, when we examine 

VOC emission trends, it should be noted that we are only examining the change in 

anthropogenic emissions, which in some cases is a very small portion of the whole. In the 

OTC photochemical air quality modeling studies, biogenic emissions are assumed to be 

unchanged between base and future years. 

Exhibit 2.2 – Biogenic versus Anthropogenic VOC Emissions 

2002

Biogenic 

2007

Biogenic 

2007

Anthropogenic 

Data Source 2002 V3 2007 V3 

Total 2007 V3 

without EGU 

CT 64,017 150,695 114,826

DE 46,343 46,598 31,147

DC 1,726 2,200 10,450

ME 600,205 484,376 82,517

MD 210,104 313,773 161,807

MA 113,958 211,136 177,998

NH 141,894 171,863 54,049

NJ 181,617 229,424 231,320

NY 492,487 878,461 485,262

PA 585,272 995,491 459,576

RI 19,233 34,177 42,304

VT 118,377 145,008 34,694

Total 2,575,233 3,663,203 1,885,950

Additionally, it should be noted that the difference between estimates of biogenic 

emissions for 2002 and 2007. The estimate for 2007 is much higher because of a change 

in the model used to estimate these emissions. For the 2002 inventory suite, BEIS was used 

while in the 2007 suite MEGAN was used. In states where biogenic emissions 

predominate, like Connecticut and Vermont, this difference may be significantly greater 

than anticipated anthropogenic reduction of VOC. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 8 

It is also important to note that Clean Air Act only requires reductions in manmade air 

pollution to achieve the national visibility goals. The visibility goal was established to 

prevent visibility impairment from manmade and not biogenic emissions. 

2.7 CONSISTENCY OF DATA SOURCES 

2.7.1 Consistency across Inventories 

The data sources used in this analysis were developed at different times and for different 

purposes. The 2002 and 2007 inventory suites are calculated estimations prepared as input 

files for regional modeling. CAMD data are emissions measurements collected to 

demonstrate compliance with regulations. Different methodologies, suitable to the purpose 

of the inventory, were used for development. 

Both between and within inventory suites, there are significant differences in methodology 

and in the sources inventoried. This may be a result of local custom or may result from 

regional differences in source importance. For example, the New Hampshire inventory 

includes emissions from industrial wood combustion but this Source Classification Code 

(SCC) is not included in the New Jersey inventory as it is unlikely that wood is used as an 

energy source in any New Jersey industry. Finally, the resources available to collect the 

data vary between states. For inventories suites, when resources are limited, states may 

consolidate minor SCCs. For this study, these discrepancies are handled differently 

depending on the source sector, as is further described in each section describing that 

sector. 

2.7.2 Changes in Energy Information Agency (EIA) Growth Factors 

Both the 2002 and 2007 inventory suites use the Energy Information Administration (EIA) 

Annual Energy Outlook (AEO) to develop growth factors for many SCCs, particularly 

those which involve fuel usage. Energy projections evolve over time with near-year 

projections being more certain than years farther in the future. In recent AEOs, there has 

been a significant shift in projected energy consumption toward natural gas. In addition, 

the economic downturn of 2009 and the emphasis on increased energy efficiency have 

resulted in lower future expectations for total energy usage. 

Exhibits 2.3, 2.4 and 2.5 show the change from AEO2005 to AEO2012 of the expected use 

of coal, natural gas, and petroleum for power generation. The blue dashed line in each 

chart is AEO2005, which was used in the 2002 inventory suite to grow the base year to 

future projections. The blue solid line in each chart is AEO2010 which was used by most 

states in the 2007 inventory suite to grow the base year to future projections. Note that 

New Jersey used AEO 2011, and certain other SCC codes for other MARAMA states were 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 9 

updated to include AEO 2011. In Exhibit 2.3, it can be seen that the expected future coal 

use dropped significantly between AEO2005 and AEO 2010. It should be noted that the 

projected use of coal further declines in future years for the most recent AEO growth 

estimation. A similar pattern can be seen in Exhibit 2.4 for petroleum. The trend is less 

clear for natural gas as can be seen in Exhibit 2.5. AEO2005 predicted that stronger 

growth for natural gas was expected than in AEO2010; however more recent growth 

factors are closer to the strong growth predicted in AEO2005 as a result of the recent surge 

in natural gas exploration and production. Lower growth of coal electricity generation 

translates into lower expected future emissions. It is important to note that this difference 

in growth rate systemically reduces the future emissions from fuel burning in the 2007 

inventory suite compared to the 2002 inventory suite. 

Exhibit 2.3 – Change between 2008 and 2020 of the Energy Information Agency 

Projection of Coal Consumption for Energy Generation. 

1200

1500

1800

2100

2400

2700

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

M

i

l

l

io

n

M

e

g

a

w

a

t

t

-H

o

u

r

s

AEO2005

AEO2008

AEO2009

AEO2010

AEO2011

AEO2012

AEO2013
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Exhibit 2.4 – Change between 2008 and 2020 of the Energy Information Agency 

Projection of Petroleum Consumption for Energy Generation. 

10

30

50

70

90

110

130

150

170

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Million Megawatt-Hours

AEO2005

AEO2008

AEO2009

AEO2010

AEO2011

AEO2012

AEO2013
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Exhibit 2.5 – Change between 2008 and 2020 of the Energy Information Agency 

Projection of Natural Gas Consumption for Energy Generation. 

500

600

700

800

900

1000

1100

1200

1300

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

M

i

l

l

io

n

M

e

g

a

w

a

t

t

-H

o

u

r

s

EIA's AEO Projection of Gas-based Electricity Generation

AEO2005

AEO2008

AEO2009

AEO2010

AEO2011

AEO2012

AEO2013

2.8 REGIONAL NATURE OF THE ANALYSIS 

The emission trend analysis presented in this report is done at a regional level. As a result, 

larger states dominate the results. Trends for individual states, especially smaller states, 

may vary. State level data is provided in Section 8 in addition to the regional data that has 

been analyzed to present a regional emissions trend. 

2.9 QUALITY ASSURANCE 

The approach outlined in the Quality Assurance Project Plan (QAPP) was used to guide 

the project. (MARAMA 2012) An important element of quality control is review of work 

products by the state workgroup formed to guide the emissions trend analysis process. 

Participants of this group are listed in Appendix A. The workgroup met via teleconference 

on multiple occasions to discuss plans for the emissions trend analysis. In addition, 

members reviewed and commented on project work products. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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3.0 AREA SOURCES 

3.1 BACKGROUND 

The area sector includes sources which individually are too small or too numerous to 

inventory as individual point sources. Area sources are estimated as an aggregate by 

county. Examples are emissions from home heating systems, house painting, consumer 

products usage, and small industrial/commercial operations not included in the inventory 

as point sources. 

Two data sources were combined in this study to establish an emission trend for area 

sources. These are: 

• 2002 MANE VU V3.3 modeling inventory with a projection to 2018 

• 2007 MARAMA V3 modeling inventory with projections to 2017, and 2020 

3.2 ISSUES WITH AREA SECTOR DATA SETS 

3.2.1 Transport Fraction 

USEPA proscribed emission estimation methodologies overestimate fugitive dust in the 

ambient air. They are intended to estimate the emissions at the exact source of emission 

(dust from roadways or construction). However, fugitive dust does not transport far and is 

not measured in ambient air sampling monitors. To adjust the inventories, fugitive dust 

emissions of PM25-PRI for certain SCCs are reduced using a USEPA-developed 

methodology that accounts for the removal of fugitive particles near their emission point 

by vegetation and surface features. This is termed application of a “Transport Fraction.” 

The largest categories adjusted are paved and unpaved roads, construction activity, and 

agricultural crop land tilling. In this inventory trend analysis, there have been no 

reductions to the inventory to account for this transport reduction for fugitive dust. 

3.2.2 Inconsistencies between area data sources 

Between development of the 2002 and the 2007 modeling inventories, significant 

improvements were made to estimation methodologies, and emission and growth factors 

used to estimate area source emissions. These are noted in this documentation, however, 

no attempt has been made to adjust the inventories to account for these changes. Changes 

affecting the area source sector include: 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 13 

Residential Wood Combustion: Residential wood combustion is the largest 

contributor to regional fine particulate emissions. A new calculation tool was 

developed in advance of the 2007 inventory to estimate emissions from residential 

wood combustion. For the tool a new suite of SCC source categories was 

developed. In addition new emission factors and new calculation methodology 

were developed. Thus, the resulting emissions for this sub-category of area 

emissions are not comparable between the two inventory suites. Fine particulate 

emissions are particularly affected by this change as can be seen in Exhibit 3.1. 

While the effect of the new tool varies from state to state, the 2007 inventory suite 

residential wood combustion PM2.5 emission estimate is, on average, 40 percent 

lower than the 2002 inventory suite for the MANE VU region. 

Exhibit 3.1 – Residential Wood Emissions of PM2.5 from the 2002 versus the 2007 

Inventory Suite. 

Inconsistency in the included source categories between inventory suites: In 

addition to residential wood, the estimation methodology for many other smaller 

sources was improved. In some cases several SCC codes were consolidated into a 

single combined SCC. In other cases new SCC codes were established. These 

shifts make a direct comparison of the inventories at the SCC level difficult. An 

analysis of the consistency between inventories was prepared by MARAMA to 

assist states in their review of this sector (MARAMA 2013). 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Road dust PM25 Direct emissions: USEPA revised the recommended calculation 

methodology for road dust prior to completion of the 2007 inventory suite. As a 

result of this revision, the emissions from paved roads generally increased. 

Energy use growth factor: The Energy Information Agency (EIA) Annual 

Energy Outlook (AEO) is used to project future area source fuel combustion 

emissions. As was described earlier, there has been an overall damping down of 

fuel use growth projected looking into the future and a significant fuel shift away 

from coal and toward natural gas. Both of these changes result in lower emissions 

in future projections. Thus, if 2018 had been projected from base year 2002 using 

current growth factors, estimated emissions from fuel combustion would have been 

lower. 

Shift of sources between area and point source sector: For a variety of reasons, 

in some states emissions may be characterized as point sources in one inventory 

and area sources in another. 

Natural variation in the base year: Emissions such as forest wildfires are 

dependent upon the year inventoried. These emissions are held constant in the 

future year for a particular inventory suite, but vary from suite to suite. 

3.2.3 State Specific Issues 

3.2.3.1 D

istrict of Columbia 

The District of Columbia revised emissions for a variety of area source SCCs for all 

pollutants for both 2002 and 2007. No adjustments were made to future year projections 

(2017, 2018, 2020). Details of adjustments are available on the MARAMA ftp. 

3.2.3.2 N

ew Jersey 

New Jersey revised 2007, 2017 and 2020 wildfire emissions from those presented in the 

2007 2017 and 2020 Technical Support Documents. Emissions were averaged over a 

period of years, which provides for a more appropriate trend analysis evaluation. USEPA 

also uses this methodology in projection inventories and modeling. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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3.3 OBSERVED REGIONAL AREA SOURCE TRENDS 

This section describes regional trends. The regional data drawn on is presented in Section 

8. In addition, Section 8 provides state level data, where the trends may be different than 

what holds true at the regional level. The regional data for area sources extracted from the 

larger Section 8 tables is summarized in Exhibit 3.2. Note that the three data sources are 

delineated by color differences: 

• Blue - 2002V3 inventory suite 

• Tan - 2007V3 inventory suite 

• White – CAMD 2010 actual data (where available) 

Exhibit 3.2 –Area Source - Air Pollution Emissions between 2002 and 2020 

2002 2007 2010 2017 2018 2020

2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

NOX 266,747 207,054 --- 194,832 263,954 194,868

PM2.5 332,676 259,938 --- 262,887 339,518 264,959

SO2 316,287 212,471 --- 119,215 190,437 116,511

VOC 1,366,735 784,233 --- 702,289 1,334,175 696,125

3.3.1 Nitrogen Oxides (NOX) 

In 2007 area sources accounted for approximately 10 percent of regional NOX emissions 

and were already below the 2018 target set by regional air quality modeling. Furthermore, 

they are projected to decline further by 2017. Reductions are largely due to turn over to 

cleaner emission units in the future. However, without additional control programs or 

conservation measures, area sector NOX emissions are projected to rise slightly again 

between 2017 and 2020. Projected 2020 emissions still remain below the 2018 regional 

target for this sector. 

3.3.2 Sulfur Dioxide (SO2) 

Area sources account for approximately 10 percent of regional SO2 emissions in 2007. 

These emissions are primarily from residential heating with distillate oil. Regional area 

source SO2 emissions trend downward through 2020 and are projected to fall below the 

2018 regional target by 2017. Expected future reductions are due to reduced fuel sulfur 

content and fuel use shifts to natural gas. Significant state differences exist with projected 

reductions more significant in New Jersey, Maryland and New York where the 

implementation of low sulfur rules are included in future year inventories, as can be seen in 

Exhibit 3.3. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Exhibit 3.3 –Number 2 Fuel Oil SO2 Emissions Trend for MANE VU State 2002 to 2020 

 

3.3.3 Fine Particulate (PM2.5 – Direct) 

Area sources account for approximately 65 percent of directly emitted regional fine 

particulate in 2007. Regionally, estimated area source emissions for fine particulate are 

generally lower in the 2007 inventory suite than the 2002 inventory suite. This is primarily 

because of a change in the emission factor used for residential wood combustion emissions 

as was shown in Exhibit 3.1. In addition, the road dust calculation method was revised, 

further confounding any possible conclusions. We therefore conclude that no trends can be 

drawn from the combined data set. However, by looking at the two individual inventory 

suites it can be seen that regionally PM2.5 from area sources are expected to increase 

slightly in the future. 

3.3.4 Volatile Organic Compounds (VOC) 

Area sources account for approximately 41 percent of regional anthropogenic VOC 

emissions in 2007. Estimated emissions for VOC are generally lower in the 2007 

inventory than the 2002 inventory because of a change in emission factor and calculation 

methodology used for residential wood combustion emissions. The difference in the two 

inventory suites for VOC from RWC is shown in Exhibit 3.4. We, therefore, conclude that 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 17 

no trends can be drawn from the combined data set. However, both inventory suites 

separately show anthropogenic VOC from area sources decreasing in the future. 

Exhibit 3.4 –Residential Wood Combustion – Difference between 2002 and 2007 

Inventory Suites 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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4.0 POINT SOURCES 

4.1 BACKGROUND 

Point sources are those that are individually characterized within the inventory. In most 

cases, states track these sources through a permitting and emissions reporting process. 

The point source sector has two subcategories: Electric Generating Units (EGU) and NonElectric Generating units (Non-EGU). This distinction is drawn because the approach 

taken to estimate base and future emissions in the two subcategories is quite different. 

Non-EGUs emissions are reported by sources, but are generally estimated using emission 

factors rather than measured. They are projected based on expected business growth 

patterns. 

EGU emissions of NOX and SO2 are generally measured using continuous emission 

monitors (CEMs). Emissions of VOC and PM2.5 are estimated using emission factors. 

The approach taken for EGUs future projection varied between the two suites of modeling 

inventories, and will be discussed in detail later.

Three sources were combined in this study to establish an emission trend for point sources 

as follows: 

• 2002 MANE VU V3.3 modeling inventory with a projection to 2018 

• 2007 MARAMA V3 modeling inventory with projections to 2017, and 2020 

• 2010 actual emissions as reported to CAMD (for EGU sources only) 

4.2 ISSUES ENCOUNTERED WITH THE POINT SECTOR DATA SETS 

4.2.1 Splitting the EGU and nonEGU files 

Most, but not all, units that report hourly emissions to CAMD are classified as EGUs. The 

following criteria were used to classify units: 

• An EGU sells most of the power generated to the electrical grid; 

• An EGU burns mostly commercial fuel which is defined in this case as natural gas, 

oil, and coal. Wood is not considered a commercial fuel as some states identify 

wood as renewable. To avoid double counting, units that burn wood and other 

renewable sources (depending on each state's own definition) are not included in 

the EGU dataset as they are included in the nonEGU point source sector. 

• In addition, the following units were not considered EGUs: (1) a unit that generates 

power for a facility but occasionally sells to the grid; (2) emergency generators; or 

(3) distributed generation units. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 19 

In the 2002 inventory, EGU and Non-EGU point sources were combined in a single file. 

Separate EGU and NonEGU files were developed for projection year 2018. For this 

project, the 2002 data was split into EGU and NonEGU using a crosswalk, developed with 

the 2002 inventory suite that identifies each unit as either EGU or nonEGU. After review 

by the states, additional units were removed from the 2002 EGU file and reclassified as 

nonEGU. 

For the 2007 inventory suite, states classified point source units as either EGU or nonEGU 

and this classification was incorporated into the 2007 point source file. This classification 

was used to split the 2007 combined file into EGU and nonEGU point files. 

The 2002 and 2007 inventory suites along with the 2010 CAMD data were combined to 

form a single file using ACCESS queries matching ORIS and/or state unit identifiers. For 

EGU emissions, a trend was established using 2002, 2007, 2010, and 2018 data. For NonEGU sources, a trend was established using 2002, 2007, 2017, 2018 and 2020 data. 

4.2.2 EGU point source growth 

For the 2002 inventory suite, EGU emissions were projected to 2018 using the Integrated 

Planning Model (IPM) by ICF. ICF is both the owner/developer of the IPM model and the 

contractor that completed the work. Because IPM uses a different unit naming scheme and 

also includes a number of smaller units that are not in the base year most units cannot be 

matched with the 2002 base year. The additional units added by IPM are generally small 

and atypical such as generators located at landfills and firing landfill gas. Finally, the IPM 

model dramatically shifts unit utilization to minimize emissions for the least cost. In most 

states IPM predicted that many units, particularly oil burning units, would shut down and 

new replacement units would be built. In some cases, the projection was considered 

unrealistic and was adjusted (MARAMA 2009). 

For the 2007 inventory, there are plans in place to project emissions using a new model 

being developed by an inter-Regional Planning Organization (RPO) cooperative team 

called ERTAC EGU. No EGU emissions results are yet available for use in this report. As 

a result, projection years 2017 and 2020 are not included for EGUs in this emissions trend 

analysis. 

4.2.3 Missing Data from EGU Units 

MARAMA noted that in the EGU combined datasets some units were missing emissions 

data from one or more of the trend years. States were asked to review the combined files 

and complete data for as many units as possible. If a unit was off-line or shut down they 

were asked to confirm the shutdown. In these cases a zero was entered for the years that 

the source was shutdown. Where states were unable to complete the data, the emission 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 20 

unit was removed from the analysis to maintain continuity between the analysis years. 

Because removal of data reduces the impact of the sector, a target of 90 percent complete 

records was set. All states were able to achieve 90 percent complete for NOX, SO2, and 

VOC emission data. In the summary tables in Section 8, values that represent 90 percent 

complete are indicated with a tag of “2”. An analysis of the consistency between 

inventories was prepared by MARAMA to assist states in their review of this sector 

(MARAMA 2013) 

The inventory year 2018 is an exception to this approach. Because of the above described 

difficulties in matching IPM generated files, no attempt was made to match the EGU 

emissions estimated for 2018. The 2018 emissions as projected by IPM were assumed to 

be complete without matching or adjustment. 

4.2.1 Missing Data from NonEGU Units 

MARAMA noted that in the Non-EGU combined datasets some units were missing 

emissions data from one or more of the trend years. States were asked to review the 

combined files and complete data for as many units as possible. If a unit was off-line or 

shut down they were asked to confirm that zero was the correct entry. 

States that provided adjusted non-EGU data include Pennsylvania, Maine, District of 

Columbia, New Hampshire and Connecticut. Only Pennsylvania was able to achieve the 

target of 90 percent for non-EGU data. Connecticut declined to complete all non-EGU 

point source information because it would result in double counting of emissions that were 

accounted for in the area source inventory. Maryland was unable to align any of their 

Non-EGU point sources between the 2002 and 2007 inventory suites because the source 

identification system was changed in the intervening years. 

While most states were unable to achieve the target of 90% complete for non-EGU point 

sources, no emission units was removed from the analysis. Instead, the non-EGU point 

inventory is presented regardless of completeness as the best available data. 

4.2.2 Condensable Particulate Matter Emissions Factor 

The PM species in the inventory are categorized as particles with an aerodynamic diameter 

less than or equal to a nominal 2.5 micrometers (PM25-PRI), which includes both 

condensable particles (PM-CON) and filterable particles (PM25-FIL). In many cases 

states provide an estimate for PM25-FIL but not PM-CON. For the 2002 inventory suite, 

in this situation an AP-42 emission factor (USEPA 1997) was used to estimate PM-CON. 

Prior to development of the 2007 inventory suite, MARAMA commissioned a study of 

condensable emissions from a variety of unit types. (MARAMA 2009) These new 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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emission factors were used to augment the 2007 inventory suite. As a result, PM25-PRI 

emissions in the 2007 inventory suite cannot be compared to the 2002 suite. 

4.2.3 Transport Fraction 

The use of transport fractions to account for the difference in fugitive dust emissions and 

ambient concentrations was discussed in the area source sector part of this report (see 

Section 3.2.1). Similarly to area sources, no transport fractions were applied to point 

source emissions. 

4.2.1 New Jersey 2002 PM2.5 

New Jersey’s 2002 PM2.5 inventory was calculated using PM10 as a base and using the 

USEPA PM calculator. Actual PM2.5 emission reports began in 2003 and were more than 

double what was estimated. Therefore, the actual decreasing trend in PM2.5 from 2003 

into the future is not reflected in a comparison using 2002. 

4.3 OBSERVED REGIONAL POINT SOURCE TRENDS 

This section describes regional trends. The regional data drawn on is presented in Section 

8. In addition, Section 8 provides state level data, where the trends may be different than 

what holds true at the regional level. The regional data for point sources extracted from the 

larger Section 8 tables is summarized in Exhibit 4.1 and 4.2. Note that the three data 

sources are delineated by color differences: 

• Blue - 2002V3 inventory suite 

• Tan - 2007V3 inventory suite 

• White – CAMD 2010 actual data (where available) 

Exhibit 4.1 – EGU Point Source - Air Pollution Emissions between 2002 and 2020 

2002 2007 2010 2017 2018 2020

2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

NOX 453,395 338,488 214,623 --- 168,268 ---

PM2.5 20,670 44,921 ---

--- 51,109 ---

SO2 1,670,176 1,546,335 620,183 --- 365,024 ---

VOC 11,943 4,975 --- --- 4,344 ---

4.3.1 Nitrogen Oxides (NOX) 

EGU point sources account for approximately 15 percent of total regional NOX emissions 

in 2007. Regionally, EGU point source NOX emissions declined over 50 percent from 

2002 through 2010. Reductions are largely due to the installation of controls. To achieve 

the regional target for 2018, emissions will need to decline an additional 10 percent beyond 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 22 

what was achieved in 2010. Many EGU units are projected to shutdown or convert to 

more efficient natural gas units before 2018 which will result in substantial additional NOX

reductions. 

Exhibit 4.2 –Non-EGU Point - Air Pollution Emissions between 2002 and 2020 

2002 2007 2010 2017 2018 2020

2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

NOX 213,414 174,043 --- 169,188 174,218 169,668

PM2.5 33,948 29,880 --- 29,659 38,393 29,868

SO2 239,400 129,615 --- 112,784 201,478 112,828

VOC 92,562 68,003 --- 68,099 103,727 68,005

Non-EGU point sources account for approximately 8 percent of regional NOX emissions in 

2007. Regional non-EGU source NOX emissions are projected to fall below the 2018 

regional target by 2017. Trends vary by state, however. Reductions are largely due to unit 

shut-downs and the installation of controls. Without additional initiatives, emissions are 

projected to rise slightly between 2017 and 2020 but will still remain below the 2018 

visibility target in 2020. 

4.3.2 Sulfur Dioxide (SO2) 

EGU point sources account for approximately 80 percent of total regional SO2 emissions 

in 2007. Regionally, EGU point source SO2 emissions declined 60 percent between 2002 

and 2010. Reductions are largely due to the installation of controls. To achieve the target 

for 2018, emissions must decline an additional 15 percent beyond what was already 

achieved in 2010. Many EGU units are projected to shutdown or convert to natural gas 

before 2018 which will result in substantial additional SO2 reductions. 

Non-EGU point sources account for approximately 7 percent of regional SO2 emissions 

in 2007. Regional non-EGU source SO2 emissions are projected to be below the 2018 

target by 2017. Reductions are largely due to unit shut-downs and the installation of 

controls. Without additional initiatives, regional emissions are projected to rise slightly 

between 2017 and 2020 but will still remain below the regional 2018 visibility target in 

2020. With the transition to natural gas and ultra-low sulfur distillate fuels and lower 

sulfur content residual fuel, in the MANE-VU states, this sector can be expected to 

decrease emissions from 2002 and 2007 levels. 

4.3.3 Fine Particulate (PM2.5-Direct) 

EGU point sources account for approximately 10 percent of the total regional PM2.5

inventory in 2007. In general 2002 and 2018 estimates are lower than was estimated for 

the 2007 inventory suite as a result of a change of estimation methodology. In 2002 most 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 23 

states did not collect total direct PM2.5 emissions from EGUs. Rather they used the EPA 

PM-Calculator to estimate PM2.5 emissions as a proportion of PM10. In the 2007 

inventory suite states used a combination of source reported data and a new set of emission 

factors generated by MARAMA in a study of stack tests of similar units. (MARAMA 

2009) There is inadequate data to indicate a PM2.5 trend for this pollutant.

Non-EGU point sources account for approximately 10 percent of total regional PM2.5-

direct emissions in 2007. Regionally, non-EGU point source PM2.5-Direct emissions have 

declined 11 percent from 2002 to 2007. Reductions are largely due to unit shut-downs and 

the installation of controls. Regional emissions are already well below the target for 2018 

emission and are projected to drop further by 2017.

4.3.4 Volatile Organic Compounds (VOC) 

EGU point sources account for less than one percent of total regional VOC emissions in 

2007. There is inadequate data to indicate a VOC trend for this pollutant. 

Non-EGU point sources account for less than five percent of total regional VOC 

emissions in all inventoried years and this proportion is expected to remain approximately 

the same in future years. Regionally, non-EGU point source VOC emissions have declined 

28 percent from 2002 through 2007. Reductions are largely due to unit shut-downs and 

installation of controls. Regional emissions are already well below the target for 2018 

emissions. 

5.0 NONROAD MOBILE SOURCES INCLUDED IN NMIM 

5.1 BACKGROUND 

Non-road sources are mobile engine powered equipment operated off of public highways. 

Units include recreational marine vessels, recreational land-based vehicles, farm and 

construction machinery, lawn and garden equipment, aircraft ground support equipment, 

and rail maintenance equipment. This equipment is powered by diesel, gasoline, 

compressed natural gas, or liquefied petroleum gas engines. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Two data sources were combined in this study to establish an emission trend for the nonroad sector as follows: 

• 2002 MANE VU V3.3 modeling inventory with a projection to 2018 

• 2007 MARAMA V3 modeling inventory with projections to 2017, and 2020 

5.2 ISSUES ENCOUNTERED WITH NONROAD SECTOR DATA SETS 

For most states, the EPA-developed NMIM/NONROAD model was used in both 2002 and 

2007 inventory suites to estimate NONROAD sector emissions. While different versions 

of the model were used, with slightly different model adjustments, for the most part these 

differences did not change the resulting emission estimation substantially. The following 

sections describe the model adjustments used in the 2002 and 2007 modeling suites. 

5.2.1 2002 inventory NonRoad Modeling 

The NONROAD2005 model was used as a starting point for the 2002 inventory. Changes 

were made to the National County Database (NCD) database based on state review and 

comment. Complete documentation of the changes is available in the inventory 

documentation (MANE-VU 2006). A summary of the adjustments to the default NCD for 

the 2002 National Mobile Input Model (NMIM) model runs includes: 

• Adjustments to fuel characteristics (Reid Vapor Pressure, sulfur and oxygenate 

fractions) to better represent county-specific fuel characteristics in 2002; 

• Default diesel sulfur content values of 2457 parts per million (ppm) for land-based 

equipment, and 2767 ppm for recreational marine for all MANE VU counties. 

5.2.2 2007 inventory NonRoad modeling 

The NONROAD2008a (July 2009 NMIM20090504) and the NMIM County Database 

(version NCD20090531), were used as starting points for the 2007 inventory. Changes 

were made to the NCD20090531 based on state review and comment. Complete 

documentation of the changes is available in the inventory documentation (MANE-VU 

2011a). A summary of the adjustments to the default NMIM County Database for the 

2007 NMIM model runs includes: 

• Adjustments to fuel characteristics (Reid Vapor Pressure, sulfur and oxygenate 

fractions) to better represent county-specific fuel characteristics in 2007; 

• The housing and population data contained in the NONROAD model were updated 

using 2007 housing information and population estimates. 

• Recreational marine vessel populations were revised using population data 

provided by the National Marine Manufacturers Association (NMMA). Total state 

populations for each of the three major categories contained in the NONROAD 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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model (outboard, inboard/stern drive and personal watercraft) were provided. 

Because the population files used by the NONROAD model (and thus NMIM) 

were configured with population values for various horsepower categories, the 

fraction of the total for each marine vessel type in each horsepower category was 

determined from the NONROAD default population files. These fractions were 

then used to allocate the total state population obtained from NMMA to the various 

horsepower categories. 

• Airport ground Support: The Federal Aviation Administration’s Emissions and 

Dispersion Modeling System (EDMS) model was used to estimate airport ground 

support emissions. They were included in the area source sector. 

5.2.3 SCCs Included in Non-Road Sector 

MARAMA determined that a different set of SCCs were included in the 2002 versus the 

2007 non-road sector. Emissions for airport ground support equipment for 2002 and 2018 

were moved from non-road to the area source sector. In addition, in 2007 the Marine, Air 

and Rail (MAR) sector was separated from the non road sector, but this was not done in 

2002. Therefore, for this study, MARAMA separated out the 2002 and 2018 MAR data 

into a separate MAR sector. 

5.2.4 Future Year Emissions Projection 

For future year projections, the NMIM/NONROAD model applies controls to account for 

all USEPA non-road emission control programs. (USEPA 2011) Exhibit 5.1 is a summary 

of the emission control programs accounted for in the NMIM/NONROAD 2008a model 

that was used in the 2007 inventory suite. With one exception, all of these rules were also 

accounted for in the NMIM/NONROAD 2005 model. The only rule that is not accounted 

for in the 2005 version of NMIM/NONROAD is the final one listed in the table: 2008 

Control of Emissions from non-road Spark-Ignition Engines and Equipment. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Exhibit 5.1 Nonroad Control Programs Included in 2007 Inventory Suite 

Regulation Description 

Control of Air Pollution; 

Determination of Significance for 

Nonroad Sources and Emission 

Standards for New Nonroad 

Compression Ignition Engines At or 

Above 37 Kilowatts 

59 FR 31036 

June 17, 1994 

This rule establishes Tier 1 exhaust emission standards for 

HC, NOx, CO, and PM for nonroad compression-ignition 

(CI) engines ≥37kW (≥50hp). Marine engines are not 

included in this rule. The start dates and pollutants 

affected vary by hp category as follows: 

50-100 hp: Tier 1,1998; NOx only 

100-175 hp: Tier 1, 1997; NOx only 

175-750 hp: Tier 1, 1996; HC, CO, NOx, PM 

>750 hp: Tier 1, 2000; HC, CO, NOx, PM 

Emissions for New Nonroad SparkIgnition Engines at or Below 19 

Kilowatts; Final Rule

60 FR 34581 

July 3, 1995 

This rule establishes Phase 1 exhaust emission standards 

for HC, N NOx Ox, and CO for nonroad spark-ignition 

engines ≤19kW (≤25hp). This rule includes both handheld 

(HH) and non-hand-held (NHH) engines. The Phase 1 

standards become effective in 1997 for: 

 Class I NHH engines (<225cc), 

 Class II NHH engines (≥225cc), 

 Class III HH engines (<20cc), and 

 Class IV HH engines (≥20cc and <50cc). 

The Phase 1 standards become effective in 1998 for:

 Class V HH engines (≥50cc) 

Final Rule for New Gasoline SparkIgnition Marine Engines; Exemptions 

for New Nonroad CompressionIgnition Engines at or Above 37 

Kilowatts and New Nonroad SparkIgnition Engines at or Below 19 

Kilowatts

61 FR 52088 

October 4, 1996 

This rule establishes exhaust emission standards for HC+ 

NOx for personal watercraft and outboard (PWC/OB) 

marine SI engines. The standards are phased in from 

1998-2006. 

Control of Emissions of Air Pollution 

From Nonroad Diesel Engines

63 FR 56967 

October 23, 1998 

This final rule sets Tier 1 standards for engines under 50 

hp, phasing in from 1999 to 2000. It also phases in more 

stringent Tier 2 standards for all engine sizes from 2001 to 

2006, and yet more stringent Tier 3 standards for engines 

rated over 50 hp from 2006 to 2008. The Tier 2 standards 

apply to NMHC+ NOx, CO, and PM, whereas the Tier 3 

standards apply to NMHC+ NOx and CO. The start dates 

by hp category and tier are as follows: 

 hp<25: Tier 1,2000; Tier 2, 2005; no Tier 3 

 25-50 hp: Tier 1, 1999; Tier 2, 2004; no Tier 3 

 50-100 hp: Tier 2, 2004; Tier 3, 2008 

 100-175 hp: Tier 2, 2003; Tier 3, 2007 

 175-300 hp: Tier 2, 2003; Tier 3, 2006 

 300-600 hp: Tier 2, 2001, Tier 3, 2006 

 600-750 hp: Tier 2, 2002; Tier 3, 2006 

 >750 hp: Tier 2, 2006, no Tier 3 

This rule does not apply to marine diesel engines above 50 

hp. 

Phase 2: Emission Standards for 

New Nonroad Non-handheld Spark 

This rule establishes Phase 2 exhaust emission standards 

for HC+ NOx for nonroad non-handheld (NHH) spark-
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Regulation Description 

Ignition Engines At or Below 19 

Kilowatts

64 FR 15207 

March 30, 1999 

ignition engines ≤19kW (≤25hp). The Phase 2 standards 

for Class I NHH engines (<225cc) become effective on 

August 1, 2007 (or August 1, 2003 for any engine initially 

produced on or after that date). The Phase 2 standards for 

Class II NHH engines (≥225cc) are phased in from 2001-

2005. 

Phase 2: Emission Standards for 

New Nonroad Spark-Ignition 

Handheld Engines At or Below 19 

Kilowatts and Minor Amendments to 

Emission Requirements Applicable 

to Small Spark-Ignition Engines and 

Marine Spark-Ignition Engines; Final 

Rule

65 FR 24268 

April 25, 2000 

This rule establishes Phase 2 exhaust emission standards 

for HC+ NOx for nonroad handheld (HH) spark-ignition 

engines ≤19kW (≤25hp). The Phase 2 standards are 

phased in from 2002-2005 for Class III and Class IV

engines and are phased in from 2004-2007 for Class V 

engines. 

Control of Emissions From Nonroad 

Large Spark-Ignition Engines and 

Recreational Engines (Marine and 

Land-Based); Final Rule

67 FR 68241 

November 8, 2002 

This rule establishes exhaust and evaporative standards 

for several nonroad categories: 

1) Two tiers of emission standards are established for large 

spark-ignition engines over 19 kW. Tier 1 includes exhaust 

standards for HC+ NOx and CO and is phased in from 

2004-2006. Tier 2 becomes effective in 2007 and includes 

exhaust standards for HC+ NOx and CO, as along with 

evaporative controls affecting fuel line permeation, diurnal 

emissions and running loss emissions. 

2) Exhaust and evaporative emission standards are 

established for recreational vehicles, which include 

snowmobiles, off-highway motorcycles, and all-terrain 

vehicles (ATVs). For snowmobiles, HC and CO exhaust 

standards are phased-in from 2006-2012. For off-highway 

motorcycles, HC+ NOx and CO exhaust emission 

standards are phased in from 2006-2007. For ATVs, 

HC+NOx and CO exhaust emission standards are phased 

in from 2006-2007. Evaporative emission standards for 

fuel tank and hose permeation apply to all recreational 

vehicles beginning in 2008. 

3) Exhaust emission standards for HC+ NOx, CO, and PM 

for recreational marine diesel engines over 50 hp begin in 

2006-2009, depending on the engine displacement. These 

are “Tier 2” equivalent standards. 

Control of Emissions of Air Pollution 

From Nonroad Diesel Engines and 

Fuel; Final Rule (Clean Air Nonroad 

Diesel Rule – Tier 4)

69 FR 38958 

June 29, 2004 

This final rule sets Tier 4 exhaust standards for CI engines 

covering all hp categories (except marine and 

locomotives), and also regulates nonroad diesel fuel sulfur 

content. 

1) The Tier 4 start dates and pollutants affected vary by hp 

and tier as follows: 

 hp<25: 2008, PM only 

 25-50 hp: Tier 4 transitional, 2008, PM only; 

 Tier 4 final, 2013, NMHC+ NOx and PM 

 50-75 hp: Tier 4 transitional, 2008; PM only; 

 Tier 4 final, 2013, NMHC+ NOx and PM 

 75-175 hp: Tier 4 transitional, 2012, HC, NOx, and PM; 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Regulation Description 

 Tier 4 final, 2014, HC, NOx, PM 

 175-750 hp: Tier 4 transitional, 2011, HC, NOx, and PM; 

 Tier 4 final, 2014, HC, NOx, PM 

 >750 hp: Tier 4 transitional, 2011, HC, NOx, and PM; 

 Tier 4 final, 2015, HC, NOx, PM 

2) This rule reduces nonroad diesel fuel sulfur levels in two 

steps. First, starting in 2007, fuel sulfur levels in nonroad 

diesel fuel will be limited to a maximum of 500 ppm, the 

same as for current highway diesel fuel. Second, starting 

in 2010, fuel sulfur levels in most nonroad diesel fuel will 

be reduced to 15 ppm. 

Control of Emissions From Nonroad 

Spark-Ignition Engines and 

Equipment; Final Rule (Bond Rule)

73 FR 59034 

October 8, 2008 

This rule establishes exhaust and evaporative standards 

for small SI engines and marine SI engines: 

1) Phase 3 HC+ NOx exhaust emission standards are 

established for Class I NHH engines starting in 2012 and 

for Class II NHH engines starting in 2011. There are no 

new exhaust emission standards for handheld engines. 

New evaporative standards are adopted for both handheld 

and non handheld equipment. The new evaporative 

standards control fuel tank permeation, fuel hose 

permeation, and diffusion losses. The evaporative 

standards begin in 2012 for Class I NHH engines and 2011 

for Class II NHH engines. For handheld engines, the 

evaporative standards are phased-in from 2012-2016.

2) More stringent HC+ NOx and CO standards are 

established for marine SI PWC/OB engines beginning in 

2010. In addition, new exhaust HC+ NOx and CO 

standards are established for stern drive and inboard 

(SD/I) marine SI engines also beginning in 2010. High 

performance SD/I engines are subject to separate HC+ 

NOx and CO exhaust standards that are phased-in from 

2010-2011. New evaporative standards were also adopted 

for all marine SI engines that control fuel hose permeation, 

diurnal emissions, and fuel tank permeation emissions. 

The hose permeation, diurnal, and tank permeation 

standards take effect in 2009, 2010, and 2011, 

respectively. 

Source: (USEPA 2010) 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 29 

5.3 OBSERVED REGIONAL NONROAD SECTOR TRENDS 

This section describes regional trends. The regional data drawn on is presented in Section 

8. In addition, Section 8 provides state level data, where the trends may be different than 

what holds true at the regional level. The regional data for nonroad sources extracted from 

the larger Section 8 tables is summarized in Exhibit 5.2. Note that the three data sources 

are delineated by color differences: 

• Blue - 2002V3 inventory suite 

• Tan - 2007V3 inventory suite 

• White – CAMD 2010 actual data (where available) 

Exhibit 5.2 – Regional Nonroad Source - Emissions between 2002 and 2020 

2,002 2,007 2010 2,017 2,018 2,020

2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

NOX 289,392 263,931 --- 153,553 158,843 135,962

PM2.5 27,922 24,701 --- 16,536 15,952 14,421

SO2 24,774 14,167 --- 420 466 443

VOC 557,536 412,890 --- 244,126 364,980 222,226

5.3.1 Nitrogen Oxides (NOX) 

The non-road sector accounts for approximately 10 percent of regional NOX emissions in 

2007. Regional non-road sources NOX emissions are projected to trend downward through 

2020 and are projected to fall below the 2018 target by 2017. Reductions are due to the 

turnover of old engines and bringing newer, cleaner engines online that meet recent federal 

emissions standards. 

5.3.2 Sulfur Dioxide (SO2) 

The non-road sector accounts for less than one percent of regional SO2 emissions in 2007. 

While insignificant, non-road source SO2 emissions are projected to trend downward 

through 2020 and are projected to fall below the 2018 target by 2017. Reductions are due 

to reduced sulfur content in fuels. 

5.3.3 Fine Particulate (PM2.5 – Direct) 

The non-road sector accounts for approximately six percent of directly emitted regional 

fine particulate emissions in 2007. Regional non-road source PM2.5 emissions are 

projected to trend downward through 2020 and are projected to fall below the 2018 target 

by 2020. Reductions are due the reduced sulfur content in fuels and the turnover of old 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 30 

engines bringing newer, cleaner engines online that meet recent federal emissions 

standards. 

5.3.4 Volatile Organic Compounds (VOC) 

The non-road sector accounts for approximately 20 percent of regional VOC emissions in 

2007. Regional non-road source VOC emissions are projected to trend downward through 

2020 and are projected to fall below the 2018 target by 2017. Reductions are due to the 

turnover of old engines bringing newer, cleaner engines online that meet recent federal 

emissions standards. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 31 

6.0 MARINE VESSELS, AIRPORTS, AND RAILROADS 

6.1 BACKGROUND 

This category of sources is collectively referred to as the MAR (marine, airports, and 

railroads) sector. Although MAR sources are generally nonroad engines, estimation of 

these emissions are not included in the NONROAD model, therefore emission estimates 

and projections are developed as a separate effort. The MAR sector includes non-road 

engines associated with the following activities: 

• Marine Vessels - The Commercial Marine Vehicle (CMV) sector includes boats 

and ships used either directly or indirectly in the conduct of commerce or military 

activity. The majority of these vessels are powered by diesel engines that are either 

fueled with distillate or residual fuel oil blends.

• Airports - The aircraft sector includes all aircraft types used for public, private, 

and military purposes. This includes four types of aircraft 1) Commercial; 2) Air 

Taxis; 3) General Aviation; and 4) Military. Ground support equipment (GSE) and 

auxiliary power units (APU) are not included in this sector. Rather, they have been 

included in the area sector. 

• Railroads - The railroad sector includes railroad locomotives powered by dieselelectric engines. Locomotives are divided into Class I line haul, Class II/III line 

haul, commuter/passenger, and Class I yard. Rail maintenance equipment is 

included in this sector. 

Two data sources were combined in this study to establish an emission trend for the MAR 

sector as follows: 

• 2002 MANE VU V3.3 modeling inventory with a projection to 2018 

• 2007 MARAMA V3 modeling inventory with projections to 2017 and 2020 

6.2 ISSUES ENCOUNTERED WITH MAR SECTOR DATA SETS 

The methodology used to estimate MAR sources was significantly revised between 

development of the 2002 and the 2007 inventory suites. ERTAC prepared a study of rail 

emissions based on industry supplied activity data and new emission factors that was 

adopted by many states, and the USEPA contracted for a major new study to improve the 

airport inventory (USEPA 2009a). In the 2002 inventory suite, the methodologies used to 

estimate this category were as described in EPA’s “Documentation for Aircraft, 

Commercial Marine Vessel, Locomotive, and other Non-road Components of the National 

Emissions Inventory”. (USEPA, 2005) New studies by ERTAC (ERTAC 2009) and EPA 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 32 

(USEPA 2009) resulted in a reset to a generally higher emissions basis for NOX and VOC 

emissions in the 2007 inventory suite from the sector. At the same time, the trend for 

PM2.5 Direct and SO2 for the MAR sector remains largely unchanged. Details of the 

approach to each inventory are contained in the base and future documentation for each 

modeling suite. (Base: MANE-VU 2012a; MANE VU 2006) (Future MANE-VU 2012b, 

MANE-VU 2007). 

6.3 OBSERVED REGIONAL MAR SECTOR TREND 

This section describes regional trends. The regional data drawn on is presented in Section 

8. The regional data for MAR sources extracted from the larger Section 8 tables is 

summarized in Exhibit 6.1. Note that the three data sources are delineated by color 

differences: 

• Blue - 2002V3 inventory suite 

• Tan - 2007V3 inventory suite 

• White – CAMD 2010 actual data (where available) 

Exhibit 6.1 – Regional MAR Sources - Air Pollution Emissions between 2002 and 2020 

2002 2007 2010 2017 2018 2020

2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

NOX 137,733 173,855 --- 127,391 111,425 118,025

PM2.5 7,929 7,430 --- 3,906 7,927 3,503

SO2 32,123 30,318 --- 4,870 8,172 4,183

VOC 14,026 19,066 --- 17,057 14,962 16,962

6.3.1 Nitrogen Oxides (NOX) 

The MAR sector accounts for approximately 7 percent of regional NOX emissions in 2007. 

Estimated emissions for NOX are generally higher in the 2007 than the 2002 inventory 

suite because of a change in estimation methodology rather than any real change in 

emissions. Therefore, no conclusions can be drawn from the combined data set. However, 

both inventory suites project NOX from MAR sources to decrease in future years. 

Reductions are due to the turnover of old engines bringing newer, cleaner engines online 

that meet recent federal emissions standards. 

6.3.2 Sulfur Dioxide (SO2) 

The MAR sector accounts for only 1 to 2 percent of regional SO2 emissions in 2007. 

While insignificant, regional MAR sector SO2 emissions are projected to trend downward 

through 2020 and are projected to fall below the 2018 target by 2017. Reductions are 

primarily due to reduced sulfur content in fuels. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 33 

6.3.3 Fine Particulate (PM2.5 – Direct) 

The MAR sector accounts for only 1 to 2 percent of directly emitted fine particulate 

emissions in 2007. While insignificant, MAR source PM2.5-Direct emissions trend 

downward through 2020 and are projected to fall below the 2018 target by 2017. 

Reductions are primarily due to reduced sulfur content in fuels. 

6.3.4 Volatile Organic Compounds (VOC) 

The MAR sector accounts for only 1 percent of regional VOC emissions in 2007, and can 

be considered to be an insignificant portion of the inventory. Estimated regional emissions 

for VOC are generally higher in the 2007 than the 2002 inventory suite because of a 

change in estimation methodology rather than any real change in emissions. Therefore, no 

firm conclusions can be drawn from the combined data set. However, both inventory 

suites project VOC from MAR sources to decrease in future years. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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7.0 ONROAD MOBILE SOURCES 

7.1 BACKGROUND 

Onroad mobile sector sources are mobile engine driven equipment operated on public 

highways. Sources include cars, buses, trucks, and motorcycles. This equipment is 

powered by diesel, gasoline, and a variety of alternative fuels including compressed natural 

gas or liquefied petroleum gas. 

Two sources were combined in this study to establish an emission trend for the onroad 

mobile sector as follows: 

• 2002 MANE VU V3.3 modeling inventory with a projection to 2018 

• 2007 MARAMA V3 modeling inventory with projections to 2020. Unlike other 

sectors, no projection to 2017 was completed for mobile emissions. 

The calculation of mobile emissions is complex because emissions vary with ambient 

temperature, vehicle type, age, travel speeds, operating modes, and fuel volatility. For this 

reason, inventory models have been developed by USEPA to perform the numerous 

calculations to estimate emissions from vehicle exhaust, evaporative and brake and tire 

wear. For many years, the MOBILE model was used to estimate onroad emissions. The 

MOBILE model was updated many times with the last version being MOBILE6.2. The 

term “MOBILE6" is generally used to refer to any of the suite of released MOBILE 

versions. For regional air quality modeling purposes to account for temporal and spatial 

meteorological differences, the MOBILE6.2 model was implemented as part of the Sparse 

Matrix Operator Kernel Emissions (SMOKE) gridded emissions model. 

In recent years, USEPA has been developing a new model to estimate onroad mobile 

emissions called MOVES (MOtor Vehicle Emission Simulator). On March 2, 2010 EPA 

announced the release of MOVES2010 in the Federal Register (75 FR 9411). Starting in 

2010 MOVES became the required model for SIP modeling, replacing MOBILE6.2. EPA 

subsequently released two minor revisions -- MOVES2010a in September 2010 and 

MOVES2010b in April 2012. Both revisions enhance model performance but do not 

significantly affect the criteria pollutant emissions calculated using MOVES2010. To 

smooth the transition to the new model, USEPA developed software tools to convert 

MOBILE6.2 inputs for MOVES. In addition, MOVES includes a preprocessing tool called 

the County Data Manager (CDM) to convert spreadsheet based information to MySQL 

database files required by the MOVES model.
Emissions Trends Analysis for MANE-VU March 22, 2013 

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There are two ways of running the MOVES model and they are known as: 

• “Inventory” mode that provides emission estimates as mass, and 

• “Emissions rate” or “Lookup table” mode that produces lookup tables of emission 

rates as mass per unit activity. a version of MOVES is available that can be run 

within SMOKE to account for temporal and spatial meteorological differences for 

regional air quality modeling purposes. For SMOKE implementation, emission 

rate tables must first be developed for a wide range of meteorological conditions. 

For the 2007 and 2020 modeling inventories, MOVES was run in the emissions rate mode, 

which was necessary to be compatible with the regional air quality modeling. 

7.2 ISSUES WITH MOBILE SECTOR DATA SETS 

The shift from using MOBILE6.2 for the 2002 inventory suite, to using the MOVES model 

for the 2007 inventory suite to estimate onroad emissions represents a significant change in 

the estimation methodology. A large body of new research on emission factors; in addition 

to new source groupings were incorporated into the MOVES model. The effect on 

emissions, estimated by USEPA (USEPA 2009b), was expected to result in: 

• Increased NOX emission estimate by 5 percent 

• Minor but lower estimates of VOC emissions 

• Increased wintertime PM2.5 emissions estimates 

• Unchanged SO2 emissions estimates. 

7.2.1 2002 and 2018 inventory 

For the 2002 MANE-VU inventory and future projection year 2018, onroad mobile 

emissions were estimated using MOBILE6.2 as it was implemented in SMOKE. Details of 

the assumptions used are provided in the inventory documentation. (NESCAUM 2006b) 

7.2.2 2007 and 2020 inventory 

For the 2007 MARAMA V3 inventory and the future projection year 2020, onroad mobile 

emissions were estimated using the MOVES 2010a model run in the emission rate mode. 

To reduce run time, states grouped counties and identified a representative county to 

represent each group. County groupings and their representative counties remained within 

state lines. In addition, months were grouped by season and a single month was selected to 

represent each group. NESCAUM, Pennsylvania, New York and Virginia partnered to 

perform the runs for the region which resulted in a Version 1 of the mobile inventory. 

Version 1 was documented by Huiyan Yang of NESCAUM, who led the modeling effort. 

(NESCAUM 2011) 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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A number of revisions were made to Version 1. Input files were revised and SMOKEMOVES was rerun for the MANE VU region by Virginia DEQ for Delaware, Maryland 

and New Jersey. In addition, a systematic adjustment of all pollutants in all states and 

counties was made to revise the temperature used in Version 1. The temperature at 2 

meters was used for the revised estimates. No new MOVES runs were made to address 

this revision; rather emission rates were interpolated using Version 1 tables. After all of 

the adjustments were completed, a Version 2 of the mobile emissions inventory was 

prepared. Version 2 of the northeast MOVES mobile inventory is used in this analysis. 

Additional improvements may be made in the future if resources permit. 

7.3 OBSERVED REGIONAL ONROAD MOBILE SECTOR TREND 

This section describes regional trends. The regional data drawn on is presented in Section 

8. The regional data for onroad sources extracted from the larger Section 8 tables is 

summarized in Exhibit 6.1. Note that the three data sources are delineated by color 

differences: 

• Blue - 2002V3 inventory suite 

• Tan - 2007V3 inventory suite 

• White – CAMD 2010 actual data (where available) 

Exhibit 7.1 – Regional Mobile Onroad Sources - Air Pollution Emissions between 2002 

and 2020 

2002 2007 2010 2017 2018 2020

2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

NOX 1,308,235 1,175,916 ---

--- 303,956 471,558

PM2.5 22,108 45,616 ---

--- 9,189 28,365

SO2 40,092 8,974 ---

--- 8,756 7,202

VOC 789,560 600,638 --- --- 269,979 269,647

7.3.1 Nitrogen Oxides (NOX) 

The onroad mobile sector accounts for approximately 50 percent of 2007 regional NOX

emissions. Emissions in 2020 are estimated to be higher than 2018, however this is due to 

a change in estimation methodology rather than any real change in emissions. Because of 

the significant change in calculation methodology no conclusions can be drawn from the 

combined data set. However, both inventory suites show regional NOX from onroad 

mobile sources decreasing over time. Reductions are due to the turnover of old engines 

bringing newer, cleaner engines online that meet recent federal emissions standards. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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7.3.2 Sulfur Dioxide (SO2) 

The onroad mobile sector accounts for an insignificant portion of SO2 emissions 

accounting for less than one percent of regional SO2 emissions in 2007. Regional onroad 

mobile sector SO2 emissions trend downward through 2020 and are projected to fall below 

the 2018 target by 2020. Reductions are primarily due to reduced sulfur content in fuels. 

7.3.3 Fine Particulate (PM2.5 – Direct) 

The onroad mobile sector accounts for approximately 10 percent of directly emitted fine 

particulate emissions in the region in 2007. Estimated emissions for fine particles are 

generally higher in the 2007 than the 2002 inventory suite because of a change in 

estimation methodology rather than any real change in emissions. Therefore, no 

conclusions can be drawn from the combined data set. However, both inventory suites 

show regional fine particles from onroad mobile sources decreasing in future years. 

Reductions are due to the turnover of old engines bringing newer, cleaner engines online 

that meet recent federal emissions standards. 

7.3.4 Volatile organic compounds (VOC) 

The onroad mobile sector accounts for approximately 30 percent of regional VOC 

emissions in 2007. Estimated emissions for VOC are generally lower in the 2007 than the 

2002 inventory suite. However, the actual inventory percentage of VOC from the onroad 

sector is higher in 2007. Because of a change in estimation methodology no conclusions 

can be drawn from the combined data set. However, both inventory suites show regional 

VOC from onroad mobile sources decreasing in future years. These reductions are due to 

fleet turnover bringing cleaner cars into service that comply with significant federal rules. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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8.0 EMISSION SUMMARIES 

Exhibit 8.1 summarizes the MANE VU regional emission trend for NOX, SO2, PM2.5 and 

VOC by sector. Exhibits 8.2 to 8.12 provide the same information on a state basis. Color 

coding and footnotes have been added to distinguish between the three data sources used in 

the analysis. Blue columns are from the 2002 inventory suite, tan columns are from the 

2007 inventory suite and the white column is from CAMD 2010. PM25 and VOC 

emissions from EGUs are still under review by states and, therefore not provided in the 

table. Some general regional observations by pollutant include: 

NOX - Regional NOx emissions are dominated by two sectors: onroad mobile and 

EGU in all inventoried years. 

Recently measured EGU emissions tabulated for 2007 and 2010 indicate annual 

emissions from this sector are declining rapidly. In addition, EGU NOX is 

projected to decline further in future years for the 2002 inventory suites. The 2007 

inventory suite is incomplete for this category. 

The shift from MOBILE6 to MOVES represents a significant shift in methodology, 

which occurring between completion of the 2002 and 2007 inventory suite for 

mobile NOX emissions. Therefore, combining these data sets does not add 

understanding to the mobile NOX trend analysis. However, each individual suite 

shows a declining trend. 

Therefore, overall NOX emissions appear to be trending lower with some 

uncertainty due to changing mobile calculation methodologies and an incomplete 

EGU inventory. 

• PM2.5 - Directly emitted fine particle emissions are regionally dominated by the 

area sector and in particular residential wood combustion in all years inventoried. 

For this critical source, changes in both estimation methodology and emission 

factors for direct PM2.5 occurred between the 2002 and 2007 inventory suites. 

These changes result in generally lower emissions estimates for the 2007 inventory 

suite. Likewise, the methodology used to estimate smaller contributing sectors, 

namely EGU and mobile has also changed between 2002 and 2007. Therefore, 

combining these data sets does not add understanding to the PM2.5 trend analysis. 

Overall, the trend for directly emitted fine PM is highly uncertain, with some 

sectors remaining largely unchanged, while others, particularly engine-based 

sectors, are projected to decrease. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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• SO2 - Regional SO2 emissions are dominated by EGU emissions. As with NOX, 

regional EGU SO2 emissions in 2010 are significantly lower than were estimated 

for 2007. Further reductions are projected in the future for the 2002 inventory 

suite. SO2 emissions in 2007 were already below the estimate for 2018, well ahead 

of expectations. There is no significant impact of changing methodologies for any 

sector calculations. 

The combined evidence points towards a significant declining trend for SO2. 

• VOC - Regional VOC emissions are dominated by biogenic emissions which are 

estimated to remain unchanged in future years. The largest percentage of 

anthropogenic VOC emissions is from the area source sector in 2007 and in 

particular residential wood combustion in all years inventoried. For this critical 

source, changes in both estimation methodology and emission factors for VOC 

occurred between the 2002 and 2007 inventory suites. These changes result in 

generally lower emissions estimates for the 2007 inventory suite. In addition, the 

calculation methodology changed for mobile emissions, also a significant 

contributor of VOC emissions in the region. Therefore, combining these data sets 

does not add understanding to the VOC emission trend analysis. However, the 

individual inventories when evaluated separately, both indicate a declining trend 

for the most important sectors. 

• Overall, the trend for anthropogenic VOC emissions are projected to decrease in 

the future, primarily due to mobile and area source controls in being implemented 

between 2007 and 2020. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Exhibit 8.1 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

Regional Summary 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(4) 266,747 207,054 --- 194,832 263,954 194,868 

Nonroad MAR(4) 137,733 173,855 --- 127,391 111,425 118,025 

Nonroad NMIM(4) 289,392 263,931 --- 153,553 158,843 135,962 

Onroad Mobile(4) 1,308,235 1,175,916 --- --- 303,956 471,558 

Point EGU(2) 453,395 338,488 214,623 --- 168,268 --- 

Point nonEGU(3) 213,414 174,043 --- 169,188 174,218 169,668 

Total 2,668,916 2,333,286 --- --- 1,180,664 --- 

Direct PM2.5 (TPY)

Area(4) 332,676 259,938 --- 262,887 339,518 264,959 

Nonroad MAR(4) 7,929 7,430 --- 3,906 7,927 3,503 

Nonroad NMIM(4) 27,922 24,701 --- 16,536 15,952 14,421 

Onroad Mobile(4) 22,108 45,616 --- --- 9,189 28,365 

Point EGU(2) 20,670 44,921 --- --- 51,109 ---

Point nonEGU(3) 33,948 29,881 --- 29,659 38,393 29,868 

Total 445,253 412,486 --- --- 462,087 --- 

Sulfur Dioxide (TPY)

Area(4) 316,287 212,471 --- 119,215 190,437 116,511 

Nonroad MAR(4) 32,123 30,318 --- 4,870 8,172 4,183 

Nonroad NMIM(4) 24,774 14,167 --- 420 466 443 

Onroad Mobile(4) 40,092 8,974 --- --- 8,756 7,202 

Point EGU(2) 1,670,176 1,546,335 620,183 --- 365,024 --- 

Point nonEGU(3) 239,400 129,615 --- 112,784 201,478 112,828 

Total 2,322,851 1,941,879 --- --- 774,333 --- 

Volatile Organic Compounds (TPY)

Area(4) 1,366,735 784,233 --- 702,289 1,334,175 696,125 

Nonroad MAR(4) 14,026 19,066 --- 17,057 14,962 16,962 

Nonroad NMIM(4) 557,536 412,890 --- 244,126 364,980 222,226 

Onroad Mobile(4) 789,560 600,638 --- --- 269,979 269,647 

Point EGU(2) 11,943 4,975 --- --- 4,344 ---

Point nonEGU(3) 92,562 68,003 --- 68,099 103,727 68,005 

Total 2,832,364 1,889,805 --- --- 2,092,168 --- 

1) This trend is built from three sources: 

2002 V3 with future projection to 2018 (Blue Columns) 

2007 V3 with a projection to 2017 and 2020 (Tan Columns) 

CAMD actual 2010 emissions as reported to the US EPA CAMD (White Columns) 

(2) Data meets or exceeds target of 90% complete across all years for most states. Units with incomplete data 

for one or more years have been completed by states or have been removed so that a consistent set 

of data is presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory and TSD for most states. No revision to correct inconsistent 

methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Exhibit 8.2 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

Connecticut 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(4) 12,745 12,421 --- 11,101 11,821 11,048 

Nonroad MAR(4) 7,601 9,001 --- 5,934 6,475 5,344 

Nonroad NMIM(4) 17,802 16,019 --- 8,721 9,732 7,762 

Onroad Mobile(4) 68,816 53,860 --- --- 14,787 19,200 

Point EGU(2) 6,106 4,706 2,901 --- 2,809 --- 

Point nonEGU(3) 6,994 5,489 --- 7,951 7,448 8,307 

Total 120,065 101,496 --- --- 53,072 --- 

Direct PM2.5 (TPY)

Area(4) 14,251 10,606 --- 10,290 12,368 10,217 

Nonroad MAR(4) 221 391 --- 190 227 166 

Nonroad NMIM(4) 1,569 1,338 --- 919 906 815 

Onroad Mobile(4) 1,042 1,969 --- --- 500 978 

Point EGU(2) 468 815 --- --- 746 ---

Point nonEGU(3) 832 433 --- 483 902 493 

Total 18,383 15,552 --- --- 15,649 --- 

Sulfur Dioxide (TPY)

Area(4) 12,424 16,083 --- 12,943 3,398 12,401 

Nonroad MAR(4) 715 1,541 --- 239 787 156 

Nonroad NMIM(4) 1,366 799 --- 30 28 32 

Onroad Mobile(4) 1,667 401 --- --- 366 340 

Point EGU(2) 13,122 6,901 4,039 --- 6,443 --- 

Point nonEGU(3) 2,466 1,170 --- 1,212 2,371 1,228 

Total 31,760 26,895 --- --- 13,393 --- 

Volatile Organic Compounds (TPY)

Area(4) 87,308 57,253 --- 46,364 68,398 45,849 

Nonroad MAR(4) 371 752 --- 633 392 633 

Nonroad NMIM(4) 33,503 20,713 --- 11,797 20,299 10,980 

Onroad Mobile(4) 31,755 34,764 --- --- 10,768 11,494 

Point EGU(2) 396 251 --- --- 122 ---

Point nonEGU(3) 4,635 1,366 --- 1,469 3,796 1,491 

Total 157,968 115,099 --- --- 103,775 --- 

1) This trend is built from three sources: 

2002 V3 with future projection to 2018 (Blue Columns) 

2007 V3 with a projection to 2017 and 2020 (Tan Columns) 

CAMD actual 2010 emissions as reported to the US EPA CAMD (White Columns) 

(2) Data meets or exceeds target of 90% complete across all years. Units with incomplete data for one or 

more years have been completed by states or have been removed so that a consistent set of data is 

presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory and TSD. No revision to correct inconsistent methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Exhibit 8.3 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

Delaware 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(4) 2,617 2,238 --- 2,209 3,018 2,218 

Nonroad MAR(4) 10,437 6,284 --- 4,298 11,671 3,915 

Nonroad NMIM(4) 5,781 4,997 --- 3,095 2,956 2,723 

Onroad Mobile(4) 21,341 22,026 --- --- 5,917 21,258 

Point EGU(2) 8,610 10,004 4,346 --- 7,415 --- 

Point nonEGU(3) 8,084 5,692 --- 3,328 4,246 3,271 

Total 56,870 51,241 --- --- 35,223 --- 

Direct PM2.5 (TPY)

Area(4) 3,205 3,031 --- 3,131 3,426 3,212 

Nonroad MAR(4) 402 339 --- 118 532 95 

Nonroad NMIM(4) 523 453 --- 284 276 243 

Onroad Mobile(4) 415 670 --- --- 191 1,938 

Point EGU(2) 1,617 1,895 --- --- 2,313 ---

Point nonEGU(3) 2,059 1,219 --- 876 1,254 848 

Total 8,221 7,607 --- --- 7,992 --- 

Sulfur Dioxide (TPY)

Area(4) 1,589 1,144 --- 946 1,545 911 

Nonroad MAR(4) 3,471 2,139 --- 280 3,288 139 

Nonroad NMIM(4) 511 266 --- 7 8 7 

Onroad Mobile(4) 584 192 --- --- 128 380 

Point EGU(2) 30,626 32,699 14,499 --- 8,077 --- 

Point nonEGU(3) 43,131 10,391 --- 6,541 7,610 6,357 

Total 79,912 46,831 --- --- 20,656 --- 

Volatile Organic Compounds (TPY)

Area(4) 15,520 9,482 --- 8,631 13,066 8,673 

Nonroad MAR(4) 482 806 --- 748 539 742 

Nonroad NMIM(4) 7,527 7,157 --- 3,888 5,113 3,498 

Onroad Mobile(4) 10,564 10,289 --- --- 5,037 11,965 

Point EGU(2) 1,100 80 --- --- 112 ---

Point nonEGU(3) 4,674 3,413 --- 2,588 1,987 2,572 

Total 39,867 31,227 --- --- 25,854 --- 

1) This trend is built from three sources: 

2002 V3 with future projection to 2018 (Blue Columns) 

2007 V3 with a projection to 2017 and 2020 (Tan Columns) 

CAMD actual 2010 emissions as reported to the US EPA CAMD (White Columns) 

(2) Data meets or exceeds target of 90% complete across all years. Units with incomplete data for one or 

more years have been completed by states or have been removed so that a consistent set of data is 

presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory and TSD. No revision to correct inconsistent methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Exhibit 8.4 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

District of Columbia 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(2) 1,390 1,547 --- 1,560 2,229 1,592 

Nonroad MAR(4) 506 512 --- 358 372 326 

Nonroad NMIM(4) 3,065 2,787 --- 1,560 1,443 1,249 

Onroad Mobile(4) 8,902 8,724 --- --- 1,717 6,209 

Point EGU(2) 539 177 510 --- 103 --- 

Point nonEGU(3) 748 611 --- 636 368 650 

Total 15,150 14,358 --- --- 6,232 --- 

Direct PM2.5 (TPY)

Area(2) 1,140 1,542 --- 1,560 860 1,566 

Nonroad MAR(4) 11 11 --- 6 7 6 

Nonroad NMIM(4) 288 234 --- 132 117 102 

Onroad Mobile(4) 153 374 --- --- 58 590 

Point EGU(2) 46 17 --- --- 99 ---

Point nonEGU(3) 60 36 --- 21 98 21 

Total 1,699 2,214 --- --- 1,239 --- 

Sulfur Dioxide (TPY)

Area(2) 908 1,241 --- 995 522 953 

Nonroad MAR(4) 34 38 --- 0 2 0 

Nonroad NMIM(4) 341 196 --- 3 3 3 

Onroad Mobile(4) 271 88 --- --- 41 124 

Point EGU(2) 1,094 142 874 --- 83 --- 

Point nonEGU(3) 1,026 470 --- 379 553 380 

Total 3,674 2,175 --- --- 1,204 --- 

Volatile Organic Compounds (TPY)

Area(2) 5,705 5,568 --- 5,324 4,991 5,369 

Nonroad MAR(4) 20 35 --- 24 18 21 

Nonroad NMIM(4) 2,053 1,324 --- 749 1,351 710 

Onroad Mobile(4) 4,895 3,470 --- --- 1,797 3,326 

Point EGU(2) 9 6 --- --- 5 ---

Point nonEGU(3) 67 53 --- 54 71 54 

Total 12,750 10,456 --- --- 8,233 --- 

1) This trend is built from three sources: 

2002 V3 with future projection to 2018 (Blue Columns) 

2007 V3 with a projection to 2017 and 2020 (Tan Columns) 

CAMD actual 2010 emissions as reported to the US EPA CAMD (White Columns) 

(2) Data meets or exceeds target of 90% complete across all years. Units with incomplete data for one or 

more years have been completed by states or have been removed so that a consistent set of data is 

presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory and TSD. No revision to correct inconsistent methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Exhibit 8.5 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

Maine 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(4) 7,391 6,655 --- 5,960 7,050 5,851 

Nonroad MAR(4) 1,606 3,176 --- 2,500 1,583 2,341 

Nonroad NMIM(4) 8,184 7,425 --- 5,206 4,946 4,774 

Onroad Mobile(4) 54,687 36,922 --- --- 12,828 18,203 

Point EGU(2) 1,005 696 719 --- 1,827 --- 

Point nonEGU(3) 19,055 17,050 --- 20,373 13,688 20,422 

Total 91,928 71,924 --- --- 41,922 --- 

Direct PM2.5 (TPY)

Area(4) 32,776 12,526 --- 12,061 33,202 12,000 

Nonroad MAR(4) 196 452 --- 214 245 186 

Nonroad NMIM(4) 1,131 1,078 --- 755 732 656 

Onroad Mobile(4) 934 1,454 --- --- 266 2,564 

Point EGU(2) 398 125 --- --- 279 ---

Point nonEGU(3) 5,422 3,727 --- 3,628 5,622 3,623 

Total 40,857 19,362 --- --- 40,346 --- 

Sulfur Dioxide (TPY)

Area(4) 13,153 9,812 --- 7,870 4,940 7,609 

Nonroad MAR(4) 146 296 --- 33 63 28 

Nonroad NMIM(4) 767 415 --- 16 19 17 

Onroad Mobile(4) 1,804 377 --- --- 894 566 

Point EGU(2) 2,013 1,677 820 --- 7,422 --- 

Point nonEGU(3) 21,706 15,554 --- 12,655 18,492 12,535 

Total 39,589 28,131 --- --- 31,830 --- 

Volatile Organic Compounds (TPY)

Area(4) 100,624 31,966 --- 26,113 90,868 25,631 

Nonroad MAR(4) 407 448 --- 378 443 356 

Nonroad NMIM(4) 30,734 29,877 --- 19,301 21,543 16,727 

Onroad Mobile(4) 23,037 15,239 --- --- 10,414 18,052 

Point EGU(2) 843 32 --- --- 53 ---

Point nonEGU(3) 5,250 4,987 --- 4,733 5,598 4,561 

Total 160,895 82,549 --- --- 128,919 --- 

1) This trend is built from three sources: 

2002 V3 with future projection to 2018 (Blue Columns) 

2007 V3 with a projection to 2017 and 2020 (Tan Columns) 

CAMD actual 2010 emissions as reported to the US EPA CAMD (White Columns) 

(2) Data meets or exceeds target of 90% complete across all years. Units with incomplete data for one or 

more years have been completed by states or have been removed so that a consistent set of data is 

presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory and TSD. No revision to correct inconsistent methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 
Emissions Trends Analysis for MANE-VU March 22, 2013 

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Exhibit 8.6 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

Maryland 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(4) 15,842 10,312 --- 10,948 17,822 11,184 

Nonroad MAR(4) 9,706 22,727 --- 15,421 8,528 13,870 

Nonroad NMIM(4) 27,602 25,703 --- 15,340 15,653 13,466 

Onroad Mobile(4) 122,210 115,128 --- --- 28,097 45,474 

Point EGU(2) 77,062 54,686 22,610 --- 14,567 --- 

Point nonEGU(3) 19,317 20,204 --- 23,054 18,888 23,228 

Total 271,739 248,760 --- --- 103,555 --- 

Direct PM2.5 (TPY)

Area(4) 27,330 19,789 --- 20,884 30,158 21,201 

Nonroad MAR(4) 1,490 786 --- 382 1,662 324 

Nonroad NMIM(4) 2,856 2,470 --- 1,679 1,634 1,475 

Onroad Mobile(4) 2,200 3,955 --- --- 1,033 1,837 

Point EGU(2) 2,365 12,064 --- --- 6,431 ---

Point nonEGU(3) 2,649 3,245 --- 3,682 3,501 3,689 

Total 38,889 42,309 --- --- 44,419 --- 

Sulfur Dioxide (TPY)

Area(4) 12,412 5,960 --- 1,674 9,118 1,704 

Nonroad MAR(4) 5,375 2,482 --- 472 535 375 

Nonroad NMIM(4) 2,548 1,434 --- 36 42 38 

Onroad Mobile(4) 4,058 932 --- --- 656 977 

Point EGU(2) 277,263 294,426 51,635 --- 36,962 --- 

Point nonEGU(3) 16,544 10,957 --- 14,058 38,886 14,069 

Total 318,200 316,191 --- --- 86,199 --- 

Volatile Organic Compounds (TPY)

Area(4) 120,272 64,429 --- 57,045 104,624 57,042 

Nonroad MAR(4) 3,301 2,012 --- 1,659 3,867 1,642 

Nonroad NMIM(4) 53,011 35,155 --- 21,223 34,093 19,887 

Onroad Mobile(4) 61,847 55,628 --- --- 29,913 24,458 

Point EGU(2) 5,193 428 --- --- 575 ---

Point nonEGU(3) 5,714 4,583 --- 5,700 6,279 5,662 

Total 249,338 162,235 --- --- 179,351 --- 

1) This trend is built from three sources: 

2002 V3 with future projection to 2018 (Blue Columns) 

2007 V3 with a projection to 2017 and 2020 (Tan Columns) 

CAMD actual 2010 emissions as reported to the US EPA CAMD (White Columns) 

(2) Data meets or exceeds target of 90% complete across all years. Units with incomplete data for one or 

more years have been completed by states or have been removed so that a consistent set of data is 

presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory and TSD. No revision to correct inconsistent methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 46 

Exhibit 8.7 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

Massachusetts 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(4) 31,567 20,252 --- 18,984 36,296 19,151 

Nonroad MAR(4) 12,729 12,576 --- 9,101 10,949 8,540 

Nonroad NMIM(4) 29,830 26,464 --- 14,815 15,993 13,159 

Onroad Mobile(4) 143,368 73,441 --- --- 22,813 19,171 

Point EGU(2) 31,701 11,274 8,563 --- 18,157 --- 

Point nonEGU(3) 16,906 12,353 --- 14,308 20,090 14,788 

Total 266,101 156,360 --- --- 124,298 --- 

Direct PM2.5 (TPY)

Area(4) 42,082 30,438 --- 29,945 43,086 29,883 

Nonroad MAR(4) 569 651 --- 435 541 404 

Nonroad NMIM(4) 2,643 2,267 --- 1,539 1,505 1,354 

Onroad Mobile(4) 2,410 2,798 --- --- 840 1,475 

Point EGU(2) 1,491 2,433 --- --- 3,233 ---

Point nonEGU(3) 2,789 2,257 --- 2,250 3,332 2,277 

Total 51,984 40,844 --- --- 52,537 --- 

Sulfur Dioxide (TPY)

Area(4) 54,947 19,859 --- 15,996 8,357 15,357 

Nonroad MAR(4) 1,364 982 --- 290 395 278 

Nonroad NMIM(4) 2,403 1,376 --- 41 47 44 

Onroad Mobile(4) 4,399 767 --- --- 1,937 341 

Point EGU(2) 92,996 54,628 36,969 --- 47,927 --- 

Point nonEGU(3) 13,965 8,603 --- 7,713 16,544 7,719 

Total 170,074 86,215 --- --- 75,207 --- 

Volatile Organic Compounds (TPY)

Area(4) 162,039 85,870 --- 66,211 134,974 65,306 

Nonroad MAR(4) 1,915 1,926 --- 1,624 2,122 1,569 

Nonroad NMIM(4) 54,811 35,675 --- 20,509 34,172 18,989 

Onroad Mobile(4) 57,186 50,443 --- --- 17,056 16,414 

Point EGU(2) 584 486 --- --- 484 ---

Point nonEGU(3) 7,765 4,071 --- 4,081 10,356 3,999 

Total 284,301 178,471 --- --- 199,164 --- 

(1) This trend is built from three sources: 

2002 V3 with future projection to 2018 

2007 V3 with a projection to 2017 and 2020 

CAMD actual 2010 emissions as reported to the US EPA CAMD 

(2) Data meets or exceeds target of 90% complete across all years. Units with incomplete data for one or 

more years have been completed by states or have been removed so that a consistent set of data is 

presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory. No revision to correct inconsistent methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 47 

The SO2 emissions reported from area sources in Massachusetts match the value in the future year 

inventory documentation. This is because an error was corrected after final publication of the 2002 

Version 3 documentation. However, the error was not corrected in the modeling files. 

Exhibit 8.8 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

New Hampshire 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(4) 10,992 4,737 --- 4,152 12,243 4,111 

Nonroad MAR(4) 1,776 1,454 --- 1,306 1,723 1,286 

Nonroad NMIM(4) 8,104 8,548 --- 5,521 4,558 5,268 

Onroad Mobile(4) 33,283 33,923 --- --- 7,671 30,342 

Point EGU(2) 6,894 4,754 4,788 --- 3,089 --- 

Point nonEGU(3) 3,576 2,694 --- 3,388 1,086 3,467 

Total 64,625 56,110 --- --- 30,369 --- 

Direct PM2.5 (TPY)

Area(4) 17,534 8,623 --- 8,598 18,089 8,633 

Nonroad MAR(4) 95 62 --- 46 98 45 

Nonroad NMIM(4) 868 798 --- 558 534 493 

Onroad Mobile(4) 562 1,424 --- --- 263 3,010 

Point EGU(2) 1,973 602 --- --- 2,156 ---

Point nonEGU(3) 426 499 --- 1,169 940 1,179 

Total 21,459 12,008 --- --- 22,080 --- 

Sulfur Dioxide (TPY)

Area(4) 7,076 5,283 --- 4,176 3,123 3,991 

Nonroad MAR(4) 220 545 --- 81 226 46 

Nonroad NMIM(4) 668 440 --- 16 16 18 

Onroad Mobile(4) 777 275 --- --- 537 542 

Point EGU(2) 43,962 42,524 36,835 --- 10,766 --- 

Point nonEGU(3) 5,607 2,743 --- 2,655 3,086 2,658 

Total 58,310 51,810 --- --- 17,753 --- 

Volatile Organic Compounds (TPY)

Area(4) 65,374 22,343 --- 20,894 62,687 20,807 

Nonroad MAR(4) 142 195 --- 175 158 178 

Nonroad NMIM(4) 22,231 17,105 --- 11,028 14,807 9,783 

Onroad Mobile(4) 16,762 13,599 --- --- 6,564 14,629 

Point EGU(2) 101 110 --- --- 73 ---

Point nonEGU(3) 1,815 768 --- 1,445 998 1,431 

Total 106,425 54,120 --- --- 85,288 --- 

1) This trend is built from three sources: 

2002 V3 with future projection to 2018 (Blue Columns) 

2007 V3 with a projection to 2017 and 2020 (Tan Columns) 

CAMD actual 2010 emissions as reported to the US EPA CAMD (White Columns) 

(2) Data meets or exceeds target of 90% complete across all years. Units with incomplete data for one or 

more years have been completed by states or have been removed so that a consistent set of data is 

presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory and TSD. No revision to correct inconsistent methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 48 

Exhibit 8.9 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

New Jersey 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(3) 29,637 21,829 --- 23,340 21,829 23,339 

Nonroad MAR(4) 19,969 22,264 --- 20,390 17,575 19,335 

Nonroad NMIM(4) 40,583 36,340 --- 20,710 23,457 18,358 

Onroad Mobile(4) 152,076 135,339 --- --- 30,150 42,168 

Point EGU(2) 33,171 16,530 9,317 --- 12,984 --- 

Point nonEGU(3) 18,599 13,517 --- 11,879 17,091 12,092 

Total 294,035 245,819 --- --- 123,086 --- 

Direct PM2.5 (TPY)

Area(2) 19,071 18,961 --- 18,441 17,322 18,568 

Nonroad MAR(4) 1,047 866 --- 453 920 442 

Nonroad NMIM(4) 3,831 3,212 --- 2,216 2,214 1,964 

Onroad Mobile(4) 2,469 4,830 --- --- 1,140 2,167 

Point EGU(2) 1,504 4,410 --- --- 2,825 ---

Point nonEGU(3) 3,125 2,405 --- 2,527 4,203 2,568 

Total 31,047 34,685 --- --- 28,624 --- 

Sulfur Dioxide (TPY)

Area(2) 10,923 8,812 --- 706 4,374 704 

Nonroad MAR(4) 12,162 7,274 --- 937 765 1,009 

Nonroad NMIM(4) 3,345 1,905 --- 55 67 58 

Onroad Mobile(4) 3,649 917 --- --- 785 715 

Point EGU(2) 50,898 37,299 15,076 --- 15,918 --- 

Point nonEGU(3) 10,389 3,401 --- 2,591 7,800 2,645 

Total 91,366 59,608 --- --- 29,709 --- 

Volatile Organic Compounds (TPY)

Area(3) 168,931 96,243 --- 89,972 134,104 89,699 

Nonroad MAR(4) 2,020 3,355 --- 3,396 2,175 3,453 

Nonroad NMIM(4) 80,884 47,520 --- 27,429 51,435 25,801 

Onroad Mobile(4) 89,753 72,224 --- --- 31,415 24,123 

Point EGU(2) 1,091 383 --- --- 228 ---

Point nonEGU(3) 13,431 10,100 --- 10,080 19,902 10,035 

Total 356,110 229,826 --- --- 239,259 --- 

1) This trend is built from three sources: 

2002 V3 with future projection to 2018 (Blue Columns) 

2007 V3 with a projection to 2017 and 2020 (Tan Columns) 

CAMD actual 2010 emissions as reported to the US EPA CAMD (White Columns) 

(2) Data meets or exceeds target of 90% complete across all years. Units with incomplete data for one or 

more years have been completed by states or have been removed so that a consistent set of data is 

presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory and TSD. No revision to correct inconsistent methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 49 

Exhibit 8.10 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

New York 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(4) 99,463 72,053 --- 63,711 93,946 63,082 

Nonroad MAR(4) 31,278 55,900 --- 39,249 27,033 36,309 

Nonroad NMIM(4) 77,940 72,224 --- 43,456 45,059 38,842 

Onroad Mobile(4) 319,733 305,589 --- --- 78,365 129,829 

Point EGU(2) 84,206 46,826 27,018 --- 24,175 --- 

Point nonEGU(3) 26,058 23,080 --- 20,452 19,308 20,898 

Total 638,678 575,672 --- --- 287,886 --- 

Direct PM2.5 (TPY)

Area(4) 87,202 63,906 --- 68,408 84,231 70,000 

Nonroad MAR(4) 1,150 2,258 --- 1,134 1,090 986 

Nonroad NMIM(4) 7,623 6,710 --- 4,426 4,239 3,840 

Onroad Mobile(4) 5,898 14,225 --- --- 2,542 7,079 

Point EGU(2) 3,826 3,553 --- --- 9,258 ---

Point nonEGU(3) 3,115 2,212 --- 2,244 3,568 2,265 

Total 108,814 92,863 --- --- 104,928 --- 

Sulfur Dioxide (TPY)

Area(4) 130,484 70,044 --- 11,651 100,453 11,670 

Nonroad MAR(4) 5,959 10,639 --- 1,631 1,556 1,480 

Nonroad NMIM(4) 6,886 3,955 --- 118 129 126 

Onroad Mobile(4) 10,640 2,177 --- --- 1,794 1,866 

Point EGU(2) 265,268 106,081 47,968 --- 98,150 --- 

Point nonEGU(3) 15,815 14,696 --- 13,110 18,374 13,187 

Total 435,052 207,592 --- --- 220,456 --- 

Volatile Organic Compounds (TPY)

Area(4) 507,365 195,976 --- 184,269 440,927 183,721 

Nonroad MAR(4) 2,149 4,599 --- 4,045 2,345 4,001 

Nonroad NMIM(4) 155,390 114,923 --- 67,231 102,182 60,939 

Onroad Mobile(4) 287,845 161,385 --- --- 68,014 70,838 

Point EGU(2) 1,433 2,339 --- --- 731 ---

Point nonEGU(3) 9,870 8,379 --- 8,421 12,124 8,455 

Total 964,052 487,601 --- --- 626,323 --- 

1) This trend is built from three sources: 

2002 V3 with future projection to 2018 (Blue Columns) 

2007 V3 with a projection to 2017 and 2020 (Tan Columns) 

CAMD actual 2010 emissions as reported to the US EPA CAMD (White Columns) 

(2) Data meets or exceeds target of 90% complete across all years. Units with incomplete data for one or 

more years have been completed by states or have been removed so that a consistent set of data is 

presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory and TSD. No revision to correct inconsistent methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 50 

Exhibit 8.11 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

Pennsylvania 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(4) 47,991 47,545 --- 45,925 50,015 46,318 

Nonroad MAR(4) 41,622 35,853 --- 25,801 25,017 23,969 

Nonroad NMIM(4) 61,803 55,300 --- 30,422 30,567 26,143 

Onroad Mobile(4) 346,472 354,117 --- --- 91,516 119,917 

Point EGU(2) 203,175 187,981 133,095 --- 82,461 --- 

Point nonEGU(2) 91,129 71,961 --- 62,174 69,382 60,875 

Total 792,192 752,757 --- --- 348,958 --- 

Direct PM2.5 (TPY)

Area(4) 74,954 73,514 --- 73,054 82,649 73,226 

Nonroad MAR(4) 2,664 1,436 --- 806 2,516 736 

Nonroad NMIM(4) 5,747 5,338 --- 3,506 3,280 3,025 

Onroad Mobile(4) 5,331 12,461 --- --- 2,064 4,614 

Point EGU(2) 6,979 18,951 --- --- 23,588 ---

Point nonEGU(2) 13,036 13,609 --- 12,557 14,548 12,677 

Total 108,711 125,309 --- --- 128,645 --- 

Sulfur Dioxide (TPY)

Area(4) 63,725 66,584 --- 55,878 48,475 55,018 

Nonroad MAR(4) 2,629 3,698 --- 799 515 600 

Nonroad NMIM(4) 5,240 2,968 --- 84 92 86 

Onroad Mobile(4) 10,924 2,509 --- --- 1,436 896 

Point EGU(2) 892,918 969,936 411,451 --- 133,186 --- 

Point nonEGU(2) 105,189 59,813 --- 50,208 83,637 50,371 

Total 1,080,625 1,105,508 --- --- 267,341 --- 

Volatile Organic Compounds (TPY)

Area(4) 240,829 176,781 --- 164,863 230,033 162,374 

Nonroad MAR(4) 3,106 4,519 --- 3,949 2,780 3,941 

Nonroad NMIM(4) 99,180 86,383 --- 51,373 67,154 46,392 

Onroad Mobile(4) 176,090 163,693 --- --- 78,624 58,026 

Point EGU(2) 1,033 765 --- --- 1,916 ---

Point nonEGU(2) 36,358 28,987 --- 28,267 39,127 28,480 

Total 556,596 461,128 --- --- 419,634 --- 

1) This trend is built from three sources: 

2002 V3 with future projection to 2018 (Blue Columns) 

2007 V3 with a projection to 2017 and 2020 (Tan Columns) 

CAMD actual 2010 emissions as reported to the US EPA CAMD (White Columns) 

(2) Data meets or exceeds target of 90% complete across all years. Units with incomplete data for one or 

more years have been completed by states or have been removed so that a consistent set of data is 

presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory and TSD. No revision to correct inconsistent methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 51 

Exhibit 8.12 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

Rhode Island 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(4) 3,897 3,469 --- 3,301 4,252 3,329 

Nonroad MAR(4) 449 3,262 --- 2,196 437 1,956 

Nonroad NMIM(4) 4,541 4,388 --- 2,348 2,281 2,114 

Onroad Mobile(4) 16,677 18,775 --- --- 5,351 14,380 

Point EGU(2) 659 426 574 --- 576 --- 

Point nonEGU(3) 2,388 950 --- 854 2,158 862 

Total 28,611 31,270 --- --- 15,055 --- 

Direct PM2.5 (TPY)

Area(4) 2,065 3,896 --- 3,922 2,068 3,936 

Nonroad MAR(4) 74 128 --- 80 78 71 

Nonroad NMIM(4) 369 349 --- 216 224 191 

Onroad Mobile(4) 211 733 --- --- 148 1,781 

Point EGU(2) 28 56 --- --- 156 ---

Point nonEGU(3) 175 124 --- 124 178 128 

Total 2,922 5,286 --- --- 2,852 --- 

Sulfur Dioxide (TPY)

Area(4) 4,558 3,897 --- 3,222 1,368 3,108 

Nonroad MAR(4) 43 667 --- 95 35 59 

Nonroad NMIM(4) 333 211 --- 7 7 7 

Onroad Mobile(4) 425 161 --- --- 100 393 

Point EGU(2) 13 15 15 --- 55 --- 

Point nonEGU(3) 2,659 1,501 --- 1,415 2,998 1,437 

Total 8,031 6,452 --- --- 4,563 --- 

Volatile Organic Compounds (TPY)

Area(4) 31,403 24,214 --- 20,292 23,306 19,750 

Nonroad MAR(4) 84 184 --- 217 89 214 

Nonroad NMIM(4) 7,695 6,721 --- 2,885 5,299 2,657 

Onroad Mobile(4) 12,538 10,263 --- --- 6,305 12,806 

Point EGU(2) 37 73 --- --- 42 ---

Point nonEGU(3) 1,903 922 --- 945 1,781 963 

Total 53,659 42,377 --- --- 36,822 --- 

1) This trend is built from three sources: 

2002 V3 with future projection to 2018 (Blue Columns) 

2007 V3 with a projection to 2017 and 2020 (Tan Columns) 

CAMD actual 2010 emissions as reported to the US EPA CAMD (White Columns) 

(2) Data meets or exceeds target of 90% complete across all years. Units with incomplete data for one or 

more years have been completed by states or have been removed so that a consistent set of data is 

presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory and TSD. No revision to correct inconsistent methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 52 

Exhibit 8.13 Annual Air Pollutant Emission Trends by Sector between 2002 and 2020 

Vermont 

2002 2007 2010 2017 2018 2020

Data Source(1) 2002 V3 2007 V3 CAMD 2007 V3 2002 V3 2007 V3

Oxides of Nitrogen (TPY)

Area(4) 3,215 3,996 --- 3,641 3,433 3,645 

Nonroad MAR(4) 54 846 --- 837 62 834 

Nonroad NMIM(4) 4,156 3,736 --- 2,359 2,198 2,104 

Onroad Mobile(4) 20,670 18,072 --- --- 4,744 5,407 

Point EGU(2) 267 428 173 --- 105 --- 

Point nonEGU(3) 560 441 --- 791 466 808 

Total 28,922 27,519 --- --- 11,008 --- 

Direct PM2.5 (TPY)

Area(4) 11,065 13,106 --- 12,593 12,059 12,517 

Nonroad MAR(4) 10 50 --- 42 11 42 

Nonroad NMIM(4) 475 454 --- 306 291 263 

Onroad Mobile(4) 483 723 --- --- 144 332 

Point EGU(2) 8 0.1 --- --- 25 ---

Point nonEGU(3) 259 114 --- 98 246 97 

Total 12,300 14,447 --- --- 12,776 --- 

Sulfur Dioxide (TPY)

Area(4) 4,088 3,752 --- 3,158 4,764 3,085 

Nonroad MAR(4) 5 17 --- 13 5 13 

Nonroad NMIM(4) 366 202 --- 7 8 7 

Onroad Mobile(4) 894 178 --- --- 82 62 

Point EGU(2) 3 7 2 --- 35 --- 

Point nonEGU(3) 903 316 --- 248 1,127 243 

Total 6,259 4,472 --- --- 6,021 --- 

Volatile Organic Compounds (TPY)

Area(4) 23,266 14,108 --- 12,311 26,197 11,904 

Nonroad MAR(4) 29 235 --- 209 34 212 

Nonroad NMIM(4) 10,518 10,337 --- 6,713 7,532 5,863 

Onroad Mobile(4) 17,288 9,641 --- --- 4,072 3,516 

Point EGU(2) 122 22 --- --- 3 ---

Point nonEGU(3) 1,079 373 --- 316 1,707 302 

Total 52,302 34,716 --- --- 39,545 --- 

1) This trend is built from three sources: 

2002 V3 with future projection to 2018 (Blue Columns) 

2007 V3 with a projection to 2017 and 2020 (Tan Columns) 

CAMD actual 2010 emissions as reported to the US EPA CAMD (White Columns) 

(2) Data meets or exceeds target of 90% complete across all years. Units with incomplete data for one or 

more years have been completed by states or have been removed so that a consistent set of data is 

presented across years. Therefore totals are not identical to modeled inventory or TSD. 

(3) Data does not meet target of 90% complete across all years. Total represents all units completed by state. 

Totals are not identical to modeled inventory or TSD.

(4) Data identical to modeled inventory and TSD. No revision to correct inconsistent methodology. 

Nonroad MAR – includes commercial marine vessels, airports, and railroad locomotives 

Nonroad NMIM – includes equipment included in USEPA’s NMIM/NONROAD model 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 53 

9.0 ELECTRONIC FILES

Exhibit 9.1 lists the file names for all final deliverables. These files are stored on 

MARAMA ftp site available for access by states agency personnel. 

Exhibit 9.1 Emission Inventory Data Files 

File Name Description 

TSD_10_23_ETrend.docx Regional Emissions Trends Analysis for MANEVU 

All MAR Data All states All Pollutants.xlsx Complete set of data for MAR. This includes all 

MANE VU States and all pollutants. 

[State] EGU - Reviewed.xlsx An analysis of MANE VU NOX, SO2, PM25, 

and VOC emissions for electric generating units 

where the data has been reviewed and 

accepted by the state. Replace [State] with the 

abbreviation for the MANE VU state of interest. 

Example, for Delaware: DE_EGUReviewed.xlsx 

[State] EGU.xlsx An analysis of MANE VU NOX, SO2, PM25, 

and VOC emissions for electric generating units 

where the data has not yet been reviewed and 

accepted by the state. Replace [State] with the 

abbreviation for the MANE VU state of interest. 

Example, for New Jersey: NJ_EGUReviewed.xlsx 

[Pollutant] Area Tier 3 Analysis.xlsx An analysis of NOX emissions from area 

sources by MANE VU state, pollutant and year. 

This dataset breaks the data into Tiers up to 

Tier 3. Replace [Pollutant] with NOX, SO2, 

PM25 or SO2. Example NOX Area Tier3 

Analysis.xlsx. 

[State] NonEGU.xlsx An analysis for Non-EGUs by MANE VU state, 

this includes all pollutants for each MANE VU 

state. Replace [State] with the abbreviation for 

the MANE VU state of interest. Example for 

New York: NY NOnEGU.xlsx. 

Nonroad _Complete_Analysis.xlsx An analysis of Nonroad emission trend by 

pollutant, MANE VU state and year. 

Onroad Analysis.xlsx Summarized set of data for Onroad at the state 

level. This includes all pollutants for all MANE 

VU states and all years. 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 54 

10.0 REFERENCES 

CAMD 2010. Data downloaded on July 14th 2011. 

http://camddataandmaps.epa.gov/gdm/index.cfm?fuseaction=emissions.wizard 

EIA 2005. Annual Energy Outlook 2005 with Projections to 2025 

ftp://tonto.eia.doe.gov/forecasting/0383 (2005).pdf

EIA 2008. Annual Energy Outlook 2008 with Projections to 2030. 

http://www.eia.gov/oiaf/aeo/pdf/0383(2008).pdf 

EIA 2009. Annual Energy Outlook 2009 with Projections to 2030 

http://www.eia.gov/oiaf/aeo/pdf/0383(2009).pdf. 

EIA 2010. Annual Energy Outlook 2010 with Projections to 2035 

http://www.eia.gov/oiaf/aeo/pdf/0383(2010).pdf 

ERTAC 2009. ERTAC Rail Emissions Inventory Part 3: Class II and III Locomotives. 

Michelle Bergin, GA Environmental Protection Division Matthew Harrell, IL 

Environmental Protection Agency Mark Janssen, Lake Michigan Air Directors Consortium 

http://www.gaepd.org/air/airpermit/downloads/planningsupport/regdev/locomotives/class2

_3_doc2012.pdf

MANE-VU 2006. Prepared by E.H. Pechan & Associates, Inc. Technical Support 

Document for 2002 MANE-VU SIP Modeling Inventories, Version 3. November 2006. 

http://www.marama.org/technical-center/emissions-inventory/2002-inventory-andprojections/mane-vu-2002-emissions-inventory

MANE-VU 2007. Prepared by MACTEC Federal Programs, Inc. Development of 

Emission Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Nonroad 

Sources in the MANE-VU Region. February 2007. http://www.marama.org/technicalcenter/emissions-inventory/2002-inventory-and-projections/mane-vu-future-yearemissions-inventory

MANE-VU 2011a. Submitted by AMEC Environment & Infrastructure and SRA 

International, Inc. Technical Support Document for the Development of the 2007 

Emissions Inventory for Regional Air Quality Modeling in the Northeast/Mid-Atlantic 

Region Version 3.3. January 2011. http://www.marama.org/technical-center/emissionsinventory/2007-emissions-and-projections/version-3-2007-emissions-inventory 

MANE-VU 2011b. Submitted by AMEC Environment & Infrastructure and SRA 

International, Inc. Technical Support Document for the Development of the 2017/2020 

Emission Inventories for Regional Air Quality Modeling in the Northeast/Mid-Atlantic 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 55 

Region Version 3.3. January 2012. http://www.marama.org/technical-center/emissionsinventory/2007-emissions-and-projections/future-year-inventory-version-3 

MARAMA 2009a. Documentation of 2018 Emissions from Electric Generating Units in 

the Eastern United States for MANE-VU’s Regional Haze Modeling. 

http://marama.org/publications_folder/EGU_Projections_Summary_Final_Aug_2009.pdf

MARAMA 2009b. Emissions Factors for Condensable Particulate Matter Emissions 

From Electric Generating Units. 

http://marama.org/publications_folder/TechnicalMemo_EFs_for_CPM_from_EGUsRevise

d_with_PAcomments_20090129.pdf

MARAMA 2012. Combined Quality Assurance Project Plan (QAPP) and Work Plan.

MARAMA 2013. MANE-VU States Emissions Inventory Completeness by State, Sector 

and Pollutant.

NESCAUM 2006. Contributions to Regional Haze in the Northeast and Mid-Atlantic 

United States. http://des.nh.gov/organization/divisions/air/do/asab/rhp/documents/b.pdf

NESCAUM 2006b. Development of MANE-VU Mobile Source Projection Inventories 

for SMOKE/MOBILE6 Application. http://www.nescaum.org/documents/nescaummanevu-2002-and-future-onroad-inventory-20060620.pdf 

NESCAUM 2011. Development of MANE-VU Onroad Mobile Source Emissions for 

2007 and 2020 using MOVES. Prepared by Huiyan Yang of NESCAUM. 

http://www.nescaum.org/documents/nescaum-2007-2020-moves-modeling-tsd20120118.pdf 

USEPA 2005. Documentation For Aircraft, Commercial Marine Vessel, Locomotive, and 

other Nonroad Components of the National Emissions Inventory, Volume I – 

Methodology; EPA Contract No.: 68-D-02-063. Eastern Research Group (ERG) for E.H. 

Pechan & Associates, Inc. Prepared for the US EPA Emissions, Monitoring and Analysis 

Division, Sept. 30, 2005. 

ftp://ftp.epa.gov/EmisInventory/2002finalnei/documentation/mobile/2002nei_mobile_nonr

oad_methods.pdf

USEPA 2009a. Documentation for Aircraft Component of the National Emissions 

Inventory Methodology. ERG No.: 0245.02.302.001. For Laurel Driver of OAQPS. 

http://www.epa.gov/ttnchie1/net/aircraft_component.pdf

USEPA 2009b. Air Pollution Emissions from Highway Vehicles: What MOVES Tells Us. 

 M. Beardsley, D. Brzezinski, J. Koupal and J. Warila, US EPA OTAQ. Presented at the 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Page 56 

2009 USEPA Emissions Inventory Conference in Baltimore MD. 

http://www.epa.gov/ttn/chief/conference/ei18/session6/beardsley.pdf

USEPA 2010. U.S. Environmental Protection Agency. Transport Rule Emission Inventories 

Notice of Data Availability (NODA). Docket ID No. EPA-HQ-OAR-2009-0491. October 27, 

2010. TR_EI_NODA_relevant_CoSTpackets_and_inventories.xls 

ftp://ftp.epa.gov/EmisInventory/2005v4/tr_ei_noda 

USEPA 2011. U.S. Environmental Protection Agency. Emission Standards Reference Guide. 

http://www.epa.gov/oms/regs/nonroad/aviation/420f10013.pdf 

USEPA 1997. AP-42. Compilation of Air Pollutant Emission Factors. Fifth Edition. 

http://www.epa.gov/ttnchie1/ap42/ 
Emissions Trends Analysis for MANE-VU March 22, 2013 

Appendix C 

Appendix A 

State Review Workgroup 

State Emission Inventory Contact SIP Writer Contact

Delaware David Fees Jack Sipple

New Jersey Judy Rand Sharon Davis

Danny Wong Stella Oluwaseun-Apo

Ray Papalski

Rhode Island Karen Slattery Karen Slattery

Vermont Jeff Merrell Rich Periot

Connecticut Steven Potter Wendy Jacobs

New Hampshire David Healy Jeff Underhill

New York Ona Papageorgiou Diana Rivenburgh

Maine Kristen Colby Jeff Crawford

Pennsylvania Randy Bordner (stationary) Randy Bordner

Chris Trostle (mobile)

Maryland Roger Thunell Brian Hug

Mary Jane Rutkowski 

District of Columbia Jessica Daniels Jessica Daniels

Massachusetts Ken Santlal William Lamkin
NH Regional Haze 5-Year Progress Report

ATTACHMENT E

New Hampshire Administrative Rule Env-A 2302.02 

Emission Standards Applicable to Tangential-Firing, Dry-Bottom Boilers 

(Amended)
NH Regional Haze 5-Year Progress Report
NH Regional Haze 5-Year Progress Report

ATTACHMENT F

Evidence of Plan’s Adoption

[40 CFR Part 51, Appendix V, 2.1(b)]
NH Regional Haze 5-Year Progress Report

EVIDENCE OF PLAN’S ADOPTION

The cover letter, signed by the Governor’s designee, is evidence that the State of New Hampshire 

has adopted this revision to the State Implementation Plan (SIP). The only state requirement for 

SIP submittals is that, at least 30 days before the date of any public hearing related to SIP revisions, 

public notice shall be published in a newspaper of general daily statewide circulation (see Env-A 

204.01). Then, if a hearing is held, it must be conducted in accordance with Env-C 205 (see Env-A 

204.02). For evidence of the plan’s adoption in accordance with Env-A 204, see the Evidence of 

Public Notice and the Certification of Public Hearing (Attachments I and J).
NH Regional Haze 5-Year Progress Report

ATTACHMENT G

Evidence of Legal Authority

[40 CFR Part 51, Appendix V, 2.1(c)]

Laws of New Hampshire, RSA 125-C:6 

Powers and Duties of the Commissioner
NH Regional Haze 5-Year Progress Report

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NH Regional Haze 5-Year Progress Report
NH Regional Haze 5-Year Progress Report
NH Regional Haze 5-Year Progress Report

ATTACHMENT H

Evidence That New Hampshire Followed All Procedural Requirements

[40 CFR Part 51, Appendix V, 2.1(e)]
NH Regional Haze 5-Year Progress Report

EVIDENCE THAT NEW HAMPSHIRE FOLLOWED ALL PROCEDURAL

REQUIREMENTS

The only state requirement for SIP submittals is that, at least 30 days before the date of any public 

hearing related to SIP revisions, public notice shall be published in a newspaper of general daily 

statewide circulation (see Env-A 204.01). Then, if a hearing is held, it must be conducted in 

accordance with Env-C 205 (see Env-A 204.02). For evidence of the plan’s adoption in accordance 

with Env-A 204, see the Evidence of Public Notice and the Certification of Public Hearing 

(Attachments I and J).
NH Regional Haze 5-Year Progress Report

ATTACHMENT I

Evidence of Public Notice

[40 CFR Part 51, Appendix V, 2.1(f)]
NH Regional Haze 5-Year Progress Report

This page is intentionally left blank.
NH Regional Haze 5-Year Progress Report
NH Regional Haze 5-Year Progress Report

 
NH Regional Haze 5-Year Progress Report

ATTACHMENT J

Certification of Public Hearing

[40 CFR Part 51, Appendix V, 2.1(g)]
NH Regional Haze 5-Year Progress Report
NH Regional Haze 5-Year Progress Report

ATTACHMENT K

Compilation of Public Comments and NHDES’s Response Thereto

[40 CFR Part 51, Appendix V, 2.1(h)]
NH Regional Haze 5-Year Progress Report
NH Regional Haze 5-Year Progress Report
NH Regional Haze 5-Year Progress Report
NH Regional Haze 5-Year Progress Report
NH Regional Haze 5-Year Progress Report
NH Regional Haze 5-Year Progress Report
NH Regional Haze 5-Year Progress Report

NHDES’s Response to Comments on New Hampshire’s 

Regional Haze 5-Year Progress Report

The New Hampshire Department of Environmental Services (NHDES) held a public hearing on 

September 23, 2014, and provided a public comment period, extending from that date to October 3, 

2014, to accept testimony on New Hampshire’s draft Regional Haze Progress report and related 

amendments to administrative rule Env-A 2302.02. No members of the public attended the hearing, 

but letters containing written comments were received from three entities: the U.S. Environmental 

Protection Agency (EPA), the U.S. Department of the Interior, National Park Service (NPS); and the 

U.S. Department of Agriculture, Forest Service (FS). Copies of the letters are attached. The 

following is a summary of comments received and NHDES’s responses thereto.

Comment: EPA requested a technical clarification in the SIP Submittal (page v) and the correction 

of a typographical error in Section 12. EPA also encouraged New Hampshire to move forward with 

adoption of a low-sulfur fuel oil strategy as outlined in the MANE-VU Ask.

Response: NHDES has included the requested minor revisions in the final document. New 

Hampshire continues to be interested in pursuing a low-sulfur fuel oil strategy. Recently, the 

Oil Heat Council of New Hampshire requested that the New Hampshire legislature consider a 

bill in the 2015 legislative session to require the use of low-sulfur fuel oil throughout the state, 

effective in 2018. NHDES is actively engaged in the legislative process that would allow such a 

change to happen.

Comment: FS concurred that New Hampshire’s regional haze plan is sufficient in its current form 

to achieve the 2018 reasonable progress goals for visibility. FS also noted that the observed 2009-

2013 visibility data for New Hampshire’s Class I areas are already better than the 2018 reasonable 

progress goals. 

(No response is needed.)

Comment: NPS commented that New Hampshire has met the regulatory requirements for regional 

haze progress reports and that New Hampshire’s regional haze SIP is sufficient to meet the 2018 

reasonable progress goals at Class I areas in New Hampshire and neighboring states. NPS 

requested a few minor adjustments to the text. NPS also asked for an estimate of the magnitude of 

SO2 emission reductions that could result from adoption of a low-sulfur fuel oil strategy. 

Response: NHDES has made the requested revisions to the text. With respect to the low-sulfur 

fuel oil strategy, any estimate will depend on the assumptions applied. As a starting point, it 

may be assumed that 2012 was a typical year, in which state totals for distillate and residual fuel 

oil consumption for all sectors were 3,589,000 and 262,000 bbl, respectively.33 Further, it may 

be assumed that the reductions in fuel sulfur content from a low-S strategy would average 0.3% 

for distillate oil and 1.0% for residual oil. Under this specific scenario, SO2 emissions resulting 

from the combustion of both grades of fuel oil would be reduced by about 4,000 tons annually. 

The actual emission reductions could be smaller than this amount because current fuel oil in 

bulk storage already includes some lower-sulfur material whose exact specifications are 

unknown.

33 Source: U.S. Energy Information Administration (EIA). At the time of this estimate, 2012 is the most recent year for

which EIA annual data are available. See http://www.eia.gov/state/data.cfm?sid=NH#ConsumptionExpenditures.