Connecticut 

Regional Haze SIP Revision 

Final, November 2009 

Prepared by the 

Connecticut Department of Environmental Protection 

Member of the 

Mid-Atlantic/Northeast Visibility Union 
Connecticut Regional Haze Page i 

State Implementation Plan November 2009 

The Connecticut Department of Environmental Protection acknowledges the efforts and assistance of Mid-Atlantic/Northeast Visibility Union (MANE-VU), Mid-Atlantic Regional Air Management Association 

(MARAMA), Northeast States for Coordinated Air Use Management 

(NESCAUM) and all of the other MANE-VU states, especially New Hampshire, in the assembly of this State Implementation Plan. 
Connecticut Regional Haze ii

State Implementation Plan November 2009 

Table of Contents 

Executive Summary.....................................................................................xiii 

 Introduction ........................................................................................................................................... xiii 

 What is Regional Haze .......................................................................................................................... xiii 

General SIP Requirements .........................................................................................................xiv 

 1.0 The Regional Haze Issue .................................................................................................................. 1-1 

 1.1 Regional Haze Planning after Remand of CAIR ..................................................................... 1-2 

 1.2 The Basics of Haze.............................................................................................1-4 

 1.3 Anatomy of Regional Haze..............................................................................1-5 

 1.4 Regulatory Framework...................................................................................1-7 

 1.4.1 The Regional Haze Rule.......................................................................1-8 

 1.4.2 State Implementation Plan....................................................................1-9 

2.0 Areas Contributing to Regional Haze.....................................................................2-1 

 2.1 Class I Areas Affected by Connecticut’s Emission Sources.......................................2-1 

3.0 Regional Planning and Consultation..........................................................................................3-1 

 3.1 Mid-Atlantic/Northeast Visibility Union (MANE-VU)............................................3-1 

 3.2 Regional Consultation and the “Ask”.................................................................3-2 

 3.2.1 Connecticut-Specific Consultations........................................................3-7 

 3.2.2 The MANE-VU “Ask”........................................................................3-7 

 3.2.2.1 Meeting the “Ask”-MANE-VU States............................................3-8 

 3.2.2.2 Meeting the “Ask” – Connecticut.................................................3-8 

 3.2.2.3 Meeting the “Ask” – States outside MANE-VU................................3-9 

 3.2.3 Technical Ramifications of Differing Approaches.....................................3-10 

 3.2.4 Consultation Issues...........................................................................3-11 

 3.2.5 State/Tribe and Federal Land Manager Coordination...............................3-13 

 3.2.6 EPA Consultation and Review.............................................................3-15 

4.0 Assessment of Baseline and Natural Visibility Conditions..........................................4-1 

 4.1 Calculation Methodology...............................................................................4-1 

 4.2 MANE-VU Baseline Visibility.........................................................................4-3 

5.0 Air Monitoring Strategy....................................................................................5-1 
Connecticut Regional Haze iii 

State Implementation Plan November 2009 

 5.1 IMPROVE Program Objectives......................................................................5-1 

 5.2 Monitoring Requirements..............................................................................5-1 

 5.3 Monitoring Sites for MANE-VU Class I Areas....................................................5-2 

 5.3.1 Acadia National Park, Maine..............................................................5-3 

 5.3.2 Brigantine Wilderness, New Jersey.......................................................5-4 

 5.3.3 Great Gulf Wilderness, New Hampshire.................................................5-5 

 5.3.4 Presidential Range – Dry River Wilderness, New Hampshire......................5-6 

 5.3.5 Lye Brook Wilderness, Vermont..........................................................5-6 

 5.3.6 Moosehorn Wilderness, Maine............................................................5-8 

 5.3.7 Roosevelt Campobello International Park, New Brunswick, Canada.............5-9 

6.0 Emissions Inventory........................................................................................6-1 

 6.1 Baseline and Future-Year Emissions Inventories for Modeling...............................6-1 

 6.1.1 Baseline Inventory (2002)..................................................................6-2 

 6.1.2 Future-Year Emissions Inventories......................................................6-3 

 6.2 Emission Processor Selection and Configuration..................................................6-4 

 6.3 Inventories for Specific Source Categories.........................................................6-4 

 6.3.1 Stationary Point Sources...................................................................6-4 

 6.3.1.1 Electric Generating Units.........................................................6-5 

 6.3.1.2 Non-EGU Point Sources..........................................................6-5 

 6.3.2 Stationary Area Sources....................................................................6-6 

 6.3.3 Non-Road Mobile Sources..................................................................6-6 

 6.3.4 On-Road Mobile Sources...................................................................6-7 

 6.3.5 Biogenic Emission Sources.................................................................6-7 

 6.4 Summary of Emissions Inventories...................................................................6-8 

7.0 Air Quality Modeling.......................................................................................7-1 

 7.1 Meteorology.............................................................................................7-1 

 7.2 Data Preparations......................................................................................7-3 

 7.3 Model Platforms........................................................................................7-3 

 7.3.1 CMAQ..........................................................................................7-6 

 7.3.2 REMSAD......................................................................................7-6 

 7.3.3 CALGRID.....................................................................................7-6 

 7.3.4 CALPUFF.....................................................................................7-7 

8.0 Understanding the Sources of Haze-Causing Pollutants..........................................8-1 
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State Implementation Plan November 2009 

 8.1 Fine-Particle Pollutants...............................................................................8-1 

 8.2 Contributing States and Regions....................................................................8-2 

 8.3 Emission Sources and Characteristics............................................................8-10 

 8.3.1 Sulfur Dioxide (SO2)........................................................................8-10 

 8.3.2 Volatile Organic Compounds (VOC)....................................................8-12 

 8.3.3 Oxides of Nitrogen (NOx)...................................................................8-13 

 8.3.4 Primary Particulate Matter (PM10 and PM2.5)......................................8-15 

 8.3.5 Ammonia Emissions (NH3)...............................................................8-20 

9.0 Best Available Retrofit Technology (BART).........................................................9-1 

 9.1 BART Overview.......................................................................................9-1 

 9.2 Establishing a BART benchmark..................................................................9-3 

 9.2.1 Identification of BART-eligible sources................................................9-3 

 9.2.2 Determination of which BART-eligible sources are subject to BART...........9-7 

 9.2.3 Determination of what BART is for each source subject to BART...............9-7 

 9.2.4 Determination of overall visibility improvement anticipated from the 

 application of BART to all sources subject to BART...............................9-12 

 9.3 Connecticut’s Alternative Measures..............................................................9-14 

 9.3.1 Connecticut’s SO2 Program for Alternative BART.................................9-16 

 9.3.2 Connecticut’s NOx Program for Alternative BART................................9-25 

 9.3.3 BART Requirements for PM............................................................9-35 

 9.4 Reasonably Attributable Visibility Impairment................................................9-38 

 9.5 Conclusion.............................................................................................9-38 

10.0 Reasonable Progress Goals............................................................................10-1 

 10.1 Calculation of Uniform Rate of Progress......................................................10-1 

 10.2 Identification of (Additional) Reasonable Control Measures.............................10-2 

 10.2.1 Rationale for Determining Reasonable Controls....................................10-3 

 10.2.2 Best Available Retrofit Technology Controls........................................10-5 

 10.2.3 Low-Sulfur Fuel Strategy................................................................10-6 

 10.2.4 Targeted EGU Strategy for SO2 Reduction...........................................10-10 

 10.2.5 Non-EGU SO2 Emissions Reduction Strategy for Non-MANE-VU States.....10-16 

 10.3 Visibility Effects of (Additional) Reasonable Control Measures.........................10-23 

11.0 Long Term Strategy....................................................................................11-1 

 11.1 Overview of Strategy Development Process..................................................11-1 
Connecticut Regional Haze v 

State Implementation Plan November 2009 

 11.2 Technical Basis for Strategy Development.....................................................11-3 

 11.3 Existing Commitments to Reduce Emissions..................................................11-4 

 11.3.1 Controls on EGUs Expected by 2018..................................................11-5 

 11.3.2 Controls on Non-EGU Point Sources Expected by 2018...........................11-8 

 11.3.3 Controls on Area Sources Expected by 2018.........................................11-9 

 11.3.4 Controls on Mobile Sources Expected by 2018......................................11-10 

 11.3.5 Controls on Non-Road Sources Expected by 2018..................................11-11 

 11.4 Additional Reasonable Measures..................................................................11-12 

 11.4.1 BART.........................................................................................11-13 

 11.4.2 Low-Sulfur Oil Strategy..................................................................11-14 

 11.4.3 Targeted EGU Strategy..................................................................11-14 

 11.5 Source Retirement and Replacement Schedules................................................11-16 

 11.6 Measures to Mitigate the Impacts of Construction Activities................................11-17 

 11.7 Agricultural and Forestry Smoke Management................................................11-18 

 11.8 Estimated Effects of Long-Term Strategy on Visibility.......................................11-19 

 11.9 Connecticut’s Share of Emission Reductions....................................................11-24 

 11.10 Emission Limitations and Compliance Schedules.............................................11-27 

 11.11 Enforceability of Emission Limitations and Control Measures............................11-27 

 11.12 Prevention of Significant Deterioration.........................................................11-29 

Attachments

 
Connecticut Regional Haze vi

State Implementation Plan November 2009 

LIST OF FIGURES

Figure 1.1 Map of CAIR States......................................................................1-2 

Figure 1.2 Locations of Federally Protected Mandatory Class I Areas.........................1-8 

Figure 3.1 EPA-Designated Regional Planning Organizations (RPOs)........................3-1 

Figure 5.1 Map of Acadia National Park Showing Location of IMPROVE Monitor.........5-3 

Figure 5.2 Acadia National Park on Clear and Hazy Days.......................................5-4 

Figure 5.3 Map of Edwin B. Forsythe National Wildlife Refuge................................5-4 

Figure 5.4 Brigantine Wilderness on Clear and Hazy Days......................................5-5 

Figure 5.5 Map of Great Gulf and Presidential Range - Dry River Wilderness Areas Showing 

 Location of IMPROVE Monitor........................................................5-5 

Figure 5.6 Great Gulf Wilderness on Clear and Hazy Days.....................................5-6 

Figure 5.7 Presidential Range - Dry River Wilderness in Autumn..............................5-6 

Figure 5.8 Location of Lye Brook Wilderness IMPROVE Monitor............................5-7 

Figure 5.9 Aerial View of Lye Brook Wilderness IMPROVE Monitoring Site...............5-7 

Figure 5.10 Lye Brook Wilderness on Clear and Hazy Days.....................................5-8 

Figure 5.11 Moosehorn Wilderness on Clear and Hazy Days....................................5-8 

Figure 5.12 Map of the Baring and Edmunds Divisions of the Moosehorn National 

Wildlife Refuge Showing Location of IMPROVE Monitor........................5-9 

Figure 5.13 Map of Roosevelt Campobello International Park..................................5-10 

Figure 5.14 Roosevelt Campobello International Park on Clear and Hazy Days........5-10, 6-1 

Figure 7.1 Modeling Domains Used in MANE-VU Air Quality Modeling Studies 

with CMAQ................................................................................7-2 

Figure 7.2 Examples of Processed Model-Ready Emissions....................................7-5 

Figure 8.1 Contributions to PM2.5 Extinction at Seven Class I Areas...........................8-2 

Figure 8.2 Ranked Sulfate Contributions to Northeast Class I Receptors Based on 

Q/d Method (Mass Basis), by Location of Origin....................................8-4 

Figure 8.3 Ranked Sulfate Contributions to Mid-Atlantic Class I Receptors Based on 

Q/d Method (Mass Basis), by Location of Origin....................................8-4 

Figure 8.4 Modeled 2002 Contributions to Sulfate at Great Gulf, by State....................8-6 

Figure 8.5 Modeled 2002 Contributions to Sulfate at Brigantine, by State....................8-7 

Figure 8.6 Modeled 2002 Contributions to Sulfate at Lye Brook, by State....................8-7 

Figure 8.7 Modeled 2002 Contributions to Sulfate at Acadia, by State........................8-8 

Figure 8.8 Modeled 2002 Contributions to Sulfate at Moosehorn, by State...................8-8 

Figure 8.9 Modeled 2002 Contributions to Sulfate at Shenandoah, by State..................8-9 

Figure 8.10 Modeled 2002 Contributions to Sulfate at Dolly Sods, by State...................8-9 

Figure 8.11 Annual Sulfur Dioxide (SO2) Emissions, by State..................................8-10 

Figure 8.12 2002 Sulfur Dioxide (SO2) Emissions, by State.....................................8-11 
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State Implementation Plan November 2009 

Figure 8.13 2002 Volatile Organic Compound (VOC) Emissions, by State...................8-13 

Figure 8.14 Annual Nitrogen Oxide (NOX) Emissions, by State................................8-14 

Figure 8.15 2002 Nitrogen Oxide (NOX) Emissions, by State...................................8-15 

Figure 8.16 Primary Course Particle (PM10) Emissions, by State...............................8-16 

Figure 8.17 Primary Fine Particle (PM2.5) Emissions, by State..................................8-16 

Figure 8.18 Wood Smoke Source Regional Aggregations........................................8-18 

Figure 8.19 2002 Primary Coarse Particle (PM10) Emissions, by State.........................8-19 

Figure 8.20 2002 Primary Fine Particle (PM2.5) Emissions, by State...........................8-19 

Figure 8.21 Ammonia (NH3) Emissions, by State.................................................8-21 

Figure 8.22 2002 Ammonia (NH3) Emissions, by State..........................................8-21 

Figure 9.1 Connecticut BART Eligible Sources SO2 Emissions...............................9-6 

Figure 9.2 Connecticut BART Eligible Sources NOx Emissions..............................9-6 

Figure 9.3 2002 NEI v3 Point Source SO2 Emissions (TPY) and MANE-VU Class I 

 Areas.......................................................................................9-14 

Figure 9.4 Trends of SO2 Potential Emissions (TPY) from all NOx Budget Sources 

 (County Totals) and BART-Eligible Sources (2001, 

 2002, 2006)................................................................................9-22 

Figure 9.5 Trends of SO2 Potential Emissions (TPY) from all NOx Budget Sources 

 (County Totals) and BART-Eligible Sources (2001, 2002, 2006) (with 

 Class I areas)..............................................................................9-24 

Figure 9.6 Trends of NOx Potential Emissions (TPY) from all NOx Budget Sources 

 (County Totals) and BART-Eligible Sources (1994, 2002, 

 2006).......................................................................................9-30 

Figure 9.7 Trends of NOx Potential Emissions (TPY) from all NOx Budget Sources 

 (County Totals) and BART-Eligible Sources (1994, 2002, 

 2006 (with Class I areas)................................................................9-31 

Figure 10.1 Average Change in 24hr PM2.5 Due to Low-Sulfur Fuel Strategy (Phases 

1 & 2 Combined) Relative to OTB/OTW (values in μg/m3

).....................10-7 

Figure 10.2 Location of 167 EGU Stacks Contributing the Most to Visibility Impairment 

at MANE-VU Class I Areas..........................................................10-11 

Figure 10.3 Preliminary Estimate of Average Change in 24hr PM2.5 Resulting from a 

90 Percent Reduction in SO2 Emissions from the Top 167 EGU Stacks 

Affecting MANE-VU Class I Areas.................................................10-12 

Figure 10.4 Demonstration of Required and Reasonable Visibility Progress for 

20 Percent Worst Visibility Days....................................................10-24 

Figure 10.5 Demonstration of Required Maintenance or Improvement of Visibility 

for 20 Percent Best Visibility Days..................................................10-24 

Figure 11.1 Expected Visibility Improvement at Great Gulf Wilderness Based on 

Most Recent Projections...............................................................11-22 
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State Implementation Plan November 2009 

Figure 11.2 Expected Visibility Improvement at Acadia National Park Based on Most 

Recent Projections.....................................................................11-22 

Figure 11.3 Expected Visibility Improvement at Brigantine National Wildlife Refuge 

Based on Most Recent Projections...................................................11-23 

Figure 11.4 Expected Visibility Improvement at Lye Brook Wilderness Based on Most 

Recent Projections.....................................................................11-23 

Figure 11.5 Expected Visibility Improvement at Moosehorn National Wildlife Refuge 

Based on Most Recent Projections...................................................11-24 
Connecticut Regional Haze ix

State Implementation Plan November 2009 

LIST OF TABLES 

Table 2.1 Connecticut’s Contributions to Total Annual Average Sulfate Impact (Percent, 

Mass Basis) at Eastern Class I Areas in 2002.........................................2-2 

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

Annual Sulfate Impacts at Northeast Class I Areas (REMSAD)...................2-3 

Table 3.1 MANE-VU Members.....................................................................3-2 

Table 3.2 MANE-VU Consultation Principles for Regional Haze Planning..................3-4 

Table 3.3 Summary of MANE-VU’s Consultations on Regional Haze Planning............3-6 

Table 3.4 Class I Area States Requesting Consultation with Connecticut....................3-7 

Table 4.1 IMPROVE Monitors for MANE-VU Class I Areas.................................4-1 

Table 4.2 Summary of Baseline Visibility and Natural Visibility Conditions for the 

20 Percent Best and 20 Percent Worst Visibility Days at MANE-VU 

Class I Areas..............................................................................4-3 

Table 6.1 Connecticut 2002 Emissions Inventory Summary....................................6-8 

Table 6.2 Connecticut 2018 RPG (Best and Final) Emissions Inventory Summary.........6-8 

Table 8.1 Percent Contributions (Mass Basis) of Individual States and Regions to 

Total Annual Sulfate Impacts at Northeast Class I Areas (REMSAD)............8-3 

Table 8.2 MANE-VU 1990, 1996 and 2002 SO2 Point Source Emissions (tpy)............8-11 

Table 9.1 Initial list of BART-Eligible Sources in Connecticut................................9-3 

Table 9.2 Final list of BART-eligible sources in Connecticut..................................9-5 

Table 9.3 MANE-VU BART workgroup recommended BART emission limits for non- 

 CAIR EGUs and industrial boilers....................................................9-12 

Table 9.4 Universe of Sources Addressed in Connecticut’s SO2 and NOx Programs 

 for Alternative BART (Post-2002 NOx Budget Program Source, Unit ID, 

 Location, Size)...........................................................................9-15 

Table 9.5 SO2 Annual Potential Emissions @8760 Hours (tpy)...............................9-19 

Table 9.6 SO2 Daily Potential Emissions @24 Hours (tpd)....................................9-20 

Table 9.7 SO2 Actual Annual Emissions (tpy)...................................................9-21 

Table 9.8 Comparison of SO2 Potential Emissions and Reductions since 2002 from all 

 Post-2002 NOx Budget Program sources vs. BART-eligible sources alone 

 (tpy).......................................................................................9-23 

Table 9.9 Comparison of SO2 Actual Emissions and Reductions since 2001 from all 

 Post-2002 NOx Budget Program sources vs. BART-eligible sources alone 

 (tpy).......................................................................................9-23 

Table 9.10 Historical NOx limits for BART-eligible Units (lb/MMBtu)......................9-26 

Table 9.11 NOx Ozone Season Allowances Allocated to BART-eligible Units..............9-27 

Table 9.12 Potential and Actual NOx Emissions from all Post-2002 NOx Budget Program 

Units (tpy).................................................................................9-29 

Table 9.13 NOx Potential Emissions (tpy)..........................................................9-32 
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State Implementation Plan November 2009 

Table 9.14 NOx Potential Emissions (tons per day)..............................................9-33 

Table 9.15 NOx Actual Emissions (tpy)............................................................9-33 

Table 9.16 Comparison of NOx Potential Emissions and Reductions since 2002 from 

 all Post-2002 NOx Budget Program sources vs. BART-eligible sources 

 alone (tpy)................................................................................9-34 

Table 9.17 Comparison of NOx Actual Emissions and Reductions since 1994 from all 

 Post-2002 NOx Budget Program sources vs. BART-eligible sources 

 alone (tpy)................................................................................9-34 

Table 9.18 Registration/Permit Status and Existing Primary PM Controls at BART-eligible 

Units...................................................................................... 9-35 

Table 9.19 MANE-VU modeling of individual unit emissions for 2002.....................9-36 

Table 9.20 Cost of PM Controls and 2005 Actual PM Emissions..............................9-37 

Table 10.1 Uniform Rate of Progress Calculation (all values in deciviews).................10-2 

Table 10.2 Summary of Results from Four-Factor Analysis of Different Source 

 Categories................................................................................10-4 

Table 10.3 Estimated Emissions from BART-Eligible Facilities in MANE-VU States 

(Facilities Likely to be Controlled as a Result of BART Alone).................10-5 

Table 10.4 Estimated Cost Ranges for SO2 Control Options for Coal-Fired EGU Boilers 

(2006 dollars per ton of SO2 removed)..............................................10-14 

Table 10.5 Available SO2 Control Options for ICI Boilers....................................10-18 

Table 10.6 Estimated Costs of Dry Sorbent Injection (DSI) for ICI Boilers 

 (2006 dollars)...........................................................................10-20 

Table 10.7 Estimated Costs of Flue Gas Desulfurization for ICI Boilers 

 (2006 dollars)...........................................................................10-21 

Table 11.1 Retired EGUs...........................................................................11-16 

Table 11.2 SO2 Emissions from Point, Area, and Mobile Sources in Connecticut.........11-25 

Table 11.3 SO2 Emissions from Point, Area, and Mobile Sources in all of MANE-VU...11-26 
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State Implementation Plan November 2009 

LIST OF ATTACHMENTS 

ATTACHMENT A – EPA Regional Haze Checklist 

ATTACHMENT B – MANE-VU Contribution Assessment 

ATTACHMENT C – Inter-RPO State/Tribal and FLM Consultation Framework 

ATTACHMENT D – Consultation Summaries and Other Documentation 

ATTACHMENT E – The MANE-VU “Ask” 

ATTACHMENT F – Comments from VISTAS and West Virginia Department of 

Environmental Protection 

ATTACHMENT G – MANE-VU Modeling for Reasonable Progress Goals 

ATTACHMENT H – Documentation of 2018 Emissions from EGUs in the Eastern United 

States 

ATTACHMENT I – Comments from Federal Land Managers and EPA (with responses) 

ATTACHMENT J – Comments from Other Stakeholders 

ATTACHMENT K – MANE-VU Natural Background Visibility Conditions 

ATTACHMENT L – MANE-VU Baseline and Natural Background Visibility Conditions 

ATTACHMENT M – Technical Support Document for 20002 MANE-VU SIP Modeling 

Inventories, Version 3 

ATTACHMENT N – Development of Emission Projections for 2009, 2012, and 2018 for 

NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region 

ATTACHMENT O – Development of MANE-VU Mobile Source Projection Inventories for 

SMOKE/MOBILE6 Application 

ATTACHMENT P – NYSDEC Technical Support Document TSD-1c 

ATTACHMENT Q – MANE-VU 2018 Visibility Projections 

ATTACHMENT R – NYSDEC Technical Support Document TSD-1a 

ATTACHMENT S – NYSDEC Technical Support Document TSD-1e 

ATTACHMENT T – NYSDEC Technical Support Document TSD-1d 

ATTACHMENT U – CALGRID Modeling Protocol 

ATTACHMENT V – Technical Support Document on Agricultural and Forestry Smoke 

Management in the MANE-VU Region 

ATTACHMENT W – MANE-VU Five-Factor Analysis of BART-Eligible Sources 

ATTACHMENT X – BART Equivalency Demonstration for Sources in Connecticut 

(including modeling results) 

ATTACHMENT Y – Assessment of Reasonable Progress for Regional Haze in MANE-VU 

Class I Areas 

ATTACHMENT Z – Assessment of Control Technology Options for BART-Eligible 

Sources 

ATTACHMENT AA – Low-Sulfur Heating Oil in the Northeast States 

ATTACHMENT BB – Comparison of CAIR and CAIR Plus Proposal Using the Integrated 

Planning Model (IPM®) 
Connecticut Regional Haze xii 

State Implementation Plan November 2009 

ATTACHMENT CC – The Nature of Fine Particle and Regional Haze Air Quality Problems 

in the MANE-VU Region 

ATTACHMENT DD – Technical Support Document on Measures to Mitigate Visibility 

Impacts of Construction Activities in the MANE-VU Region 

ATTACHMENT EE - Benefits Mapping and Analysis Program (BENMAP) 

ATTACHMENT FF - Connecticut Smoke Management Policy Documentation 

ATTACHMENT GG – Connecticut General Statute section 16a-21a 
Connecticut Regional Haze xiii 

State Implementation Plan November 2009 

Executive Summary 

Introduction 

State and federal air quality regulators have been challenged with developing multi-pollutant 

control programs due to the synergistic impacts of pollutants such as nitrogen oxides (NOx), 

sulfur dioxide (SO2), particulate matter (PM) and volatile organic compounds (VOC) on 

attainment of the ozone and PM2.5 national ambient air quality standards (NAAQS) as well as 

on human health. In addition to requirements to maintain and meet NAAQS, states are also 

charged with reducing exposure to air toxics, eliminating a type of visibility impairment known 

as regional haze by 2064, and mitigating greenhouse gas emissions that contribute to global 

climate change. 

In order to accomplish such diverse tasks, many emission sectors including energy, 

transportation, industrial, residential, commercial and agricultural must engage in control 

strategies. Within these sectors, areas which are likely to achieve emissions reductions in 

Connecticut include electric generating units (EGUs), diesel trucks, stationary diesel engines, 

outdoor wood boilers, industrial/commercial/institutional (ICI) boilers, residential heating, and 

light duty vehicles. Emission reductions achieved by lowering fuel sulfur content, instituting 

energy efficiency measures, implementing a high electric demand day program and moving 

towards reductions beyond the federal NOx cap-and-trade programs are other possible areas for 

emission reductions. 

While the context of this document specifically addresses regional haze state implementation 

plan (SIP) requirements, improving overall air quality and meeting numerous goals with 

limited resources will require a multi-pollutant approach. Indeed, regional haze is impacted by 

multiple visibility impairing pollutants, including SO2, NOx and PM. Multi-pollutant actions 

taken to reach regional haze reduction goals will positively influence on several air quality 

initiatives. In addition, the January 2008 Benefits Mapping and Analysis Program (BENMAP) 

study prepared by Northeast States for Coordinated Air Use Management (NESCAUM) shows 

that programs designed to reduce regional haze will result in billions of dollars in public health 

benefits (Attachment EE). 

What is Regional Haze? 

Regional haze is visibility-impairing pollution produced across a broad geographic area by 
Connecticut Regional Haze xiv 

State Implementation Plan November 2009 

sources and activities emitting fine particles and their precursors. Such fine particles are 

comprised mainly of sulfates, nitrates, organic carbon, elemental carbon and soil dust. 

Congress adopted the visibility provisions in the Clean Air Act (CAA) in order to protect areas 

of scenic significance at 156 mandatory Class I Federal areas (Class I areas), which include 

certain national parks, wilderness areas and national memorial parks, and international parks. 

General SIP Requirements 

The Environmental Protection Agency (EPA) requires states to submit regional haze SIPs that 

describe the states’ measures for meeting the national goal of a return to natural visibility 

conditions at Class I areas by 2064. States with Class I areas must set reasonable progress 

goals for achieving and maintaining natural visibility conditions in their SIPs. Connecticut 

does not contain any Class I areas. States impacting Class I areas must submit SIPs detailing 

anticipated actions taken in order to meet reasonable progress goals, as well as explaining the 

long-term strategy, including enforceable emissions limitations, compliance schedules, and 

other measures for meeting this long-term return to natural visibility goal. Regional haze SIPs 

are also required to include calculations of baseline and natural visibility conditions as well as 

monitoring strategies for tracking reasonable progress. Finally, regional haze SIPs must 

include a determination of Best Available Retrofit Technology (BART) for sources of a certain 

size or emissions profile that began operating during a specific timeframe. In the future, states 

must submit revisions to the regional haze SIP every 5 years evaluating progress toward 

meeting reasonable progress goals and also updating the long-term strategy in 2018 as well as 

every 10 years thereafter. 
Connecticut Regional Haze Page 1-1 

State Implementation Plan November 2009 

1.0 THE REGIONAL HAZE ISSUE 

In 1999, the Environmental Protection Agency (EPA) issued regulations to improve visibility 

in 156 national parks and wilderness areas across the United States. The affected areas 

include many of our best known natural places, including the Grand Canyon, Yosemite, 

Yellowstone, Mount Rainier, Shenandoah, the Great Smokies, Acadia, and the Everglades. 

These regulations address visibility impairment in the form of regional haze. 

Haze is an atmospheric phenomenon that obscures the clarity, color, texture, and form of what 

we see. It is caused primarily by anthropogenic (manmade) pollutants but can also be caused 

by a number of natural phenomena, including forest fires, dust storms, and sea spray. Some 

haze-causing pollutants are emitted directly to the atmosphere by anthropogenic emission 

sources such as electric power plants, factories, automobiles, construction activities, and 

agricultural burning. Others occur when gases emitted to the air (haze precursors) interact to 

form new particles that are carried downwind of the original source. 

Emissions from these activities generally span broad geographic areas and can be transported 

hundreds or thousands of miles. Consequently, regional haze occurs in every part of the 

nation. Because of the regional nature of haze, EPA’s regulations require the states to consult 

with one another toward the national goal of improving visibility – specifically, at the 156 

parks and wilderness areas designated under the Clean Air Act (CAA) as mandatory Class I 

Federal Areas. 

The Regional Haze Rule calls for each state to formulate a long-term strategy for meeting this 

goal. These requirements apply to any state having a Class I area as well as any state that 

contributes to visibility impairment at any (downwind) Class I area. The visibility goal must 

be designed both to improve visibility on the haziest days and to ensure that no degradation 

occurs on the clearest days. 

A state’s long-term strategy must include enforceable emission reduction measures designed 

to meet reasonable progress goals. The first long-term strategy covers the 10-15-year period 

ending in 2018, and subsequent revisions are to be issued every 10 years thereafter. In 

identifying the emission reduction measures to be included in the long-term strategy, states 

should address all types of manmade emissions contributing to visibility degradation in Class 

I areas, including those from mobile sources; stationary sources (such as factories); smaller, 

so-called “area” sources (such as residential wood stoves and small boilers); and prescribed 

fires to reduce wildland fuel loads. 

 

In developing their plans, states can take into account emission reductions attributable to 

ongoing air pollution control programs at the state, regional, or national levels. For most 

states and regions of the country, however, additional emission control measures beyond 

those already on the books will be necessary if national visibility goals are to be achieved. In 

addition, the Regional Haze Rule mandates that control measures be implemented for certain 

existing sources placed into operation between 1962 and 1977. This portion of the rule is 

known as Best Available Retrofit Technology (BART). 

Each state’s plan for addressing regional haze will take the form of a State Implementation 

Plan (SIP) or SIP revision. Connecticut’s SIP, presented here, was developed after extensive 

consultations with other states and regional planning organizations. Connecticut also 
Connecticut Regional Haze Page 1-2

State Implementation Plan November 2009 

consulted with states outside the Northeast. 

The regulatory, organizational, and technical basis for Connecticut’s regional haze plan will 

be found in Sections 1.0 through 8.0 of this SIP document. The prescriptive elements of 

Connecticut’s plan – BART provisions, reasonable progress goals, and long-term strategy – 

are described in detail in Sections 9.0 through 11.0. 

1.1 Regional Haze Planning after Remand of CAIR 

On March 10, 2005, EPA issued the Clean Air Interstate Rule (CAIR). This federal rule was 

designed to achieve permanent reductions in sulfur dioxide (SO2) and nitrogen oxides (NOX) 

emissions in the eastern United States through a cap-and-trade system using emission 

allowances. CAIR would permanently cap emissions originating in 28 eastern states and the 

District of Columbia (Figure 1.1). 

Figure 1.1: Map of CAIR States 

http://www.epa.gov/cair/

According to EPA’s CAIR website, SO2 emissions in the affected states would be reduced by 

more than 70 percent from 2003 levels, and NOX emissions by more than 60 percent from 

2003 levels, upon full implementation of CAIR (see http://www.epa.gov/cair/). Resulting 

improvements in air quality would yield $85 to $100 billion in health benefits and nearly $2 

billion in visibility benefits per year by 2015, and premature mortality would be substantially 

reduced across the eastern U.S. 

On July 11, 2008, the U.S. Court of Appeals for the District of Columbia Circuit found that 

CAIR violated the CAA. The court vacated CAIR in its entirety and remanded to EPA to 

promulgate a new rule consistent with the court’s opinion. EPA appealed the decision amid 
Connecticut Regional Haze Page 1-3

State Implementation Plan November 2009 

widespread concern that, despite its flaws, some form of CAIR was preferable to the sudden 

regulatory void created by the court’s decision. Upon reconsideration, on December 23, 2008 

the U.S. Court of Appeals for the District of Columbia Circuit stayed the vacatur of CAIR but 

maintained the remand to EPA to promulgate a new rule consistent with the court’s July 11, 

2008 opinion. The court did not impose a definitive deadline by which EPA must correct 

CAIR’s flaws, but the court stated that it does “not intend to grant an indefinite stay of the 

effectiveness” of its decision. 

Because CAIR formed the regulatory underpinnings for most of the emission reductions that 

were to produce visibility improvements in mandatory Class I areas, the vacatur of CAIR 

would have represented a major difficulty for the individual states in attempting to comply 

with the Regional Haze Rule. While all states have depended in varying degree on CAIR in 

the preparation of their regional haze SIPs, some Southeast states have relied almost entirely 

on CAIR to demonstrate compliance with the rule. As a major ramification, the vacatur 

would have immediately invalidated EPA’s determination that CAIR satisfied the 

requirements of BART. 

The U.S. Congress and EPA are considering a number of possible short- and long-term 

regulatory or legislative fixes to improve CAIR. It is too early to know when this process will 

reach a conclusion and what the outcome will dictate for regional haze planning. Over the 

longer term, Connecticut anticipates that future emission control requirements meeting the 

provisions of a reauthorized CAA, or its successor, will be at least as stringent as CAIR 

originally would have obtained. As to the validity of the already-completed planning 

components, a number of mitigating circumstances apply: 

• Some states may apply BART provisions where CAIR would previously have sufficed 

and this is likely to yield even greater emission reductions from BART-eligible 

facilities. 

• Many states have instituted their own emission reduction programs through multipollutant legislation and other means. Connecticut applauds the efforts of other states 

and encourages them to follow through with the implementation of laws, consent 

decrees, and other measures that would complement emissions reductions from CAIR. 

• Strict adherence to the spirit of the CAA in future national initiatives will probably 

result in emission reductions exceeding those previously projected for CAIR. A major 

limitation of the original CAIR was that it relied on interstate emissions trading and did 

not respond to the specific language of the CAA, Section 110 a (2)(D), which prohibits 

any source or activity within a state from impairing the ability of another state to meet 

national air quality standards or visibility requirements. CAIR was only one tool, not 

an all-purpose remedy, for addressing the problem of interstate transport of pollutants. 

For these reasons, the Connecticut Department of Environmental Protection (CTDEP) 

believes that future emissions and air quality levels under CAIR remand scenarios are not 

likely to be vastly different from values predicted by MANE-VU’s completed modeling, even 

though that modeling was based on implementation of CAIR as originally finalized. 

Consequently, the reasonable progress goals and long-term strategy developed for 

Connecticut’s regional haze SIP still represent a defensible position from which to go forward 

with measures to improve visibility at MANE-VU’s Class I Areas. 

Connecticut and the other MANE-VU states have maintained all along that the regional haze 
Connecticut Regional Haze Page 1-4

State Implementation Plan November 2009 

SIPs should look beyond the provisions of CAIR to identify additional emission control 

measures that could be effectively employed to mitigate regional haze. In this respect, 

Connecticut and the rest of MANE-VU stand apart from some other states in asserting that 

additional measures beyond CAIR are essential to meeting established visibility goals at 

MANE-VU’s Class I Areas. 

In describing Connecticut’s present situation, it may be helpful to note that the remand of 

CAIR is a complicating factor but not an absolute impediment to making visibility progress in 

the near term. The salient points to consider are as follows: 

• Connecticut will meet its “fair share” of emissions in comparison with other MANEVU states and the CAIR states, as Connecticut’s long-term strategy demonstrates (see 

Section 11.0). 

• By the time of the first regional haze SIP five-year progress report, the regulatory 

framework should be clearer; and new modeling results may be available. It will then 

be possible to fine-tune regional haze plans to meet the CAIR replacement rule. 

CTDEP is committed to reviewing and updating its regional haze SIP at that time. 

It should be noted that Connecticut’s Regional Haze SIP includes many references to the 

original CAIR program. These references serve two purposes: 1) The included references 

provide historical context, and 2) they help to maintain continuity with the large body of 

completed work – much of it based on the original CAIR – that serves as the foundation for 

regional haze planning in the MANE-VU states to date. 

1.2 The Basics of Haze 

Small particles and certain gaseous molecules in the atmosphere cause poor visibility by 

scattering and absorbing light, thereby reducing the amount of visual information about 

distant objects that reaches an observer. Some light scattering by air molecules and naturally 

occurring aerosols occurs even under natural conditions.1

The distribution of particles in the atmosphere depends on meteorological conditions and leads 

to various forms of visibility impairment. When high concentrations of pollutants are well 

mixed in the atmosphere, they form a uniform haze. When temperature inversions trap 

pollutants near the surface, the result can be a sharply demarcated layer of haze. Plume blight – 

a distinct, frequently brownish plume of pollution from a particular emissions source – occurs 

under stable atmospheric conditions, where pollutants take a long time to disperse. 

Visibility impairment can be quantified using three different, but mathematically related 

measures: light extinction per unit distance (e.g., Mm-1)

2

; visual range (i.e., how far one can 

see); and deciviews (dv), a useful metric for measuring increments of visibility change that 

are just perceptible to the human eye. Each can be estimated from the ambient concentrations 

 

1

 The fact that air molecules scatter more short-wavelength (blue) light accounts for the blue color of the sky. The term 

“aerosol” is defined as a suspension of particles in a gas. In this report, the term refers to particles suspended in the 

atmosphere. 

2

 In units of inverse length. An inverse megameter (Mm-1) is equal to one over one thousand kilometers. 
Connecticut Regional Haze Page 1-5

State Implementation Plan November 2009 

of individual particle constituents, taking into account their unique light-scattering (or 

absorbing) properties and making appropriate adjustments for relative humidity. Assuming 

natural conditions, visibility in the Northeast and Mid-Atlantic is estimated to be about 23 

Mm-1, which corresponds to a visual range of about 106 miles or 8 dv. Under current polluted 

conditions in the region, average visibility ranges from 103 Mm-1 in the south to 55 Mm-1 in the 

north; these values correspond to a visual range of 24 to 44 miles or 23 to 17 dv, respectively. 

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

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

The small particles that commonly cause hazy conditions in the East are primarily composed 

of sulfate, nitrate, organic carbon, elemental carbon (soot), and crustal material (e.g., soil dust, 

sea salt, etc.). Of these constituents, only elemental carbon impairs visibility by absorbing 

visible light; the others scatter light. Sulfate, nitrate, and organic carbon3 are secondary 

pollutants that form in the atmosphere from precursor pollutants, primarily SO2, NOX, and 

volatile organic compounds (VOCs), respectively. By contrast, soot, crustal material and 

some organic carbon particles are released directly to the atmosphere. Particle constituents 

also differ in their relative effectiveness at reducing visibility. Sulfates and nitrates, for 

example, contribute disproportionately to haze because of their chemical affinity for water. 

This property allows them to grow rapidly, in the presence of moisture, to the optimal particle 

size for scattering light (i.e., 0.1 to 1 micrometer). 

1.3 Anatomy of Regional Haze 

Monitoring data collected over the last decade show that fine particle4 concentrations, and 

hence visibility impairment, are generally highest near industrial and highly populated areas 

of the Northeast and Mid-Atlantic. Particle concentrations are lower, and visibility conditions 

are better, at the more northerly Class I sites (such as the Great Gulf and Presidential Range - 

Dry River Wildernesses in New Hampshire), where visibility on the 20 percent best days5 is 

close to natural, unpolluted conditions. By contrast, visibility at the more southerly 

Brigantine site in New Jersey is substantially impaired even on the 20 percent clearest days. 

On the 20 percent haziest days, visibility impairment is substantial throughout the region. 

Sulfate is the dominant contributor to fine particle pollution throughout the eastern U.S. On 

the haziest 20 percent of days, it accounts for one-half to two-thirds of total fine particle mass 

and is responsible for about three-quarters of total light extinction at Class I sites in the 

Northeast and Mid-Atlantic. Even on the clearest 20 percent of days, sulfate typically 

constitutes 40 percent or more of total fine particle mass in the region. Moreover, sulfate 

accounts for 60 to 80 percent of the difference in fine particle mass concentrations on hazy 

versus clear days. 

 

3

 The term “organic carbon” encompasses a large number of hydrogen and carbon containing molecules. Light scattering 

secondary organic aerosols result from the oxidation of hydrocarbons that are emitted from many different sources, 

ranging from automobiles to solvents, to natural vegetation. Organic carbon can be emitted as a primary particle from 

sources such as wood burning, meat cooking, automobiles, and paved road dust. 

4

 “Fine particles” refers throughout this study to particles less than or equal to 2.5 micrometers in diameter, consistent with

US EPA’s fine particle National Ambient Air Quality Standard (NAAQS). 

5

 “20 percent best visibility conditions” are defined throughout this report as the simple average of the lower 20th percentile 

of a cumulative frequency distribution of available data (expressed in deciviews). Similarly, “20 percent worst visibility 

conditions” represent the upper 20th percentile of the same distribution of available data. 
Connecticut Regional Haze Page 1-6

State Implementation Plan November 2009 

Organic carbon consistently accounts for the next largest fraction of total fine particle mass; 

its contribution typically ranges from 20 to 30 percent on the haziest days. Notably, organic 

carbon accounts for as much as 40 to 50 percent of total mass on the clearest days, indicating 

that biogenic hydrocarbon sources (i.e. vegetation) are important at Class I areas in the region. 

The relative contributions of nitrate, elemental carbon, and fine soil are smaller than those of 

sulfate and organic carbon – typically less than 10 percent of total mass and varying with 

location. However, in some settings such as a monitoring site in Washington, DC,6 nitrate 

plays a considerably larger role, pointing to the importance of local NOX sources to fineparticle pollution in urban environments. 

In the Northeast, the worst visibility tends to occur during the summer. New Hampshire’s 

Department of Environmental Services found that about half of the worst visibility days in the 

New Hampshire Class I Areas occur in the summer when meteorological conditions are more 

conducive to the formation of sulfate from SO2 and to the oxidation of organic aerosols. The 

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

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

contributions from upwind source regions. In contrast to sulfate and organic carbon, the 

nitrate contribution is typically higher in the winter months7

. The crustal and elemental 

carbon fractions do not show a clear pattern of seasonal variation. 

The basis for EPA’s regional haze regulations is recognition that visibility impairment is 

fundamentally a regional phenomenon. Emissions from numerous sources over a broad 

geographic area commonly create hazy conditions across large portions of the eastern U.S. as 

a result of the long-range transport of airborne particles and precursor pollutants in the 

atmosphere. The key sulfate precursor, SO2, for example, has an atmospheric lifetime of 

several days and is known to be subject to transport distances of hundreds of miles. NOX and 

some organic carbon species are also subject to long-range transport, as are small particles of 

soot and crustal material. 

The importance of transport dynamics is well illustrated by a particularly severe haze episode 

that occurred in mid-July of 1999. During this episode, unusually hot and humid conditions 

coincided with the development of a high-pressure system over the Mid-Atlantic States that 

produced atmospheric stagnation over the heavily urbanized, southern portion of the 

northeastern Regional Planning Organization region (i.e., Philadelphia - DC - southern New 

Jersey). At the same time, wind patterns above the area of stagnation brought a steady flow of 

air from the Midwest into the New England states. This set of conditions resulted in several 

days of unusually high concentrations of fine-particle pollution throughout the region. On 

July 17, 1999, ambient sulfate concentrations at Acadia National Park were 40 percent higher 

than any previous measurement at that site since the late 1980s. On the same day, visibility at 

the Burlington, Vermont, airport was limited to just 3 miles. As is often the case, high 

concentrations of ground-level ozone accompanied these severe haze conditions. These 

coinciding conditions occurred because haze and ground-level ozone – although they are 

 

6

 The Washington, DC, site is part of the IMPROVE nationwide monitoring network and is mentioned here for the purposes 

of comparison. 

7

 This is largely due to the fact that the ammonium nitrate bond is more stable at lower temperatures. The role of ammonia 

in combination with both sulfate and nitrate is discussed further in later sections. 
Connecticut Regional Haze Page 1-7

State Implementation Plan November 2009 

fundamentally different phenomena – tend to form and accumulate under similar 

meteorological conditions. 

1.4 Regulatory Framework 

In amendments to the CAA in 1977, Congress added Section 169A (42 U.S.C. 7491), setting 

forth the following national visibility goal: 

“Congress hereby declares as a national goal the prevention of any future, and the remedying of 

any existing, impairment of visibility in mandatory Class I Federal areas which impairment 

results from manmade air pollution.” 

The "Class I" designation was given to each of 158 areas in existence as of August 1977 that 

met the following criteria: 

• all national parks greater than 6000 acres 

• all national wilderness areas and national memorial parks greater than 5000 acres 

• one international park 

In 1980, Bradwell Bay, Florida, and Rainbow Lake, Wisconsin, were excluded for purposes 

of visibility protection as federal Class I areas. Today, 156 national park and wilderness areas 

remain as Class I visibility protection areas (Figure 1.2). 

Over the following years, modest steps were taken to address the visibility problems in Class I 

areas. The control measures taken mainly addressed plume blight from specific pollution 

sources, a localized phenomenon, and did little to address regional haze issues in the Eastern 

United States. 

When the CAA was amended, again, in 1990, Congress added Section 169B (42 U.S.C. 

7492), authorizing further research and regular assessments of progress made. In 1993, the 

National Academy of Sciences concluded that “current scientific knowledge is adequate and 

control technologies are available for taking regulatory action to improve and protect visibility.” 

In addition to authorizing creation of visibility transport commissions and setting forth their 

duties, Section 169B(f) of the CAA mandated creation of the Grand Canyon Visibility 

Transport Commission (GCVTC) to make recommendations to EPA for the region affecting 

the visibility of the Grand Canyon National Park. GCVTC submitted its report to EPA in 

June 1996, following four years of research and policy development. This report, as well as 

the many research reports prepared by the GCVTC, contributed invaluable information to 

EPA in its development of regulations for visibility improvement. 
Connecticut Regional Haze Page 1-8

State Implementation Plan November 2009 

Figure 1.2: Locations of Federally Protected Mandatory Class I Areas 

 

1.4.1 The Regional Haze Rule 

The federal requirements that states must meet to achieve national visibility goals are 

contained in the Code of Federal Regulations (CFR), Title 40: Protection of Environment, 

Part 51 – Requirements for Preparation, Adoption, and Submittal Of Implementation Plans, 

Subpart P – Protection of Visibility (40 CFR 51.300-309). Known more simply as the 

Regional Haze Rule, these regulations were adopted on July 1, 1999, and went into effect on 

August 30, 1999. The rule seeks to address the combined visibility effects of various 

pollution sources over a large geographic region. This wide-reaching pollution net means that 

many states – even those without Class I Areas – are required to participate in haze reduction 

efforts. The specific requirements for States’ regional haze SIPs are set forth in 40 CFR 

51.308, Regional Haze Program Requirements. 

In consultation with the states and tribes, EPA designated five Regional Planning 

Organizations (RPO) to assist with the coordination and cooperation needed to address the 

regional haze issue. The Mid-Atlantic and Northeast states, joined by the District of 

Columbia and tribes in the Northeast, formed the Mid-Atlantic / Northeast Visibility Union 
Connecticut Regional Haze Page 1-9

State Implementation Plan November 2009 

(MANE-VU).8

EPA’s adoption of the Regional Haze Rule faced several legal challenges. On May 24, 2002, 

the U.S. Court of Appeals for the District of Columbia Circuit ruled on the challenge brought 

by the American Corn Growers Association against the Regional Haze Rule. The Court 

remanded the BART provisions of the rule to EPA and denied industry’s challenge to the haze 

rule goals of achieving natural visibility levels and zero degradation. On June 15, 2005, EPA 

finalized a rule addressing the court’s remand. 

On February 18, 2005, the U.S. Court of Appeals for the D.C. Circuit issued another ruling 

vacating the Regional Haze Rule in part and sustaining it in part. For more information see 

Center for Energy and Economic Development v. EPA, no. 03-1222, (D.C. Cir. Feb. 18, 2005) 

(“CEED v. EPA”). In this case, the court granted a petition challenging provisions of the 

Regional Haze Rule governing the optional emissions trading program for certain Western 

States and Tribes (the WRAP Annex Rule).

In the aftermath of these decisions, EPA’s final rulemaking incorporated the following 

changes to the Regional Haze Rule: 

• Revised the regulatory text in 40 CFR 51.308(e)(2)(i) in response to the CEED court’s 

remand, to 

− Remove the requirement that the determination of BART be based on 

cumulative visibility analyses, and 

− Clarify the process for making such determinations, including the application 

of BART presumptions for electric generating units (EGUs) as contained in 40 

CFR 51, Appendix Y; 

• Added new regulatory text in 40 CFR 51.308(e)(2)(vi) to provide minimum elements 

for cap-and-trade programs in lieu of BART; and 

• Revised regulatory text in 40 CFR 51.309 to reconcile the optional framework for 

certain Western states and tribes to implement the recommendations of the GCVTC 

with the CEED decision. 

1.4.2 State Implementation Plan 

EPA prepared a checklist summarizing the requirements of the final Regional Haze Rule to be 

addressed in Regional Haze SIPs. Attachment A contains a copy of that checklist with crossreferences to sections of Connecticut’s Regional Haze SIP showing how the requirements 

have been met. 

In accordance with 40 CFR 51.308(a) and (b), Connecticut submits this SIP to meet the 

requirements of EPA’s Regional Haze Rule. This SIP addresses the core requirements of 40 

CFR 51.308(d) and the BART components of 40 CFR 50.308(e). In addition, this SIP addresses 

requirements pertaining to regional planning, and state/tribe and Federal Land Manager 

(FLM) coordination and consultation. 

 

8

 MANE-VU includes the following member states: Connecticut, Delaware, Maine, Maryland, Massachusetts, New 

Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and the District of Columbia. A more 

complete description of MANE-VU appears in Section 3.0 of this SIP. 
Connecticut Regional Haze Page 1-10

State Implementation Plan November 2009 

40 CFR 51.308(f) requires the CTDEP to submit periodic revisions to its Regional Haze SIP 

by July 31, 2018, and every ten years thereafter. CTDEP acknowledges and will comply 

with this schedule.

40 CFR 51.308(g) requires CTDEP to submit a report to EPA every 5 years that evaluates 

progress toward the reasonable progress goal for each mandatory Class I area located outside 

the state that may be affected by emissions from within the state. CTDEP will submit the 

first progress report, in the form of a SIP revision, within 5 years from the date of final 

submittal of this initial State Implementation Plan.

As required by 40 CFR 51.308(d)(4)(v), CTDEP will also make periodic updates to 

Connecticut’s emissions inventory (see Section 6.0, Emissions Inventory). CTDEP 

proposes to use the most updated inventory to coincide with the progress reports. 

Finally, as required by 40 CFR 51.308(h), CTDEP will submit a determination of 

adequacy of its regional haze SIP revision whenever a progress report is submitted. 

Depending on the findings of its five-year review, CTDEP will take one or more of the 

following actions at that time, whichever actions are appropriate or necessary: 

• If CTDEP determines that the existing State Implementation Plan requires no further 

substantive revision in order to achieve established goals for visibility improvement and 

emissions reductions, CTDEP will provide to the EPA Administrator a negative 

declaration stating that further revision of the existing plan is not needed. 

• If CTDEP determines that its implementation plan is or may be inadequate to ensure 

reasonable progress as a result of emissions from sources in one or more other state(s) 

which participated in the regional planning process, Connecticut will provide 

notification to the EPA Administrator and to those other state(s). Connecticut will 

also collaborate with the other state(s) through the regional planning process for the 

purpose of developing additional strategies to address any such deficiencies in 

Connecticut’s plan. 

• If CTDEP determines that its implementation plan is or may be inadequate to ensure 

reasonable progress as a result of emissions from sources in another country, CTDEP 

will provide notification, along with available information, to the EPA Administrator. 

• If CTDEP determines that the implementation plan is or may be inadequate to ensure 

reasonable progress as a result of emissions from sources within the state, CTDEP will 

revise its implementation plan to address the plan’s deficiencies within one year from 

this determination. 
Connecticut Regional Haze Page 2-1 

State Implementation Plan November 2009 

2.0 AREAS CONTRIBUTING TO REGIONAL HAZE 

40 CFR 51.308(d)(3)(iii) of the Regional Haze Rule requires states to determine their 

contributions to visibility impairment at mandatory Class I areas. Through source 

apportionment modeling (more fully described in Section 8.0, Understanding the Sources of 

Visibility-Impairing Pollutants), MANE-VU has identified and evaluated the major 

contributors to regional haze at MANE-VU Class I Areas as well as Class I areas in nearby 

Regional Planning Organizations (RPOs). The complete findings are contained in a report 

produced by the Northeast States for Coordinated Air Use Management (NESCAUM) 

entitled, “Contributions to Regional Haze in the Northeast and Mid-Atlantic United States,” 

August 2006, otherwise known as the Contribution Assessment (Attachment B).

The regional modeling performed by MANE-VU used a pollutant tagging scheme to produce 

a comprehensive assessment of the individual contributions from 28 nearby states to visibility 

impairment at the northeastern Class I areas and two other Class I areas. The modeling also 

provided a partial accounting of the contributions from several states along the western and 

southern edges of the modeling domain (i.e., boundary conditions) where only a portion of the 

states’ emissions were tracked. Modeling was conducted for the base year 2002 and then 

projected to year 2018, when currently anticipated emission control programs would be in 

place. 

Modeling results indicate that the relative contributions of states within the modeling domain 

will decrease significantly by 2018 as a result of anticipated SO2 emission reductions from 

implementation of existing state programs, revision of the federal Clean Air Interstate Rule 

(CAIR), and additional state and federal control measures described in following sections of 

this document. At the same time, there will be large increases in the relative contributions 

from Canada and the boundary areas. These predicted increases are due simply to the fact that 

contributions from outside the modeling domain will represent a larger share of the total after 

the various emission control programs have reduced contributions from within the domain. 

2.1 Class I Areas Affected by Connecticut’s Emission Sources 

Connecticut does not contain any Class I areas. Emission sources within Connecticut have 

had measurable impacts on visibility at Class I areas at downwind locations. The magnitude 

of these impacts is described in detail in MANE-VU’s Contribution Assessment (Attachment 

B). Table 2.1 briefly lists the affected Class I areas and Connecticut’s percent contribution to 

total annual sulfate at each area in the 2002 baseline year, as determined from the modeling. 
Connecticut Regional Haze Page 2-2

State Implementation Plan November 2009 

Table 2.1: Connecticut’s Contributions to Total Annual Average Sulfate Impact 

(Percent, Mass Basis) at Eastern Class I Areas in 2002 

Mandatory Class I Area(s) Percent Contribution 

Great Gulf Wilderness* & Presidential Range – Dry River Wilderness* 0.48 

Acadia National Park* 0.76 

Moosehorn Wilderness* & Roosevelt Campobello International Park* 0.56 

Lye Brook Wilderness* 0.55 

Brigantine Wilderness* 0.53 

Shenandoah National Park 0.08 

Dolly Sods Wilderness 0.04 

 *MANE-VU Class I Area 

Connecticut’s emissions account for less than 1 percent of visibility-impairing sulfate in the 

downwind Class I areas of Great Gulf Wilderness & Presidential Range-Dry River 

Wilderness, Acadia National Park, Moosehorn Wilderness & Roosevelt Campobello 

International Park, and Lye Brook Wilderness. Also, Connecticut’s emissions account for 

less than 1 percent of visibility-impairing sulfate in the more southerly Class I areas of 

Brigantine Wilderness, Shenandoah National Park, and Dolly Sods Wilderness. 

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

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

northeast Class I Areas when considering all MANE-VU states. 
Connecticut Regional Haze Page 2-3

State Implementation Plan November 2009 

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

Annual Sulfate Impacts at Northeast Class I Areas (REMSAD) 

Contributing 

State or Region 

Mandatory Class I Area 

Acadia 

ME 

Brigantine 

NJ 

Dolly Sods 

WV 

Great Gulf &

Presidential 

Range – Dry 

River, NH 

Lye Brook 

VT 

Moosehorn

& Roosevelt 

Campobello

ME 

Shenandoah 

VA 

Connecticut 0.76 0.53 0.04 0.48 0.55 0.56 0.08

Delaware 0.96 3.20 0.30 0.63 0.93 0.71 0.61

District of Columbia 0.01 0.04 0.01 0.01 0.02 0.01 0.04

Maine 6.54 0.16 0.01 2.33 0.31 8.01 0.02

Maryland 2.20 4.98 2.39 1.92 2.66 1.60 4.84

Massachusetts 10.11 2.73 0.18 3.11 2.45 6.78 0.35

New Hampshire 2.25 0.60 0.04 3.95 1.68 1.74 0.08

New Jersey 1.40 4.04 0.27 0.89 1.44 1.03 0.48

New York 4.74 5.57 1.32 5.68 9.00 3.83 2.03

Pennsylvania 6.81 12.84 10.23 8.30 11.72 5.53 12.05

Rhode Island 0.28 0.10 0.01 0.11 0.06 0.19 0.01

Vermont 0.13 0.06 0.00 0.41 0.95 0.09 0.01

MANE-VU 36.17 34.83 14.81 27.83 31.78 30.08 20.59

MRPO 11.98 18.16 30.26 20.10 21.48 10.40 26.84

VISTAS 8.49 21.99 36.75 12.04 13.65 6.69 33.86

CenRAP 0.88 1.12 1.58 1.65 1.67 0.82 1.48

Canada 8.69 7.11 3.90 14.84 12.43 7.85 4.75

Other 33.79 16.78 12.70 23.54 18.99 44.17 12.48

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

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

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

than stated. 

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

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

Planning and Consultation. Using results from the REMSAD model, MANE-VU applied the 

following three criteria to identify states and regions for the purposes of consultation on 

regional haze: 

1. Any state/region that contributed 0.1 μg/m3

 sulfate or greater on the 20 percent worst 

visibility days in the base year (2002), 

2. Any state/region that contributed at least 2 percent of total sulfate observed on the 20 

percent worst visibility days in 2002, and 

3. Any state/region among the top ten contributors on the 20 percent worst visibility days 

in 2002. 

For the purposes of deciding how broadly to consult, the MANE-VU States settled on the 

second of the three criteria: any state/region that contributed at least 2 percent of total sulfate 

observed on the 20 percent worst visibility days in 2002. Connecticut, Rhode Island, 

Vermont, and the District of Columbia were not identified as being among the political or 

regional units contributing at least 2 percent of sulfate at any of the seven Class I areas. 

However, as participants in MANE-VU, those entities have agreed to pursue adoption of 
Connecticut Regional Haze Page 2-4

State Implementation Plan November 2009 

regional control measures aimed at visibility improvement on the haziest days and prevention 

of visibility degradation on the clearest days. Section 8.2 includes additional discussion 

regarding individual state contributions to regional haze at Class I areas. 
Connecticut Regional Haze Page 3-1 

State Implementation Plan November 2009 

3.0 REGIONAL PLANNING AND CONSULTATION 

In 1999, EPA and affected states/tribes agreed to create five Regional Planning Organizations 

(RPOs) to facilitate interstate coordination on State Implementation Plans (SIPs) addressing 

regional haze. The RPOs, and states/tribes within each RPO, are required to consult on 

emission management strategies toward visibility improvement in affected Class I areas. As 

shown in the accompanying map (Figure 3.1), the five RPOs are MANE-VU (MidAtlantic/Northeast Visibility Union), VISTAS (Visibility Improvement State and Tribal 

Association of the Southeast), MRPO (Midwest Regional Planning Organization), CenRAP 

(Central Regional Air Planning Association), and WRAP (Western Regional Air Partnership). 

Connecticut is a member of MANE-VU. 

Figure 3.1: EPA-Designated Regional Planning Organizations (RPOs). 

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

MANE-VU’s work is managed by the Ozone Transport Commission (OTC) and carried out 

by OTC, the Mid-Atlantic Regional Air Management Association (MARAMA), and 

NESCAUM. The states, tribes, and federal agencies comprising MANE-VU are listed in 

Table 3.1. Individuals from the member states, tribes, and agencies, along with professional 

staff from OTC, MARAMA, and NESCAUM, make up the various committees and 

workgroups. MANE-VU also established a Policy Advisory Group (PAG) to provide advice 

to decision-makers on policy questions. EPA, Federal Land Managers, states, and tribes are 

represented on the PAG, which meets on an as-needed basis. 
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State Implementation Plan November 2009 

Table 3.1: MANE-VU Members 

Connecticut Rhode Island 

Delaware Vermont 

Maine District of Columbia 

Maryland Penobscot Nation 

Massachusetts St. Regis Mohawk Tribe 

New Hampshire U.S. Environmental Protection Agency* 

New Jersey U.S. Fish and Wildlife Service* 

New York U.S. Forest Service* 

Pennsylvania U.S. National Park Service* 

 *Non-voting member 

Since its inception on July 24, 2001, MANE-VU has created an active committee structure to 

address both technical and non-technical issues related to regional haze. The primary 

committees are the Technical Support Committee (TSC) and the Communications Committee. 

While the work of these committees is instrumental to policies and programs, all policy 

decisions reside with and are made by the MANE-VU Board. 

The TSC is charged with assessing the nature and magnitude of the regional haze problem 

within MANE-VU, interpreting the results of technical work, and reporting on such work to 

the MANE-VU Board. This committee has evolved to function as a valuable resource on all 

technical projects and issues for MANE-VU. The TSC has established a process to ensure 

that important regional-haze-related projects are completed in a timely fashion, and members 

are kept informed of all MANE-VU tasks and duties. In addition to the formal working 

committees, there are three standing workgroups of the TSC assigned by topic area: the Emissions 

Inventory Workgroup, the Modeling Workgroup, and the Monitoring/Data Analysis 

Workgroup. 

The Communications Committee is charged with developing approaches to inform the public 

about the regional haze problem and making recommendations to the MANE-VU Board to 

facilitate that goal. This committee oversees the production of MANE-VU’s newsletter and 

outreach tools, both for stakeholders and the public, regarding regional issues affecting 

MANE-VU’s members. 

3.2 Regional Consultation and the “Ask” 

On May 10, 2006, MANE-VU adopted the Inter-RPO State/Tribal and FLM Consultation 

Framework (Attachment C). That document set forth the principles presented in Table 3.2. 

The MANE-VU states and tribes applied these principles to the regional haze consultation and 

SIP development process. Issues addressed included regional haze baseline assessments, 

natural background levels, and development of reasonable progress goals – described at 

length in later sections of this SIP. 

Formal inter-regional consultation meetings took place on August 6, 2007, in Rosemont, 

Illinois, (for Midwestern states) and on August 20, 2007, in Atlanta, Georgia, (for Southern
Connecticut Regional Haze Page 3-3 

State Implementation Plan November 2009 

states). Consultation continues with the Midwestern states, seeking common approaches for 

reducing power plant emissions beyond the levels defined under the now-remanded federal 

CAIR rule, controls on industrial boilers, and cleaner-burning fuels for mobile sources. 

Ongoing consultation with MRPO focuses mainly on the health benefits of reducing ozone 

and small particulate emissions; however, the control measures being considered would also 

result in visibility improvements. 

Throughout the consultation process, MANE-VU states were guided by the principals 

contained in a resolution adopted by the MANE-VU Class I states on June 7, 2007. In the 

resolution, the Class I states agreed to set reasonable progress goals for 2018 that would 

provide visibility improvement at least as great as that which would be achieved under a 

uniform rate of progress to reach natural visibility conditions by 2064. The goals would be 

set by the Class I states at levels reflecting implementation of measures determined to be 

reasonable after consultation with the contributing states. At the same time, the Class I states 

recognized that each state should be given the flexibility to choose other measures that 

achieve the same or greater benefits. 

The final results of consultation efforts will ultimately rest with the individual states as they 

develop and implement their own regional haze SIPs. The other MANE-VU states have 

agreed to incorporate certain control measures into their SIPs, but most of these plans are still 

under development. For the non-MANE-VU states, the expectation is that the same or 

equivalent control measures will be included in those states plans. However, some states – 

particularly those within the VISTAS region – have already submitted draft SIPs that do not 

go as far in controlling emissions as MANE-VU would like. See Subsection 3.2.2.3 and 

Subsection 3.2.4, below, for further discussion related to the non-MANE-VU states. 
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State Implementation Plan November 2009 

Table 3.2: MANE-VU Consultation Principles for Regional Haze Planning 

1. All State, Tribal, RPO, and Federal participants are committed to continuing dialogue and 

information sharing in order to create understanding of the respective concerns and needs of 

the parties. 

2. Continuous documentation of all communications is necessary to develop a record for inclusion 

in the SIP submittal to EPA. 

3. States alone have the authority to undertake specific measures under their SIP. This inter-RPO 

framework is designed solely to facilitate needed communication, coordination and cooperation 

among jurisdictions but does not establish binding obligation on the part of participating 

agencies. 

4. There are two areas which require State-to-State and/or State-to-Tribal consultations (“formal” 

consultations): (i) development of the reasonable progress goal for a Class I area, and (ii) 

development of long-term strategies. While it is anticipated that the formal consultation will 

cover the technical components that make up each of these policy decision areas, there may be 

a need for the RPOs, in coordination with their State and Tribal members, to have informal 

consultations on these technical considerations. 

5. During both the formal and informal inter-RPO consultations, it is anticipated that the States 

and Tribes will work collectively to facilitate the consultation process through their respective 

RPOs, when feasible. 

6. Technical analyses will be transparent, when possible, and will reflect the most up-to-date 

information and best scientific methods for the decision needed within the resources available. 

7. The State with the Class I area retains the responsibility to establish reasonable progress goals. 

The RPOs will make reasonable efforts to facilitate the development of a consensus among the 

State with a Class I area and other States affecting that area. In instances where the State with 

the Class I area can not agree with such other States that the goal provides for reasonable 

progress, actions taken to resolve the disagreement must be included in the State’s regional 

haze implementation plan (or plan revisions) submitted to the EPA Administrator as required 

under 40 CFR §51.308(d)(1)(iv). 

8. All States whose emissions are reasonably anticipated to contribute to visibility impairment in a 

Class I area, must provide the Federal Land Manager (“FLM”) agency for that Class I area with 

an opportunity for consultation, in person, on their regional haze implementation plans. The 

States/Tribes will pursue the development of a memorandum of understanding to expedite the 

submission and consideration of the FLM’s comments on the reasonable progress goals and 

related implementation plans. As required under 40 CFR §51.308(i)(3), the plan or plan 

revision must include a description of how the State addressed any FLM comments. 

9. States/Tribes will consult with the affected FLMs to protect the air resources of the State/Tribe 

and Class I areas in accordance with the FLM coordination requirements specified in 40 CFR 

§51.308(i) and other consultation procedures developed by consensus. 

10. The consultation process is designed to share information, define and document issues, develop 

a range of options, solicit feedback on options, develop consensus advice if possible, and 

facilitate informed decisions by the Class I States. 

11. The collaborators, including States, Tribes and affected FLMs, will promptly respond to other 

RPOs’/States’/Tribes’ requests for comments. 
Connecticut Regional Haze Page 3-5 

State Implementation Plan November 2009 

The following points identify several important ways in which MANE-VU member states and 

tribes have cooperatively addressed regional haze: 

• Prioritization: MANE-VU developed a process to coordinate MARAMA, OTC, and 

NESCAUM staff in developing budget priorities, project rankings, and the eventual 

federal grant requests. 

• Issue Coordination: MANE-VU established a conference call and meeting schedule 

for each of its committees and workgroups. In addition, its MANE-VU directors 

regularly discussed pertinent issues. 

• SIP Policy and Planning: MANE-VU states/tribes collaborated on the development of 

a regional haze SIP template and the technical aspects of the SIP development process. 

• Capacity Building: To educate its staff and members, MANE-VU included technical 

presentations on conference calls and organized workshops with nationally recognized 

experts. Presentations on data analysis, Best Available Retrofit Technology (BART) 

applicability, inventory topics, modeling, and control measures were effective education 

and coordination tools. 

• Routine Operations: MANE-VU staff at OTC, MARAMA, and NESCAUM established 

a coordinated approach to budget tracking, project deliverables and due dates, 

workgroup meetings, inter-RPO consultations, etc. 

Both formal and informal consultations within MANE-VU have been ongoing since the 

organization’s establishment in 2001; but the bulk of formal consultation took place in 2007, 

as outlined in Table 3.3. Further documentation of consultation meetings and calls is included 

in Attachment D. 
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State Implementation Plan November 2009 

Table 3.3: Summary of MANE-VU’s Consultations on Regional Haze Planning

1.1.7 New Hampshire’s Consultations 

40 CFR Section 51.308(d)(3)(i) requires the State of New Hampshire to consult with other 

states/tribes to develop coordinated emission management strategies. This requirement 

applies both when emissions from a state/tribe are reasonably anticipated to contribute to 

visibility impairment in Class I areas outside the state/tribe and when emissions from other 

states/tribes are reasonably anticipated to contribute to visibility impairment at mandatory 

Class I areas within a state/tribe. 

New Hampshire consulted with other states/tribes by participating in the MANE-VU and 

inter-RPO processes leading to the creation of coordinated strategies on regional haze. This 

coordinated effort considered the individual and aggregated impacts of states’/tribes’ 

emissions on Class I areas within and outside the states/tribes. 

As described in Section 2.0, Areas Contributing to Regional Haze, emissions originating in 

New Hampshire have had, and will continue to have, impacts on other Class I areas in the 

region. Accordingly, New Hampshire has entered into consultations with the states and 

provinces in which the affected Class I areas are located (Table 2.1). 

Table 2.1: Class I Areas States Requesting Consultation with New Hampshire 

Class I Federal Area State / Province 

 Great Gulf Wilderness New Hampshire 

 Presidential Range Dry River Wilderness New Hampshire 

 Acadia National Park Maine 

 Moosehorn Wilderness Maine 

 Roosevelt Campobello International Park Maine / New Brunswick 

 Lye Brook Wilderness Vermont 

 Brigantine Wilderness New Jersey 

The listed states represent only a fraction of those with whom New Hampshire has entered 

into consultations on regional haze. Through the MANE-VU process, more than twenty states 

and Canadian provinces have been identified as contributing to visibility degradation in New 

Hampshire’s two Class I areas: the Great Gulf Wilderness and the Presidential Range - Dry 

River Wilderness. On April 2, 2007, NHDES sent letters formally requesting consultation 

under the Regional Haze Rule to states and Canadian provinces – specifically, those shown 

via modeling to contribute at least 2 percent of visibility-impairing sulfates at Class I Areas in 

New Hampshire (refer to the Contribution Assessment, Attachment B), and all other states 

located within MANE-VU 

MANE-VU Intra-Regional Consultation Meeting, March 1, 2007: 

MANE-VU members reviewed the requirements for regional haze plans, preliminary modeling results, the 

work being done to prepare the MANE-VU report on reasonable progress factors, and control strategy 

options under review. 

MANE-VU Intra-State Consultation Meeting, June 7, 2007: 

The MANE-VU Class I states adopted a statement of principles, and all MANE-VU members discussed draft 

statements concerning reasonable controls within and outside of MANE-VU. Federal Land Managers also 

attended the meeting, which was open to stakeholders. 

MANE-VU Conference Call, June 20, 2007: 

The MANE-VU states concluded discussions of statements concerning reasonable controls within and 

outside MANE-VU and agreed on the statements called the MANE-VU “Ask” (see Subsection 3.2.2 of this 

SIP), including a statement concerning controls within MANE-VU, a statement concerning controls outside 

MANE-VU, and a statement requesting a course of action by the EPA. Federal Land Managers also 

participated in the call. Upon approval, all three statements as well as the statement of principles adopted on 

June 7 were posted and publicly available on the MANE-VU website. The MANE-VU “Ask” was 

determined to represent the needs of all Class I areas both within the MANE-VU region and beyond, and was 

thus adopted as a goal for Connecticut. 

MANE-VU Class I States’ Consultation Open Technical Call, July 19, 2007: 

The MANE-VU “Ask” was presented to states in other RPOs, RPO staff, and Federal Land Managers; and an 

opportunity was provided to request further information. This call was intended to provide information to 

facilitate informed discussion at follow-up meetings. 

MANE-VU Consultation Meeting with MRPO, August 6, 2007: 

This meeting, held at LADCO offices in Chicago, was attended by representatives of MANE-VU and MRPO 

states as well as staff. The meeting provided an opportunity to formally present the MANE-VU “Ask” to 

MRPO states and to consult with them on the reasonableness of the requested controls. Federal Land Manager 

agencies also attended the meeting. 

MANE-VU Consultation Meeting with VISTAS, August 20, 2007: 

This meeting, held at State of Georgia offices in Atlanta, was attended by representatives of MANE-VU and 

VISTAS states. The meeting provided an opportunity to formally present the MANE-VU “Ask” to VISTAS 

states and to consult with them on the reasonableness of the requested controls. Federal Land Manager 

agencies also attended the meeting. 

MANE-VU / MRPO Consultation Conference Call, September 13, 2007: 

As a follow-up to the meeting held on August 6 in Chicago, this call provided an opportunity for MANE-VU 

to clarify further what was being asked of the MRPO states. The flexibility in the “Ask” was explained. 

MRPO and MANE-VU staff agreed to work together to facilitate discussion of further controls on ICI boilers 

and EGUs. 

MANE-VU Air Directors’ Consultation Conference Call, September 26, 2007: 

MANE-VU members clarified their understanding of the “Ask” and provided direction to modeling staff 

regarding interpretation of the “Ask” for purposes of estimating visibility impacts of the requested controls. 
Connecticut Regional Haze Page 3-7 

State Implementation Plan November 2009 

3.2.1 Connecticut-Specific Consultations 

40 CFR 51.308(d)(3)(i) of the Regional Haze Rule requires the State of Connecticut to consult 

with other states/tribes to develop coordinated emission management strategies. This 

requirement applies both when emissions from a state/tribe are reasonably anticipated to 

contribute to visibility impairment in Class I areas outside the state/tribe and when emissions 

from other states/tribes are reasonably anticipated to contribute to visibility impairment at 

mandatory Class I areas within a state/tribe. Connecticut does not have any Class I areas. 

Connecticut consulted with other states/tribes by participating in the MANE-VU and interRPO processes leading to the creation of coordinated strategies on regional haze. This 

coordinated effort considered the individual and aggregated impacts of states’/tribes’ 

emissions on Class I areas within and outside the states/tribes. 

As described in Section 2.0, Areas Contributing to Regional Haze, emissions originating in 

Connecticut have had, and will continue to have, impacts on other Class I areas in the region. 

Accordingly, Connecticut has entered into consultations with the states in which the affected 

Class I areas are located (Table 3.4). 

Table 3.4: Class I Area States Requesting Consultation with Connecticut 

Class I Federal Area State / Province 

 Great Gulf Wilderness New Hampshire 

 Presidential Range - Dry River Wilderness New Hampshire 

 Acadia National Park Maine 

 Moosehorn Wilderness Maine 

 Roosevelt Campobello International Park Maine 

 Lye Brook Wilderness Vermont 

 Brigantine Wilderness New Jersey 

3.2.2 The MANE-VU “Ask” 

In addition to having a set of guiding principles for consultation (as described in Table 3.2, 

above), MANE-VU needed a consistent technical basis for emission control strategies to 

combat regional haze. After much research and analysis, on June 20, 2007, MANE-VU 

adopted the following pair of documents (available in Attachment E), which provide the 

technical basis for consultation among the interested parties and define the basic strategies for 

controlling pollutants that cause visibility impairment at Class I areas in the eastern U.S.: 

• “Statement of the Mid-Atlantic / Northeast Visibility Union (MANE-VU) Concerning a 

Course of Action within MANE-VU toward Assuring Reasonable Progress,” and 

• “Statement of the Mid-Atlantic / Northeast Visibility Union (MANE-VU) Concerning a 

Request for a Course of Action by States outside of MANE-VU toward Assuring 

Reasonable Progress.” 

Together, these documents are known as the MANE-VU “Ask.” Connecticut agrees to the 

language and substance of these documents, and is therefore pursuing emission reductions 

consistent with them. The particular emission management strategies that comprise the “Ask” 

are described in Subparts 3.2.2.1 through 3.2.2.3, below. 
Connecticut Regional Haze Page 3-8 

State Implementation Plan November 2009 

3.2.2.1 Meeting the “Ask” – MANE-VU States 

The member states of MANE-VU have stated their intention to meet the terms of the “Ask” in 

their individual State Implementation Plans. The “Ask” for member states promises that each 

state will pursue the adoption and implementation of the following emission management 

strategies, as appropriate and necessary: 

• Timely implementation of BART requirements, in accordance with 40 CFR 

51.308(e). 

• 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 reduce the sulfur content of distillate oil 

further to 15 ppm by 2016; 

• A low-sulfur fuel oil strategy in the outer zone states (the remainder of the MANEVU 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 reduce the sulfur content of distillate oil further to 15 ppm by 

2018, depending on supply availability; 

• A targeted EGU strategy for the top 100 electric generating unit (EGU) emission 

points, or stacks, identified by MANE-VU as contributing to visibility impairment at 

each mandatory Class I area in the MANE-VU region. (The combined list for all 

seven MANE-VU Class I Areas contains 167 distinct emission points. Consequently, 

this strategy is sometimes referred to as the 167-stack strategy.) The targeted EGU 

strategy calls for a ninety percent or greater reduction in sulfur dioxide (SO2) emissions 

from all identified units. If it is infeasible to achieve that level of reduction from 

specific units, equivalent alternative measures will be pursued in such state; and 

• Continued evaluation of other control measures, including improvements in energy 

efficiency, use of alternative (clean) fuels, further control measures to reduce SO2 and 

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

standards for wood combustion. These and other measures will be evaluated during 

the consultation process to determine whether they are reasonable strategies to pursue. 

Ö CTDEP supports the SIPs of each of its fellow MANE-VU states, provided that these 

commitments are incorporated into approvable State Implementation Plans. 

3.2.2.2 Meeting the “Ask” – Connecticut 

Connecticut, being a MANE-VU member state, participated in the development of the 

MANE-VU “Ask” which was approved by the MANE-VU Board on June 20, 2007. 

Connecticut intends to meet the terms of this agreement as follows: 

• By demonstrating BART equivalency through its existing regulations (for additional 

details, refer to Section 9.0, Best Available Retrofit Technology (BART)). 
Connecticut Regional Haze Page 3-9 

State Implementation Plan November 2009 

• All of Connecticut’s BART-eligible sources, as well as all NOx Budget 

Program/CAIR sources, meet the recommended residual oil content or use lower 

sulfur content residual oil than specified in MANE-VU’s low-sulfur fuel oil strategy 

as a result of Regulations of Connecticut State Agencies section 22a-174-19a. In 

terms of a state-wide limitation of #4 residual oil to 0.25-0.5% by weight by no later 

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

than 2018, CTDEP has done a preliminary analysis of the potential number of sources 

impacted. Given regional fuel supply issues, such a limitation in Connecticut is 

dependent on multi-state implementation. CTDEP continues to participate in 

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

consistent with the MANE-VU “Ask”. 

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

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

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

such fuels. Therefore, implementation of the 500 ppm limitation in Connecticut is 

contingent upon New York, Massachusetts and Rhode Island adopting a 500 ppm 

limitation for heating distillate oil and off-road diesel oil. Regarding the reduction of 

sulfur content of distillate oil to 15 ppm by 2018 component of the MANE-VU “Ask”, 

Connecticut continues to work with other states in the region and the fuel industry to 

take steps to implement reductions consistent with the MANE-VU “Ask” in the most 

efficient and reasonable manner. 

• None of Connecticut’s EGUs fall on the list of the top 167 contributing EGU emission 

points. 

• CTDEP is currently evaluating other control measures including energy efficiency, 

alternative clean fuels, and other measures to reduce SO2 and NOx emissions from all 

coal-burning facilities by 2018. CTDEP will evaluate new source performance 

standards for wood combustion. 

CTDEP will provide an update of the progress towards meeting the MANE-VU “Ask” in its 

first progress report in support of this Regional Haze SIP, to be submitted five years from the 

date of final submittal of this SIP. 

3.2.2.3 Meeting the “Ask” – States outside MANE-VU 

Connecticut agrees with the MANE-VU “Ask” for consulting states outside the MANE-VU 

region. This “Ask” requests the affected states to pursue adoption and implementation of the 

following control strategies, as appropriate and necessary: 

• Timely implementation of BART requirements, as described for the MANE-VU 

states; 

• A targeted EGU strategy, as described for the MANE-VU states, for the top 167 EGU 

stacks contributing the most to visibility impairment at mandatory Class I areas in the 

MANE-VU region, or an equivalent SO2 emission reduction within each state;
Connecticut Regional Haze Page 3-10 

State Implementation Plan November 2009 

• Installation of reasonable control measures on non-EGU sources by 2018 to achieve 

an additional 28 percent reduction in non-EGU SO2 emissions beyond current on-thebooks/on-the-way (OTB/OTW) measures, resulting in an emission reduction that is 

equivalent to that from MANE-VU’s low-sulfur fuel oil strategy (see Section 11.0, 

Long-Term Strategy); 

• Continued evaluation of other control measures, including additional reductions in 

SO2 and NOX emissions from all coal-burning facilities by 2018 and promulgation of 

new source performance standards for wood combustion. These and other measures 

will be evaluated during the consultation process to determine whether they are 

reasonable strategies to pursue. 

Ö CTDEP looks for each consulting state to address specifically, in its Regional Haze 

SIP, each element of the MANE-VU “Ask”. 

CTDEP is concerned that non-MANE-VU states may be inclined not to adopt MANE-VU’s 

“Ask” because of the associated costs, potential conflicts, and relative lack of perceived 

benefits within their jurisdictions. On the basis of consultations held, MANE-VU members 

believe that some non-MANE-VU states will choose not to pursue reductions beyond CAIRequivalent controls and other measures pertaining to BART requirements. Connecticut 

understands that, among non-MANE-VU states that have already submitted their regional 

haze SIPs to EPA, a number of the affected states have decided not to address major elements 

of the MANE-VU “Ask” in their plans. 

There are some positive developments, however. Many states of the MRPO are working with 

MANE-VU states to investigate the potential for widespread use of low-sulfur fuel oil and 

installation of emission controls on ICI boilers within their region. The Midwest states would 

be more likely than Southeast states to adopt a low-sulfur oil strategy because the VISTAS 

states do not have the same extent of fuel oil usage and lack the inventory infrastructure found 

in more northerly states. Both MRPO and VISTAS claim that a substantial portion of the top 

167 contributing EGU stacks will be controlled. However, instead of taking concrete actions on 

uncontrolled or under-controlled facilities, many of these states appear to be satisfied with 

meeting CAIR-equivalent requirements and not looking beyond this level of emission controls for 

additional emission reductions. Further discussion of these issues is provided in Subsection 3.2.4, 

below. 

3.2.3 Technical Ramifications of Differing Approaches 

MANE-VU states intended to develop a modeling platform that was common in terms of 

meteorology and emissions with each of the other nearby RPOs. The RPOs worked hard to 

form a common set of emissions with similar developmental assumptions. Even with the best 

of intentions, it became difficult to keep up with each RPO’s updates and corrections. Each 

rendition of emissions inventory improved its quality, but even a single update to one RPO’s 

emissions required each of the other RPOs to adopt the updates. With each rendition, the 

revised emissions had to be re-blended with the full set of emission files for all associated 

RPOs in the modeling domain. Because each rendition put previous modeling efforts out of 

date, and a single modeling run could take more than a month to complete, inventory updates 

have contributed to SIP delays. Most states missed the required Regional Haze SIP filing date 
Connecticut Regional Haze Page 3-11 

State Implementation Plan November 2009 

of December 17, 2007. The RPOs also took differing perspectives on which version of the 

EGU dispatching model to use. At the beginning of the process, ICF International’s 

Integrated Planning Model (IPM) version 2.1.9 was available, and EPA agreed to its use for 

emissions preparation. Subsequently, IPM version 3.0 became available and was preferred by 

some users because of its updated fuel costs. MRPO adopted IPM v3.0 for its use, but 

VISTAS stayed with IPM v2.1.9. Rather than develop non-comparative datasets for its 

previous IPM analyses, MANE-VU opted also to remain with IPM v2.1.9. Therefore, for the 

three eastern RPOs, differing emissions assumptions eventually worked their way into the 

final set of modeling assumptions. 

MANE-VU’s most recent visibility projections take into account on-the-books/on-the-way 

(OTB/OTW) emissions control programs for 2018, and go further by including additional 

reasonable controls in the region, as developed through the MANE-VU “Ask”. It should be 

noted that other RPOs may not have included such measures in their final modeling and, as a 

result, may have been able to complete their analyses ahead of Connecticut’s. Where that is 

the case, those states’ modeling results will be inconsistent with meeting the terms of the 

“Ask” – a situation that may not be adequately addressed in their individual SIPs. 

3.2.4 Consultation Issues 

40 CFR 51.308(d)(1)(iv) of the Regional Haze Rule describes another consultation 

requirement for Class I states. If a contributing state does not agree with a Class I state on its 

reasonable progress goal, the Class I state must describe in its SIP submittal the actions taken 

to resolve the disagreement. 

While states without Class I areas are required to consult at the request of states with Class I 

areas, the Regional Haze Rule does not actually require the states to agree on a common 

course of action. Instead, if agreement cannot be reached, the disagreement needs to be 

described in each state’s SIP along with a description of what actions were taken to resolve the 

disagreement. All of the MANE-VU states worked together to strategize on how to develop a 

common approach to meeting the “Ask”. All states involved in these discussions found that 

working together helped them to develop plans that would produce region-wide visibility and 

health benefits. In particular, reductions in SO2 emissions, because they would yield lower 

ambient concentrations of fine particle (PM2.5) pollution, would help all MANE-VU states in 

meeting the NAAQS and would have direct benefits to public health and welfare. 

A few non-MANE-VU states did not respond to MANE-VU Class I state’s consultation 

requests or responded by downplaying the magnitude of their states’ contributions to visibility 

impairment at MANE-VU’s Class I areas. Some states claimed that CAIR alone set the 

standard for reasonableness. By this rationale, any measure more expensive than CAIR on a 

cost-per-ton basis would not be reasonable. A uniform rate of progress was all that some 

states felt was required; and if that set of conditions could be met with CAIR, then no other 

measures needed to be considered. Also a concern for Connecticut is the possibility that some 

states may have performed modeling for establishment of reasonable progress goals without 

including the effects of a rigorous BART determination for the non-EGU sector. It is 

apparent that the various regions of the country have differing interpretations of how the 

Regional Haze Rule should be applied. 
Connecticut Regional Haze Page 3-12 

State Implementation Plan November 2009 

In a letter to MANE-VU dated April 25, 2008 (Attachment F), VISTAS indicated that for its 

member states, most actions exceeding CAIR requirements would not be reasonable. MANEVU has taken a more rigorous position with respect to additional control measures – including 

the belief that controls on ICI boilers and use of low-sulfur fuels are reasonable measures and

that it is not reasonable to assume reductions from EGUs for planning purposes unless they 

are explicitly incorporated into a State Implementation Plan. More specifically, MANE-VU 

believes that a sector-wide average of 50-percent control on coal-fired boilers and 75-percent 

control on oil-fired boilers are reasonable targets that can be achieved cost-effectively. Also, 

MANE-VU believes that low sulfur fuels – even though they are less widely available in the 

Southeast than in the Northeast – still represent a reasonable control measure in light of the 

widespread requirement for use of such fuels throughout the MANE-VU region. The 

reasonableness of these additional controls is examined more fully in Section 10.0, 

Reasonable Progress Goals. 

During the consultation process, disagreements such as these were worked through to the 

maximum extent possible, and the results of these consultations are summarized below: 

• Situation: BART analyses and projected controls were not fully incorporated into the 

VISTAS emissions inventory provided to MANE-VU. VISTAS stated that they 

would further review BART-applicable controls.

→ Outcome: In MANE-VU’s modeling to determine reasonable progress goals, 

MANE-VU made no adjustments to controls in the VISTAS region to reflect 

application of BART beyond the information that VISTAS provided. 

• Situation: The low-sulfur fuel oil strategy adopted by MANE-VU elicited concerns 

from MRPO and VISTAS as not being reasonable because of the limited availability 

of low-sulfur fuel oil and the historically lower usage of this fuel within their regions. 

→ Outcome: MANE-VU agreed to modify the “Ask” to reflect greater flexibility in 

providing for alternative measures that would produce a comparable rate of 

emission reductions. Accordingly, the “Ask” for non-MANE-VU states was 

modified to provide for an overall 28 percent reduction in SO2 emissions wherever 

they were found to be reasonable. In MANE-VU’s modeling to determine 

reasonable progress goals, SO2 emissions from non-EGU sources in non-MANEVU contributing states were reduced by this same amount. 

• Situation: MANE-VU received no response from other RPOs concerning non-EGU 

control measures that they did consider reasonable. 

→ Outcome: As a default position, MANE-VU’s modeling included emission 

adjustments for those regions based on MANE-VU’s own analyses of what 

constituted reasonable control measures from non-EGU sources (see Section 10.0, 

Reasonable Progress Goals). 

• Situation: The targeted EGU strategy was thought by some non-MANE-VU states to 

be too restrictive and too difficult to achieve. MANE-VU recognized that a 100-

percent compliance with this portion of the “Ask” was unlikely to occur because the 

CAIR trading market would probably dominate. However, MANE-VU had hoped that 

non-MANE-VU states would make a more concerted effort toward meeting this 

request. MANE-VU did receive a partial list of facilities that were expected to 
Connecticut Regional Haze Page 3-13 

State Implementation Plan November 2009 

comply. 

→ Outcome: For the top contributing EGU stacks located within the MANE-VU, 

MRPO, and VISTAS regions, expected emission reductions resulting from the 

“Ask” were distributed among facilities on the basis of recommendations received 

during inter- and intra-regional consultations. To maintain the CAIR emissions 

budget as predicted by the modeling, excess emission reductions (also predicted by 

the modeling) were uniformly added back to EGUs in all three regions. 

While the now-remanded CAIR would have been the primary determinant of which EGUs 

among the top 167 stacks would have been fitted with emission controls, MANE-VU 

recognized that these units are the primary sources affecting visibility in the MANE-VU 

states. For the initial planning, MANE-VU has allowed flexibility as to how other RPOs meet 

the “Ask”. However, MANE-VU expects that, over time, these actual facilities will need to 

be controlled if significant improvements in visibility at affected Class I areas are to be 

realized. 

MANE-VU believes that the goals of the “Ask” will be attained only by means of binding 

obligations to EGU emission reductions beyond the levels of control that CAIR would have 

provided. MANE-VU therefore maintains that additional federal action is needed to achieve 

the visibility benefits shown to be feasible through sensitivity modeling (see Attachment G, 

“MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, 

Pollution Apportionment, and Control Measure Benefits,” February 7, 2008) and 

demonstrated to be available at reasonable cost (see Attachment H, Alpine Geophysics, LLC, 

“Documentation of 2018 Emissions from Electric Generating Units in the Eastern United 

States for MANE-VU’s Regional Haze Modeling,” Final Report, August 16, 2009). 

MANE-VU’s position on this issue is formally expressed in its “Statement of the MidAtlantic / Northeast Visibility Union (MANE-VU) Concerning a Request for a Course of 

Action by the U.S. Environmental Protection Agency (EPA) toward Assuring Reasonable 

Progress,” adopted June 20, 2007. This statement, more commonly known as MANE-VU’s 

National Ask, is included in Attachment E. 

Although other RPOs did not adopt all of the same philosophies or processes for their regional 

haze SIPs, the consultation process maintains a central role in regional haze planning. 

Connecticut is pleased with the significant opportunities identified for ongoing consultation 

with other states concerning long-term strategies not only for regional haze mitigation but also 

for improved air quality in general. 

3.2.5 State/Tribe and Federal Land Manager Coordination 

CTDEP will continue to coordinate and consult with the Federal Land Managers (FLMs) 

during the development of future progress reports and plan revisions, as well as during the 

implementation of programs having the potential to contribute to visibility impairment in the 

mandatory Class I areas. 

40 CFR 51.308(i) of the Regional Haze Rule requires coordination between states/tribes and 

the FLMs. Opportunities have been provided by MANE-VU for FLMs to review and 

comment on each of the technical documents developed by MANE-VU
Connecticut Regional Haze Page 3-14 

State Implementation Plan November 2009 

and included in this SIP. Connecticut has identified agency contacts to the FLMs as required 

under 40 CFR 51.308(i)(1). Connecticut has consulted with the FLMs in the development of 

this plan and, in accordance with 40 CFR 51.308(i)(2), has provided the FLMs an opportunity 

for consultation, in person, at least 60 days prior to holding any public hearing on the SIP. 

This SIP was submitted to the FLMs on February 4, 2009 for review and comment. 

Pursuant to 40 CFR 51.308(i)(3), Connecticut has requested and received comments on this 

SIP from the Federal Land Managers. CTDEP received written preliminary comments from 

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

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

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

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

were received in a letter dated April 3, 2009 and final comments from the USFS were 

received in a letter dated April 8, 2009 (both sets of comments were received prior to the 

public hearing). The comments received from the FLMs and responses by CTDEP and a 

summary of the conference call are included in Attachment I of this plan. All of these 

documents were made available for public review during the comment period for this SIP 

(Note: The MANE-VU states also received comments from other stakeholders during the 

planning process; their comments can be found in Attachment J. [Both attachments will be 

available after the comment period.] 

The comments submitted by the FLMs were both general and specific; CTDEP appreciates 

the effort put forth by the FLMs. The comments were very helpful and will greatly assist 

CTDEP in developing an effective and approvable Regional Haze SIP. The NPS and USFWS 

were concerned that the draft SIP did not include an analysis for the full adoption of the 

MANE-VU Ask and they also recommended that additional demonstrations of the adequacy 

of the alternative BART approach be provided. The USFS stated that overall, Connecticut 

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

requirements of the Regional Haze Rule. Comments of a specific nature from the FLMs were 

relatively minor for the most part. CTDEP’s responses to the agencies’ comments are 

addressed point-by-point in the response document contained in Attachment I. 

40 CFR 51.308(i)(4) requires procedures for continuing consultation between the states/tribes 

and FLMs on the implementation of the visibility protection program. In particular, CTDEP 

will consult with the designated visibility protection program coordinators for the National Park 

Service, U. S. Fish and Wildlife Service, and the U.S. Forest Services periodically and as 

circumstances require, on the following implementation items. 

1. Status of emissions strategies identified in the SIP as contributing to improvements in 

the worst-day visibility; 

2. Summary of major new source permits issued; 

3. Status of CTDEP’s actions toward completing any future assessments or rulemakings 

on sources identified as probable contributors to visibility impairment, but not directly 

addressed in the most recent SIP revision; 

4. Work underway for preparing the 5-year SIP review and/or 10-year SIP revision, 

including any items where the FLMs’ consideration or support is requested; and
Connecticut Regional Haze Page 3-15 

State Implementation Plan November 2009 

 5. Summary of topics discussed in ongoing communications (e.g., meetings, emails, etc.) 

between CTDEP and the FLMs regarding implementation of the visibility 

improvement program. 

3.2.6 EPA Consultation and Review 

Connecticut has consulted with EPA in the course of regional haze modeling and plan 

development, and EPA has provided specific input regarding completion of the draft SIP. On 

May 22, 2008, CTDEP received written comments from EPA on a draft of the BART section 

of the regional haze SIP that was submitted for preliminary review. On April 3, 2009, 

CTDEP received additional written comments from EPA on a version of CTDEP’s draft 

regional haze SIP, identical to the draft SIP reviewed by the FLMs. Connecticut has 

addressed EPA’s comments by making appropriate amendments to the draft SIP, all of which 

are incorporated into the present document. EPA’s specific comments and CTDEP’s 

responses are included in Attachment I. 
Connecticut Regional Haze Page 4-1 

State Implementation Plan November 2009 

4.0 ASSESSMENT OF BASELINE AND NATURAL VISIBILITY CONDITIONS 

Pursuant to 40 CFR 51.308(d)(2) of the Regional Haze Rule, states must determine baseline and 

natural visibility conditions for each Class I area within their jurisdictions. This information 

allows states to assess current levels of visibility degradation and provides a basis for setting 

reasonable progress goals toward restoration of natural visibility conditions in Class I areas. 

The effectiveness of any plan to reduce regional haze in Class I areas is dependent on the 

availability of reliable data. The Interagency Monitoring of Protected Visual Environments 

(IMPROVE) program was established in 1985 to provide the data necessary to support the 

creation of Federal and State implementation plans for the protection of visibility in Class I 

areas. IMPROVE has made it possible to assess current visibility conditions, track changes in 

visibility, and identify the chemical species and emission sources responsible for visibility 

impairment. In particular, IMPROVE data were used to calculate baseline and natural 

conditions for MANE-VU Class I Areas. 

The IMPROVE monitors listed in Table 4.1 provide data representative of Class I Areas in 

the MANE-VU region. 

Table 4.1: IMPROVE Monitors for MANE-VU Class I Areas 

IMPROVE Site / Location Class I Area(s) Served Latitude, 

Longitude State 

ACAD1 

Acadia National Park Acadia National Park 44.38, -68.26 Maine 

MOOS1 

Moosehorn Wilderness 

Moosehorn Wilderness 

Roosevelt Campobello 

International Park 

45.13, -67.27 Maine 

GRGU1 

Great Gulf Wilderness 

Great Gulf Wilderness 

Presidential Range – Dry 

River Wilderness 

44.31, -71.22 New Hampshire 

LYBR1 

Lye Brook Wilderness Lye Brook Wilderness 43.15, -73.13 Vermont 

BRIG1 

Brigantine National 

Wildlife Refuge 

Brigantine National 

Wildlife Refuge 39.47, -74.45 New Jersey 

 http://www.vista.circa.colostate.edu/views/; http://vista.cira.colostate.edu/improve/

4.1 Calculation Methodology 

In September 2003, EPA issued guidance for the calculation of natural background and 

baseline visibility conditions. The guidance provided a default method and described certain 

refinements that states might consider in order to tailor their estimates to any Class I areas not 

adequately represented by the default method. At that time, MANE-VU calculated natural 

visibility for each of the MANE-VU Class I Areas using the default method for the 20 percent 

best and 20 percent worst visibility days. MANE-VU also evaluated ways to refine the 

estimates. Potential refinements included 1) increasing the multiplier used to calculate 
Connecticut Regional Haze Page 4-2 

State Implementation Plan November 2009 

impairment attributed to carbon, 2) adjusting the formula used to calculate the 20 percent best 

and worst visibility days, and 3) accounting for visibility impairment caused by sea salt at 

coastal sites. However, MANE-VU found that these refinements did not significantly 

improve the accuracy of the estimates, and MANE-VU states desired a consistent approach to 

visibility assessment. Therefore, default estimates were used with the understanding that this 

methodology would be reconsidered upon demonstrated improvements in the science. 

Once the technical analysis of visibility conditions was complete, MANE-VU provided an 

opportunity to comment to federal agencies and stakeholders. The proposed approach to 

visibility assessment was posted on the MANE-VU website on March 17, 2004, and a 

stakeholder briefing was held on the same day. Comments were received from the Electric 

Power Research Institute (EPRI), the Midwest Ozone Group (MOG), the Appalachian 

Mountain Club, the National Parks Conservation Association, the National Park Service, and 

the US Forest Service. 

Several comments supported the proposed approach in general; other comments were divided 

among four main topics: 1) the equation used to calculate visibility, 2) the statistical technique 

used to estimate the 20 percent best and worst visibility days, 3) the inclusion of 

transboundary effects and fires, and 4) the timing as to when new information should be 

included. All comments were reviewed and summarized by MANE-VU; and air directors 

were briefed on comments, proposed response options, and implications. Attachment J 

provides a compilation of comments received and a summary of stakeholders’ comments. 

MANE-VU’s position on natural background conditions was presented in a report issued in 

June 2004 (see Attachment K, “Natural Background Visibility Conditions: Considerations and 

Proposed Approach to the Calculation of Natural Background Visibility Conditions at 

MANE-VU Class I Areas,” June 10, 2004). The report stated, “Refinements to other aspects 

of the default method (e.g., refinements to the assumed distribution or treatment of Rayleigh 

extinction, inclusion of sea salt, and improved assumptions about the chemical composition of 

the organic fraction) may be warranted prior to submission of SIPs depending on the degree to 

which scientific consensus is formed around a specific approach...” 

In 2006, the IMPROVE Steering Committee adopted an alternative reconstructed extinction 

equation to revise certain aspects of the default method. The scientific basis for these 

revisions was well understood, and the Committee determined that the revisions improved the 

performance of the equation at reproducing observed visibility at Class I sites. 

In 2006, MANE-VU conducted an assessment of the default and alternative approaches for 

calculation of baseline and natural background conditions at MANE-VU Class I Areas. 

Based on that assessment, in December 2006, MANE-VU recommended adoption of the 

alternative reconstructed extinction equation for use in the regional haze SIPs. (See 

Attachment L, “Baseline and Natural Background Visibility Conditions: Considerations and 

Proposed Approach to the Calculation of Baseline and Natural Background Visibility 

Conditions at MANE-VU Class I Areas,” December 2006.) MANE-VU will continue to 

participate in further research efforts on this topic and will reconsider the calculation 

methodology as scientific understanding evolves. 
Connecticut Regional Haze Page 4-3 

State Implementation Plan November 2009 

4.2 MANE-VU Baseline Visibility 

The IMPROVE program has calculated the 20 percent best and 20 percent worst baseline 

(2000-2004) and natural visibility conditions using the EPA-approved alternative method 

described above for each MANE-VU Class I Area. The data are posted on the Visibility 

Information Exchange Web System (VIEWS) operated by the regional planning 

organizations. The information can be accessed at http://vista.cira.colostate.edu/views/) and 

is summarized in Table 4.2 below. Displayed are the five-year average baseline visibility 

values for the period 2000-2004, natural visibility levels, and the difference between baseline 

and natural visibility values for each of the MANE-VU Class I Areas. The difference 

columns (best and worst) are of particular interest because they describe the magnitude of 

visibility impairment attributable to manmade emissions, which are the focus of the Regional 

Haze Rule. 

The five-year averages for 20 percent best and worst visibility were calculated in accordance 

with 40 CFR 51.308(d)(2), as detailed in NESCAUM’s Baseline and Natural Background 

document found in Attachment L. 

Table 4.2: Summary of Baseline Visibility and Natural Visibility Conditions for the 

20 Percent Best and 20 Percent Worst Visibility Days at MANE-VU Class I Areas 

Class I Area(s) 

2000-2004 Baseline 

(deciviews) 

Natural Conditions 

(deciviews) 

Difference 

(deciviews) 

Best 

20% 

Worst 

20% 

Best 

20% 

Worst 

20% 

Best 

20% 

Worst 

20% 

Acadia National Park 8.8 22.9 4.7 12.4 4.1 10.5 

Moosehorn Wilderness and 

Roosevelt Campobello International Park 9.2 21.7 5.0 12.0 4.1 9.7 

Great Gulf Wilderness and 

Presidential Range – Dry River Wilderness 9 7.7 22.8 3.7 12.0 3.9 10.8 

Lye Brook Wilderness 6.4 24.5 2.8 11.7 3.6 12.7 

Brigantine Wilderness 14.3 29.0 5.5 12.2 8.8 16.8 

 Source: VIEWS (http://vista.circa.colostate.edu/views/), prepared on 6/22/2007 

 

9

 Based on 4-year average for 2001-2004 (data collection in 2000 was for summer only). 
Connecticut Regional Haze Page 5-1 

State Implementation Plan November 2009 

5.0 AIR MONITORING STRATEGY 

In the mid-1980’s, the Interagency Monitoring of Protected Visual Environments 

(IMPROVE) program was established to measure visibility impairment in mandatory Class I 

areas throughout the United States. The monitoring sites are operated and maintained through 

a formal cooperative relationship between the U.S. EPA, National Park Service, U.S. Fish and 

Wildlife Service, Bureau of Land Management, and U.S. Forest Service. In 1991, several 

additional organizations joined the effort: State and Territorial Air Pollution Program 

Administrators and the Association of Local Air Pollution Control Officials (which have since 

merged under the name National Association of Clean Air Agencies), Western States Air 

Resources Council, Mid-Atlantic Regional Air Management Association, and Northeast 

States for Coordinated Air Use Management. 

5.1 IMPROVE Program Objectives 

The IMPROVE program provides scientific documentation of the visual air quality of 

America’s wilderness areas and national parks. Many individuals and organizations – land 

managers; industry planners; scientists, including university researchers; public interest 

groups; and air quality regulators – use the data collected at IMPROVE sites to understand 

and protect the visual air quality resource in Class I areas. Major objectives of the IMPROVE 

program include the following: 

• Establish current visibility and aerosol conditions in mandatory Class I areas, 

• Identify chemical species and emission sources responsible for existing anthropogenic 

visibility impairment, 

• Document long-term trends for assessing progress towards the national visibility goals, 

and 

• Provide regional haze monitoring for all visibility-protected federal Class I areas 

where practical, as required by EPA’s Regional Haze Rule. 

5.2 Monitoring Requirements 

EPA’s Regional Haze Rule establishes air monitoring requirements that affected states must 

meet to assess visibility impairment caused by regional haze in Class I areas. The following 

describes how Connecticut is complying with specific sections of the rule: 

• 40 CFR 51.308(d)(4) requires a monitoring strategy for measuring, characterizing, and 

reporting regional haze / visibility impairment that is representative of all mandatory Class 

I areas within the state. Connecticut does not have any Class I areas, so this 

requirement is not applicable. This monitoring strategy must be coordinated with the 

additional requirements of 40 CFR 51.305 (reasonably attributable visibility 

impairment (RAVI)), which are not applicable to Connecticut either. 

• 40 CFR 51.308(d)(4)(i) requires states to establish additional monitoring sites or 

equipment as needed to assess whether reasonable progress goals are being achieved 

toward visibility improvement at mandatory Class I areas. Connecticut does not have 

any Class I areas, so this requirement is not applicable.

• 40 CFR 51.308(d)(4)(iii) requires, for a state with no mandatory Class I areas, 
Connecticut Regional Haze Page 5-2

State Implementation Plan November 2009 

procedures by which monitoring data and other information are used to determine the 

state’s contribution of emissions to visibility impairment at mandatory Class I areas 

outside the state. Connecticut’s contributions are summarized in Subsection 2.1 of 

this SIP and are documented in a detailed technical analysis prepared by NESCAUM 

entitled, “Contributions to Regional Haze in the Northeast and Mid-Atlantic United 

States,” August 2006 (Attachment B). The NESCAUM study used various tools and 

techniques to assess the contributions of individual states and regions to visibility 

degradation in Class I areas within and outside MANE-VU. 

• 40 CFR 51.308(d)(4)(iv) requires a state to submit visibility monitoring data annually 

for each Class I area in the state and, if possible, to provide the data in electronic 

format. Connecticut does not have any Class I areas, so this requirement is not 

applicable. 

• 40 CFR 51.308(d)(4)(v) requires a statewide inventory of emissions of pollutants that 

are reasonably anticipated to cause or contribute to visibility impairment in mandatory 

Class I areas. Section 6.0, Emissions Inventory, addresses this requirement. 

• 40 CFR 51.308(d)(4)(vi) requires that SIPs provide other elements, including 

reporting, recordkeeping, and other measures necessary to assess and report on 

visibility. While Connecticut believes the current IMPROVE network is sufficient to 

adequately measure and report progress toward the regional haze goals set for MANEVU’s Class I areas, CTDEP in the past has found additional monitoring information to 

be useful in assessing patterns of regional visibility and fine particle pollution. 

Examples of these data sources include: 

− The MANE-VU RAIN network, which provides continuous, speciated 

information on rural aerosol characteristics and visibility parameters; 

− The EPA CASTNET program, which has provided complementary rural fine 

particle speciation data at non-Class I sites; 

− The EPA Speciation Trends Network (STN), which provides speciated, urban 

fine particle data to help develop a comprehensive picture of local and 

regional sources; 

− State-operated rural and urban speciation sites using IMPROVE or Speciation 

Trends Network (STN) methods (the latter program comprising 54 monitoring 

stations located mainly in or near larger metropolitan areas); and 

− The Supersites program, which has undertaken special studies to expand knowledge 

of the processes that control fine particle formation and transport in the region. 

Assuming adequate resources, CTDEP will continue using these and other data sources for 

the purposes of understanding visibility impairment and documenting progress toward 

national visibility goals for Class I areas under the Regional Haze Rule. CTDEP agrees that 

the IMPROVE network is an appropriate monitoring network to track regional haze progress 

and encourages EPA to continue funding the IMPROVE network. CTDEP will work with 

other states and the FLMs to maintain the IMPROVE network to the extent resources are 

available. 

5.3 Monitoring Sites for MANE-VU Class I Areas 
Connecticut Regional Haze Page 5-3

State Implementation Plan November 2009 

Acadia National Park IMPROVE Site

Created by Tom Downs, MEDEP 4/17/07

IMPROVE MONITOR LOCATION

ACADIA NATIONAL PARK

LEGEND

http://www.maine.gov/dep/air/meteorology/images/Acadia.jpg

Figure 5.1: Map of Acadia National Park Showing 

Location of IMPROVE Monitor

IMPROVE monitoring sites have been established for each of the Class I areas in the region. 

The Great Gulf Wilderness and Presidential Range-Dry River Wilderness share a single 

monitoring site. Moosehorn Wilderness and Roosevelt Campobello International Park also 

share a monitoring site. Each of the other MANE-VU Class I Areas has its own monitoring 

site. 

5.3.1 Acadia National Park, Maine 

The IMPROVE monitor for Acadia National Park (ACAD1) is located at park headquarters, 

near Bar Harbor, Maine, at elevation 157 meters, latitude 44.38 ̊, and longitude -68.26 ̊. This 

monitor is operated and maintained by the National Park Service. Connecticut considers the 

ACAD1 site as adequate for assessing reasonable progress toward visibility goals at Acadia 

National Park, and no additional monitoring sites or equipment are necessary at this time. 

 
Connecticut Regional Haze Page 5-4

State Implementation Plan November 2009 

Figure 5.2: Acadia National Park on Clear and Hazy Days

 

http://www.hazecam.net/class1/acadia.html

5.3.2 Brigantine Wilderness, New Jersey 

The IMPROVE monitor for the Brigantine Wilderness (BRIG1) is located at the Edwin B. 

Forsythe National Wildlife Refuge Headquarters in Oceanville, New Jersey, at elevation 5 

meters, latitude 39.47 ̊, and longitude -74.45 ̊. This monitor is operated and maintained by the 

U.S. Fish & Wildlife Service. Connecticut considers the BRIG1 site as adequate for assessing 

reasonable progress toward visibility goals at the Brigantine Wilderness, and no additional 

monitoring sites or equipment are necessary at this time. 

Figure 5.3: Map of Edwin B. Forsythe National Wildlife Refuge 

http://www.fws.gov/northeast/forsythe/MAP.htm
Connecticut Regional Haze Page 5-5

State Implementation Plan November 2009 

IMPROVE MONITOR 

Figure 5.4: Brigantine Wilderness on Clear and Hazy Days 

 

 http://www.hazecam.net/class1/brigantine.html

5.3.3 Great Gulf Wilderness, New Hampshire 

The IMPROVE monitor for the Great Gulf Wilderness (GRGU1) is located at Camp Dodge, 

in the mid-northern area of Greens Grant in the White Mountain National Forest. The 

monitor site lies just east and south of where Route 16 crosses the Greens Grant / Martins 

Location boundary, south of Gorham, New Hampshire, at elevation 454 meters, latitude 

44.31 ̊, and longitude of -71.22 ̊. This monitor, which also represents the Presidential Range 

– Dry River Wilderness (see 5.3.4 below), is operated and maintained by the U.S. Forest 

Service. Connecticut considers the GRGU1 site as adequate for assessing reasonable progress 

toward visibility goals at the Great Gulf Wilderness, and no additional monitoring sites or 

equipment are necessary at this time. 

Figure 5.5: Map of Great Gulf and Presidential Range – Dry River Wilderness Areas 

Showing Location of IMPROVE Monitor 

 http://www.maine.gov/dep/air/meteorology/images/NHclass1.jpg
Connecticut Regional Haze Page 5-6

State Implementation Plan November 2009 

Figure 5.6: Great Gulf Wilderness on Clear and Hazy Days 

5.3.4 Presidential Range – Dry River Wilderness, New Hampshire 

The IMPROVE monitor for the Presidential Range – Dry River Wilderness is also the 

monitor for Great Gulf Wilderness (GRGU1), as described above. Connecticut considers the 

GRGU1 site as adequate for assessing reasonable progress toward visibility goals at the 

Presidential Range – Dry River Wilderness, and no additional monitoring sites or equipment 

are necessary at this time. 

Figure 5.7: Presidential Range – Dry River Wilderness in Autumn 

 http://www.wilderness.net

5.3.5 Lye Brook Wilderness, Vermont 

The IMPROVE monitor for the Lye Brook Wilderness (LYBR1) is located on Mount 

Equinox at the windmills in Manchester, Vermont, at elevation 1015 meters, latitude 43.15 ̊, 

and longitude of -73.13 ̊. The monitor does not lie within the wilderness area but is situated 

on a mountain peak across the valley to the west of the wilderness area. The IMPROVE site 

and the Lye Brook Wilderness are at similar elevations. The monitor is operated and 

maintained by the U.S. Forest Service. Connecticut considers the LYBR1 site as adequate for 

 http://www.wilderness.net
Connecticut Regional Haze Page 5-7

State Implementation Plan November 2009 

assessing reasonable progress toward visibility goals at the Lye Brook Wilderness, and no 

additional monitoring sites or equipment are necessary at this time. 

Figure 5.8: Location of Lye Brook Wilderness IMPROVE Monitor 

 http://www.wilderness.net/index.cfm?fuse=NWPS&sec=stateView&state=NH&map=menhvt

Figure 5.9: Aerial View of Lye Brook Wilderness IMPROVE Monitoring Site 

 sources: GoogleEarth: and Paul Wishinski Vermont DEC, Air 

Pollution Control Division

IMPROVE MONITOR SITE 

APPROX. WILDERNESS 

IMPROVE MONITOR SITE 
Connecticut Regional Haze Page 5-8

State Implementation Plan November 2009 

Figure 5.10: Lye Brook Wilderness on Clear and Hazy Days 

 

 http://www.hazecam.net/class1/lye.html

5.3.6 Moosehorn Wilderness, Maine 

The IMPROVE monitor for the Moosehorn Wilderness (MOOS1) is located near McConvey 

Road, about one mile northeast of the National Wildlife Refuge Baring (ME) Unit 

Headquarters, at elevation 78 meters, latitude 45.13 ̊, and longitude -67.27 ̊. This monitor 

also represents the Roosevelt Campobello International Park in New Brunswick, Canada. The 

monitor is operated and maintained by the U.S. Fish & Wildlife Service. Connecticut 

considers the MOOS1 site as adequate for assessing reasonable progress toward visibility 

goals at the Moosehorn Wilderness, and no additional monitoring sites or equipment are 

necessary at this time. 

Figure 5.11: Moosehorn Wilderness on Clear and Hazy Days 

 http: //www.hazecam.net/moosehorn.html 
Connecticut Regional Haze Page 5-9

State Implementation Plan November 2009 

Figure 5.12: Map of the Baring and Edmunds Divisions of the Moosehorn National 

Wildlife Refuge Showing Location of IMPROVE Monitor 

5.3.7 Roosevelt Campobello International Park, New Brunswick, Canada 

The IMPROVE monitor for Roosevelt Campobello International Park is also the monitor for 

the Moosehorn Wilderness (MOOS1), as described above. Connecticut considers the MOOS1 

site as adequate for assessing reasonable progress toward visibility goals at Roosevelt 

Campobello International Park, and no additional monitoring sites or equipment are necessary 

at this time. 
Connecticut Regional Haze Page 5-10

State Implementation Plan November 2009 

Figure 5.13: Map of Roosevelt Campobello International Park 

 http://www.maine.gov/dep/air/meteorology/images/rcip.jpg

Figure 5.14: Roosevelt Campobello International Park on Clear and Hazy Days 
Connecticut Regional Haze Page 6-1 

State Implementation Plan November 2009 

source: Chessie Johnson 

6.0 EMISSIONS INVENTORY 

40 CFR 51.308(d)(4)(v) of EPA’s Regional Haze Rule requires a statewide emissions 

inventory of pollutants that are reasonably anticipated to cause or contribute to visibility 

impairment in any mandatory Class I area. The inventory must include emissions for a 

baseline year, future (projected) year, and the most recent year for which data are available. 

Connecticut’s baseline year, 2002, is also the most recent year for which data are available. 

The pollutants inventoried include nitrogen oxides (NOX), sulfur dioxides (SO2), volatile 

organic compounds (VOCs), fine particles (particulate matter less than 2.5 micrometers in 

diameter, or PM2.5), coarse particles (particulate matter less than 10 micrometers in diameter, 

or PM10), and ammonia (NH3). The following source categories were included in the 

emissions inventory: stationary point sources, stationary area sources, on-road mobile sources, 

non-road mobile sources, and biogenic sources. These emissions categories are discussed 

further in Subsection 7.3, Model Platforms. 

6.1 Baseline and Future-Year Emissions Inventories for Modeling 

40 CFR 51.308(d) (3) (iii) of EPA’s Regional Haze Rule requires the State of Connecticut to 

identify the baseline emissions inventory on which emission control strategies are founded. 

The baseline inventory is intended to be used for assessing progress in making emission 

reductions. In accordance with EPA’s guidance memorandum “2002 Base Year Emission 

Inventory SIP Planning: 8-hour Ozone, PM2.5, and Regional Haze Programs,” November 18, 

2002, all of the MANE-VU states are using 2002 as the baseline year for regional haze. 

Previously, on February 1, 2008, Connecticut submitted its 2002 baseline inventory to EPA to 

meet its implementation planning obligations under the 8-hour ozone program. It should be 

noted, however, that emissions inventories are not static documents, but are constantly revised 

and updated to reflect the input of better emissions estimates as they become available. With 

contractor assistance, MARAMA developed a 2002 baseline modeling inventory using the 

inventories that Connecticut and other states submitted to EPA to meet their SIP obligations 

and the requirements of the Consolidated Emissions Reporting Rule (CERR). To create the 

2002 baseline inventory for modeling, MARAMA and its contractor quality-assured and 

augmented states’ inventories and generated the necessary input files for the emissions 

processing model. As described in Subsection 6.1.1 below, work on this effort underwent 

several versions. Therefore, the 2002 baseline emissions summarized in this document may 

differ slightly from Connecticut’s original 2002 baseline inventory submittal. 
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State Implementation Plan November 2009 

Future-year inventories for 2009, 2012, and 2018 were projected from the 2002 base year. 

These future-year emissions inventories include emissions growth due to projected increases in 

economic activity as well as emissions reductions expected from the implementation of control 

measures. While the 2009 and 2012 emissions projections were originally developed in support 

of Connecticut’s and other states’ ozone attainment demonstrations, the inventory for 2018 (the 

year targeted by the Regional Haze Rule) was developed for the specific purposes of regional 

haze SIP planning. Therefore, although the 2009 and 2012 projected inventories are mentioned in 

subsequent sections, only the 2002 baseline inventory and 2018 projected inventory are described 

below in Subsection 6.4, Summary of Emissions Inventories. 

Accurate baseline and future-year emissions inventories are crucial to the analyses required 

for the regional haze SIP process. These emissions inventories were used to drive the air 

quality modeling simulations undertaken to assess the visibility improvements that would 

result from possible control measures. Air quality modeling was also used to perform a 

pollution apportionment, which evaluates the contribution to visibility impairment by 

geographic region and emission source sector. 

To be compatible with the air quality modeling simulations, the baseline and future-year 

emissions inventories were processed with the Sparse Matrix Operator Kernel Emissions 

(SMOKE) emissions pre-processor for subsequent input into the Community Mesoscale Air 

Quality (CMAQ) and Regional Model for Aerosols and Deposition (REMSAD) air quality 

models described in Subsection 7.3. Further description of the base and future-year emissions 

inventories is provided below. 

6.1.1 Baseline Inventory (2002) 

The starting point for the 2002 baseline emissions inventory was the 2002 inventory 

submittals that were made to EPA by state and local agencies as part of the CERR. With 

contractor assistance (E.H. Pechan & Associates, Inc.,), MANE-VU then coordinated and 

quality-assured the 2002 inventory data, and prepared it for input into the SMOKE emissions 

model. The 2002 emissions from non-MANE-VU areas within the modeling domain were 

obtained from other Regional Planning Organizations for their corresponding areas. These 

Regional Planning Organizations included the Visibility Improvement State and Tribal 

Association of the Southeast (VISTAS), the Midwest Regional Planning Organization 

(MRPO), and the Central Regional Air Planning Association (CenRAP). 

The 2002 baseline inventory went through several iterations. Work on Version 1 of the 2002 

MANE-VU inventory began in April 2004, and the final inventory and SMOKE input files 

were completed during January 2005. Work on Version 2 (covering the period of April 

through September 2005) involved incorporating revisions requested by some MANE-VU 

state/local agencies on the point, area, and on-road categories. Work on Version 3 (covering 

the period from December 2005 through April 2006) included additional revisions to the 

point, area, and on-road categories as requested by some states. Thus, the Version 3 inventory 

for point, area, and on-road sources was built upon Versions 1 and 2. This work also included 

development of the biogenic inventory. In Version 3, the non-road inventory was completely 

redone because of changes that EPA made to the NONROAD2005 non-road mobile 

emissions model. 
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State Implementation Plan November 2009 

Version 3 of the MANE-VU 2002 baseline emissions inventory was used in the regional air 

quality modeling simulations. Further description of the data sources, methods, and results 

for this version of the 2002 baseline inventory is presented in E.H. Pechan & Associates, Inc., 

“Technical Support Document for 2002 MANE-VU SIP Modeling Inventories, Version 3, 

November 20, 2006, also known as the Baseline Emissions Report (Attachment M). 

Emissions inventory data files are available on the MARAMA website at: 

http://www.marama.org/visibility/EI_Projects/index.html. 

6.1.2 Future-Year Emissions Inventories 

Future-year emissions inventories are provided in MACTEC’s technical support document, 

“Development of Emissions Projections for 2009, 2012, and 2018 for NonEGU Point, Area, 

and Nonroad Sources in the MANE-VU Region,” Final Report, February 28, 2007, also 

known as the Emission Projections Report (Attachment N). This document describes the data 

sources, methods, and modeling results for three future years, five emission source sectors, 

two emission control scenarios, seven pollutants, and eleven states plus the District of 

Columbia. The following summarizes the basic framework of the future-year inventories that 

were developed: 

• Projection years: 2009, 2012, and 2018; 

• Emission source sectors: point-source electric generating units (EGUs), point-source 

non-electric generating units (non-EGUs), area sources, non-road mobile sources, and 

on-road mobile sources. 

• Emission control scenarios: 

- A combined on-the-books/on-the-way (OTB/OTW) control strategy accounting 

for emission control regulations already in place as of June 15, 2005, as well as 

some emission control regulations that are not yet finalized but are expected to 

achieve additional emission reductions by 2009; and 

- A beyond-on-the-way (BOTW) scenario to account for controls from potential 

new regulations that may be necessary to meet attainment and other regional 

air quality goals, mainly for ozone. 

- An updated scenario (sometimes referred to as “best-and-final”) to account for 

additional potentially reasonable control measures. For the MANE-VU region, 

these include: SO2 reductions at a set of 167 EGUs which were identified as 

contributing to visibility impairment at northeast Class I areas; implementation 

of a low-sulfur fuel strategy for non-EGU sources; and implementation of a 

Best Available Retrofit Technology (BART) strategy for BART-eligible 

sources not controlled under other programs. 

(Note: Refer to Section 11.0, Long-Term Strategy, for detailed descriptions of specific 

control strategies.) 

• Pollutants: ammonia, carbon monoxide (CO), oxides of nitrogen (NOX), sulfur 

dioxide (SO2), volatile organic compounds (VOCs), fine particulate matter (PM2.5, 

sum of filterable and condensable components), and coarse particulate matter (PM10, 

sum of filterable and condensable components). 

• States: Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, 

New Jersey, New York, Pennsylvania, Rhode Island, and Vermont, plus the District of 
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State Implementation Plan November 2009 

Columbia (all members of the MANE-VU region). 

6.2 Emission Processor Selection and Configuration 

The Sparse Matrix Operator Kernel Emissions (SMOKE) model was used to format the 

emissions inventories for use with the air quality models that are discussed in Subsection 7.3. 

SMOKE is primarily an emissions processing system, as opposed to a true emissions 

inventory preparation system, in which emissions estimates are simulated from “first 

principles.” This means that, with the exception of mobile and biogenic sources, SMOKE’s 

purpose is to provide an efficient, modern tool for converting emissions inventory data into 

the formatted emissions files required for a photochemical air quality model. The SMOKE 

emissions processing that was performed in support of the air quality modeling for regional 

haze is described further in Subsection 7.2. 

6.3 Inventories for Specific Source Categories 

There are five emission source classifications in the emissions inventory, as follows: 

• Stationary point, 

• Stationary area, 

• Non-road mobile, 

• On-road mobile, and 

• Biogenic. 

Stationary point sources are large sources that emit greater than a specified tonnage per year, 

as described below. Stationary area sources are those sources whose individual emissions 

are relatively small (i.e., dry cleaners, service stations, agricultural areas, fires, etc.), but 

because of the large number of these sources, their collective emissions are significant. Nonroad mobile sources are equipment that can move but do not use the roadways (i.e., lawn 

mowers, construction equipment, railroad locomotives, marine vessels, aircraft, etc.). Onroad mobile sources include automobiles, trucks, buses, and motorcycles that use the 

roadway system. Biogenic sources include natural sources such as trees, crops, grasses, and 

natural decay of plants. 

The subsections below give an overview of each of the source categories and the methods that 

were used to develop their corresponding baseline and future-year emissions estimates. All 

emissions data were prepared for modeling in accordance with EPA guidance. 

6.3.1 Stationary Point Sources 

Point source emissions are emissions from large individual sources. Generally, point sources 

have permits to operate, and their emissions are individually calculated based on sourcespecific parameters. Emissions estimates for point sources are usually made on a regular 

basis, and the largest point sources are inventoried annually. Sources with emissions greater 

than or equal to 100 tons per year (tpy) of a criteria pollutant (Connecticut threshold is 25/50 

tpy for NOx and VOC, depending on the non-attainment area), 10 tpy of a single hazardous air 

pollutant (HAP), or 25 tpy for total HAPs are considered to be major sources. Emissions 

from smaller point sources are also calculated individually but less frequently. Point sources 
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State Implementation Plan November 2009 

are further subdivided into EGUs and non-EGUs. 

6.3.1.1 Electric Generating Units (EGUs) 

The base-year inventory for EGU sources were based on 2002 continuous emissions 

monitoring (CEM) data reported to EPA in compliance with the Acid Rain Program or 2002 

state emissions inventory data. The CEM data provided actual hourly emission values used in 

the modeling of SO2 and NOX emissions from these large sources. See Chapter II, Section 

A.2.a.i of the “Technical Support Document for 2002 MANE-VU SIP Modeling Inventories”, 

Version 3 (Attachment M) for a discussion of the quality assurance steps performed on the 

CEM data that were included in the 2002 baseline modeling inventory. Emissions of other 

pollutants (e.g., VOCs, CO, NH3, and PM2.5) were provided by the states in most instances. 

Future-year inventories of EGU emissions for 2009, 2012 and 2018 (see Attachment H for 

emission summaries) were developed using ICF International’s Integrated Planning Model 

(IPM) to forecast growth in electric demand and replacement of older, less efficient and more 

polluting power plants with newer, more efficient and cleaner units. This effort was 

undertaken by an inter-RPO workgroup. 

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

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

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

inventory upon which the reasonable progress goals were set. 

The IPM model results do not provide a reliable basis upon which to predict EGU closures. 

Preliminary modeling was performed with unchanged IPM 2.1.9 model results. However, 

prior to the most recent modeling, future-year EGU inventories were adjusted as follows: 

• First, IPM predictions were reviewed by permitting and enforcement staff of the 

MANE-VU states. In many cases, staff believed that the IPM shutdown predictions 

were unlikely to occur. In particular, many oil-fired EGUs in urban areas were 

predicted to be shut down by IPM. Similar source information was solicited from 

states in both VISTAS and MRPO. As a result of this model validation, the IPM 

modeling output was adjusted before the most recent modeling to reflect staff 

knowledge of specific plant status in MANE-VU, VISTAS, and MRPO states. Where 

expected EGU operating status was contrary to what was predicted by IPM modeling, 

the future-year emissions inventory was adjusted to reflect the expected operation of 

those plants. No operating status adjustments were made to Connecticut sources. 

• Second, as a result of inter- and intra-RPO consultations, MANE-VU agreed to pursue 

certain emission control measures (see Section 3.0, Regional Planning). For EGUs, 

the agreed-upon approach was to pursue emission reductions from each of the top 167 

stacks located in MANE-VU, MRPO, and VISTAS that contributed the most to 

visibility impairment at any Class I area in the MANE-VU region (none are located in 

Connecticut). This approach, known as the targeted EGU strategy, is further described 

in Section 11.0 of this SIP. 

6.3.1.2 Non-EGU Point Sources 

The primary basis for the 2002 baseline non-EGU emissions inventory was data reported by 
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State Implementation Plan November 2009 

state and local agencies for the CERR. As described in Subsection 6.1.1, MANE-VU’s 

contractor, E.H. Pechan & Associates (Pechan), coordinated the quality assurance of the 

inventory and prepared the necessary files for input into the SMOKE emissions model. Further 

information on the preparation of the MANE-VU 2002 baseline point source modeling emissions 

inventory can be found in Chapter II of the Baseline Emissions Report (Attachment M). 

 

Projected non-EGU point source emissions were developed for the MANE-VU region by 

MACTEC Federal Programs, Inc. under contract to Mid-Atlantic Regional Air Management 

Association (MARAMA). The specific methodologies that were employed are described in 

Section 2 of the Emission Projections Report (Attachment N). MACTEC used state-supplied 

growth factor data, where available, to project future-year emissions. Where state-supplied 

data were not available, MACTEC used EPA’s Economic Growth and Analysis System, 

Version 5.0 (EGAS 5.0) to develop applicable growth factors for the non-EGU component. 

MACTEC also incorporated the applicable federal and state emissions control programs to 

account for the expected emissions reductions that will take place under the OTB/OTW and 

BOTW scenarios. 

6.3.2 Stationary Area Sources 

Stationary area sources include sources whose individual emissions are relatively small but, 

because the number of sources is large, their collective emissions are significant. Some 

examples include dry cleaners, service stations, and residential heating. For each area source, 

emissions are estimated by multiplying an appropriate emission factor by some known indicator 

of collective activity, such as fuel usage, number of households, or population. 

The area source emissions inventory submittals made for the CERR became the basis for the 

area source portion of the 2002 baseline inventory. MANE-VU’s consultant, Pechan, 

prepared the area source modeling inventory using the CERR submittals as a starting point. 

Pechan quality-assured the inventory and augmented it with additional data, including 

MANE-VU-sponsored inventories for categories such as residential wood combustion and 

open burning. Details on the preparation of MANE-VU’s 2002 baseline area source emissions 

inventory can be found in Chapter III of the Baseline Emissions Report (Attachment M). 

In similar fashion, MACTEC prepared future-year area source emission projections for the 

MANE-VU region. The specific methodologies employed are described in Section 3 of the 

Emission Projections Report (Attachment N). MACTEC applied growth factors to the 2002 

baseline area source inventory using state-supplied data, where available, or using the EGAS 

5.0 growth factor model. MACTEC also accounted for the appropriate control strategies in 

the future year projections. 

6.3.3 Non-Road Mobile Sources 

Non-road mobile sources are equipment that can move but do not use the roadways, such as 

construction equipment, aircraft, railroad locomotives, and lawn & garden equipment. For the 

majority of non-road mobile sources, emissions are estimated using the EPA’s NONROAD 

model. Aircraft, railroad locomotives, and commercial marine vessels are not included in the 

NONROAD model; and their emissions are estimated using applicable references and 

methodologies. Again, Pechan prepared the 2002 baseline modeling inventory using the state 

and local CERR submittals as a starting point. Details on the preparation of the 2002 baseline 
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State Implementation Plan November 2009 

non-road inventory are described in Chapter IV of the Baseline Emissions Report 

(Attachment M). 

Future-year non-road mobile source emissions were projected for the MANE-VU region by 

MACTEC. The methodologies employed are discussed in Section 4 of the Emission 

Projections Report (Attachment N). MACTEC used EPA’s NONROAD2005 non-road 

vehicle emissions model as contained in EPA’s National Mobile Inventory Model (NMIM). 

Since the calendar year is an explicit input into the NONROAD model, future-year emissions 

for non-road vehicles could be calculated directly for the applicable projection years. For the 

non-road vehicle types that are not included in the NONROAD model (i.e. aircraft, 

locomotives, and commercial marine vessels), MACTEC used the 2002 baseline inventory 

and the projected inventories that EPA developed for these categories for CAIR to develop 

emission ratios and subsequent combined growth and control factors. Since the future years 

for the CAIR projections did not precisely match those required for the purposes of ozone, 

particulate matter, and regional haze analyses (i.e. 2009, 2012, and 2018), MACTEC used 

linear interpolation to develop factors for the required future years. 

6.3.4 On-Road Mobile Sources 

The on-road emissions source category consists of vehicles that are meant to travel on public 

roadways, including cars, trucks, buses, and motorcycles. The basic methodology used for 

on-road mobile source calculations is to multiply vehicle-miles-traveled (VMT) by emission 

factors developed using the EPA’s MOBILE6 motor vehicle emission factors model. The onroad mobile category requires that SMOKE model inputs be prepared instead of the 

SMOKE/IDA emissions data format that is required by the other emission source categories. 

Therefore, for the 2002 baseline inventory, Pechan prepared the necessary VMT and 

MOBILE6 inputs in SMOKE format. 

Projected on-road mobile source inventories were developed by NESCAUM for the MANEVU region for ozone, particulate matter, and regional haze SIP purposes. As with the other 

emissions source categories, projected on-road mobile inventories were developed for 

calendar years 2009, 2012, and 2018. As part of this effort, MANE-VU member states were 

asked to provide VMT data and MOBILE6 model inputs for the applicable calendar years. 

Using the inputs supplied by the MANE-VU member states, NESCAUM compiled and 

generated the required SMOKE/MOBILE6 emissions model inputs. Further details regarding 

the on-road mobile source projections can be found in NESCAUM’s “Technical 

Memorandum, Development of MANE-VU Mobile Source Projection Inventories for 

SMOKE/MOBILE6 Application,” June 2006 (Attachment O). 

6.3.5 Biogenic Emission Sources 

For the purposes of the 2002 baseline modeling emissions inventory, biogenic emissions were 

calculated for the modeling domain by the New York State Department of Environmental 

Conservation (NYSDEC). NYSDEC used the Biogenic Emissions Inventory System (BEIS) 

Version 3.12 as contained within the SMOKE emissions processing model. Biogenic 

emissions estimates were made for CO, nitrous oxide (NO) and VOCs. Further details about 

the biogenic emissions processing can be found in NYSDEC’s technical support document 

TSD-1c, “Emission Processing for the Revised 2002 OTC Regional and Urban 12 km Base 

Case Simulations,” September 19, 2006 (Attachment P), and in Chapter VI of Pechan’s 
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State Implementation Plan November 2009 

“Technical Support Document for 2002 MANE-VU SIP Modeling Inventories,” Version 3, 

November 20, 2006 (Attachment M). Biogenic emissions were assumed to remain constant 

for the future-years analysis – a reasonable approximation reflecting the expectation that most 

of the region will remain heavily forested for the duration of the planning period. 

6.4 Summary of Emissions Inventories 

Connecticut’s baseline and future-year emissions inventories are summarized in Tables 6.1 

and 6.2, below. All values are reported in tons per year (tpy). 

Table 6.1: Connecticut 2002 Emissions Inventory Summary (tpy) 

Emission Sector VOC NOX PM2.5 PM10 NH3 SO2

EGU Point 303 6,150 461 627 -- 13,550

Non-EGU Point 4,604 6,773 822 990 -- 2,438

Area 87,302 12,689 14,247 48,281 5,318 12,418

Mobile 31,755 68,816 1,042 1,580 3,294 1,667

Non-Road Mobile 33,880 25,460 1,794 1,952 16.6 2,087

Biogenic 64,017 560 -- -- -- --

TOTAL 221,861 120,448 18,366 53,430 8,629 32,160

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

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

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

Table 6.2: Connecticut 2018 RPG (Best and Final) Emissions Inventory Summary (tpy) 

Emission Sector VOC NOX PM2.5 PM10 NH3 SO2

EGU Point 145 3,418 927 959 341 6,697

Non-EGU Point 4,227 7,501 937 1,104 -- 2,068

Area 68,395 11,795 9,635 20,511 5,061 534

Mobile 10,768 14,787 500 567 3,872 366

Non-Road Mobile 20,694 16,233 1,135 1,236 20 815

Biogenic 64,017 560 -- -- -- --

TOTAL 168,246 54,294 13,134 24,377 9,294 10,480

Note: Emission estimates for all MANE-VU states are archived at ftp.marama.org (User 

Name: mane-vu; Password: exchange). 

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

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

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

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

data and scenario input files – page 3, SMOKE-related files – page 4). No Connecticutspecific adjustments were made to the EGU Point, Non-Road Mobile and Biogenic 

inventories. 

Note that total ammonia emissions in 2018 are projected to increase slightly from total 

ammonia emissions in 2002. This can likely be attributed to a projected increase in vehicle 
Connecticut Regional Haze Page 6-9

State Implementation Plan November 2009 

miles traveled and projected increase in EGU Point NH3 emissions (possibly from projected 

installation of SCR controls on one or more units). 

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

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

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

revision due in 2018. 
Connecticut Regional Haze Page 7-1 

State Implementation Plan November 2009 

7.0 AIR QUALITY MODELING 

Air quality modeling to assess regional haze has been performed within MANE-VU, with 

major modeling being conducted by NESCAUM and screening modeling being conducted by 

NHDES. These modeling efforts include emissions processing, meteorological input analysis, 

and chemical transport modeling to perform regional air quality simulations for calendar year 

2002 and several future periods, including the primary target date, 2018, for this SIP. 

Modeling was conducted in order to assess contributions from upwind areas as well as 

Connecticut’s contribution to Class I areas in downwind states. Further, the modeling 

evaluated visibility benefits of specific control measures being considered to achieve 

reasonable progress goals and establish a long-term emissions management strategy for 

MANE-VU Class I Areas. 

Several modeling tools were utilized for these analyses: 

• The Fifth-Generation Pennsylvania State University/National Center for Atmospheric 

Research (NCAR) Mesoscale Model (MM5) was used to derive the required 

meteorological inputs for the air quality simulations.

• The Sparse Matrix Operator Kernel Emissions (SMOKE) emissions modeling system 

was used to process and format the emissions inventories for input into the air quality 

models.

• The Community Mesoscale Air Quality model (CMAQ) was used for the primary SIP 

modeling.

• The Regional Model for Aerosols and Deposition (REMSAD) was used during 

contribution apportionment.

• The California Puff Model (CALPUFF) was used to assess the contribution of 

individual states’ emissions to sulfate levels at selected Class I receptor sites.

Each of these tools has been evaluated and found to perform adequately. The SIP-pertinent 

modeling underwent full performance testing, and the results were found to meet the 

specifications of EPA modeling guidance. 

For more details on the regional haze modeling, refer to the NESCAUM report, “MANE-VU 

Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution 

Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment G). The 

detailed modeling approach for the most recent 2018 projections can be found in 

NESCAUM’s “2018 Visibility Projections,” May 13, 2008 (Attachment Q). 

7.1 Meteorology 

The meteorological inputs for the air quality simulations were developed by the University of 

Maryland (UMD) using the MM5 meteorological modeling system. Meteorological inputs 

were generated for 2002 to correspond with the baseline emissions inventory and analysis 

year. The MM5 simulations were performed on a nested grid (Figure 7.1). The modeling 

domain is composed of a 36-km, 145 x 102 continental grid and a nested 12-km, 172 x 172 

grid encompassing the eastern United States and parts of Canada. In cooperation with the 

New York State Department of Conservation (NYSDEC), an assessment was made for the 

period of May-September 2002 to compare the MM5 predictions with observations from a 

variety of data sources, including: 
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State Implementation Plan November 2009 

• Surface observations from the National Weather Service and the Clean Air Status and 

Trends Network (CASTNET), 

• Wind-profiler measurements from the Cooperative Agency Profilers (CAP) network, 

• Satellite cloud image data from the UMD Department of Atmospheric and Oceanic 

Science, and 

• Precipitation data from the Earth Observing Laboratory at NCAR. 

The analyses shows that in general, the performance of the MM5 is reasonable both at the 

surface and in the vertical, thereby providing confidence in the use of these data in the CMAQ 

simulations. 

Further details regarding the MM5 meteorological processing and the modeling domain can 

be found in NYSDEC’s technical support document TSD-1a, “Meteorological Modeling 

Using Penn State/NCAR 5th Generation Mesoscale Model (MM5),” February 1, 2006 

(Attachment R), and in the NESCAUM report, “MANE-VU Modeling for Reasonable 

Progress Goals, Model Performance Evaluation, Pollution Apportionment, and Control 

Measure Benefits,” November 27, 2007 (Attachment G). 

Figure 7.1: Modeling Domains Used in MANE-VU Air Quality 

Modeling Studies with CMAQ

Note: Outer (blue) domain is 36-km grid. Inner (red) domain is 12-km grid. Gridlines are shown at 180-km intervals 

(5×5 36-km cells and 15×5 12-km cells). 
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State Implementation Plan November 2009 

7.2 Data Preparations 

Emissions data were prepared for input into the CMAQ and REMSAD air quality models 

using the SMOKE emissions modeling system. SMOKE supports point, area, mobile (both 

on-road and non-road), and biogenic emissions. The SMOKE emissions modeling system 

uses flexible processing to apply chemical speciation as well as temporal and spatial allocation 

to the emissions inventories. SMOKE incorporates the Biogenic Emission Inventory System 

(BEIS) and EPA’s MOBILE6 motor vehicle emission factor model to process biogenic and 

on-road mobile emissions, respectively. Vector-matrix multiplication is used during the final 

processing step to merge the various emissions components into a single model-ready 

emissions file. Examples of processed emissions outputs are shown in Figure 7.2. 

Further details on the SMOKE processing conducted in support of the air quality simulations 

is provided in NYSDEC’s technical support document TSD-1c, “Emission Processing for the 

Revised 2002 OTC Regional and Urban 12 km Base Case Simulations,” September 19, 2006 

(Attachment P), and in NESCAUM’s report, “MANE-VU Modeling for Reasonable Progress 

Goals, Model Performance Evaluation, Pollution Apportionment, and Control Measure 

Benefits,” February 7, 2008 (Attachment G). Additional details on the emissions inventory 

preparation can be found in Section 6.0 of this report. 

7.3 Model Platforms 

Two regional-scale air quality models, CMAQ and REMSAD, were used for the air quality 

simulations that directly supported the regional haze SIP effort. CMAQ was developed by 

EPA and was used to perform the primary SIP-related modeling. The CMAQ modeling 

simulations were also an important tool for the 8-hour ozone SIP process. REMSAD was 

developed by ICF Consulting/Systems Applications International with support from EPA. 

REMSAD was used by NESCAUM to perform a source apportionment (contribution 

assessment) analysis. All of the air quality simulations that were used in the SIP efforts were 

performed on the 12-km eastern modeling domain shown in Figure 7.1 above. 

NYSDEC performed an extensive model performance analysis to evaluate CMAQ model 

predictions against observations of ozone, PM2.5, and other pollutant species. In general, the

CMAQ results were best for daily maximum O3 and daily average PM2.5 and SO4 mass. 

Many other species vary tremendously over the course of a day, or from day to day, and small 

model over- or underprediction at low concentrations can lead to large biases on a composite 

basis. It is important to demonstrate that the model performs reasonably over the diurnal 

cycle, not just in terms of daily maximum or average values. Also, it is important to 

demonstrate that the model can reproduce concentrations above the ground level. This model 

performance evaluation is described in detail in NYSDEC’s technical support document TSD1e, “CMAQ Model Performance and Assessment, 8-Hr OTC Ozone Modeling,” February 23, 

2006 (Attachment S). Due to the simplified chemistry mechanism, 

REMSAD may not simulate atmospheric processes as well as CMAQ. However, 

advantages such as the tagging feature for sulfur, more efficient modeling, and reasonable 

correspondence with measurements for many species, make REMSAD an important 

source apportionment tool for MANE-VU. A model performance evaluation for PM2.5

species, aerosol extinction coefficient, and the haze index is provided in NESCAUM’s report, 
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State Implementation Plan November 2009 

“MANE-VU Modeling for Reasonable Progress Goals, Model Performance Evaluation, 

Pollution Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment G). 
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State Implementation Plan November 2009 

Figure 7.2: Examples of Processed Model-Ready Emissions: (a) SO2 from Point, 

(b) NO2 from Area, (c) NO2 from On-Road, (d) NO2 from Non-Road, 

(e) ISOP from Biogenic, and (f) SO2 from all Source Categories 
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State Implementation Plan November 2009 

7.3.1 CMAQ 

The CMAQ air quality simulations were performed cooperatively among five modeling 

centers: NYSDEC, the New Jersey Department of Environmental Protection (NJDEP) in 

association with Rutgers University, the Virginia Department of Environmental Quality 

(VADEQ), UMD, and NESCAUM. NYSDEC also performed an annual 2002 CMAQ 

simulation on the 36-km domain shown in Figure 7.1; this simulation was used to derive the 

boundary conditions for the inner 12-km eastern modeling domain. Boundary conditions for 

the 36-km simulations were obtained from a run of the GEOS-Chem (Goddard Earth 

Observing System) global chemistry transport model that was performed by researchers at 

Harvard University. The technical options that were used in performing the CMAQ 

simulations are described in detail in NYSDEC’s technical support document TSD-1d, “8hr 

Ozone Modeling Using the SMOKE/CMAQ System,” February 1, 2006 (Attachment T). 

Further technical details regarding the CMAQ model and its execution are also provided in 

NESCAUM’s report, “MANE-VU Modeling for Reasonable Progress Goals, Model 

Performance Evaluation, Pollution Apportionment, and Control Measure Benefits,” February 

7, 2008 (Attachment G). 

7.3.2 REMSAD 

The REMSAD modeling simulations were used to produce the contribution assessment 

required by the Regional Haze Rule. REMSAD’s species tagging capability makes it an 

important tool for this purpose. The REMSAD model simulations were performed on the 

same 12-km eastern modeling domain as shown in Figure 7.1. NESCAUM’s report, 

“MANE-VU Modeling for Reasonable Progress Goals, Model Performance Evaluation, 

Pollution Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment G), 

further describes the REMSAD model and its application to the regional haze SIP efforts. 

7.3.3 CALGRID 

In addition to the SIP-quality modeling platforms described above, another modeling platform 

was developed for use as a screening tool to evaluate additional control strategies or to 

perform sensitivity analyses. The CALGRID model was selected as the basis for this 

platform. CALGRID is a grid-based photochemical air quality model that is designed to be 

run in a Windows environment. In order to make the CALGRID model the best possible tool 

to supplement the SIP-quality CMAQ and REMSAD modeling, the current version of the 

CALGRID platform was set up to be run with the same set of inputs as the SIP-quality 

models. The CALGRID air quality simulations were run on the same 12-km eastern 

modeling domain that was used for CMAQ and REMSAD. This model’s performance was 

comparable to the performance of the already evaluated CMAQ and REMSAD models and 

was thus determined to perform adequately. 

Conversion utilities were developed to reformat the meteorological inputs, the boundary 

conditions, and the emissions data for use with the CALGRID modeling platform. Premerged SMOKE emissions files were obtained from the modeling centers and reformatted for 

input into EMSPROC6, the emissions pre-processor for the CALGRID modeling system. 

EMSPROC6 allows the CALGRID user to adjust emissions temporally, geographically, and 

by emissions category for control strategy analysis. The pre-merged SMOKE files that were 

obtained from the modeling centers were broken down into the biogenic, point, area, non-
Connecticut Regional Haze Page 7-7

State Implementation Plan November 2009 

road, and on-road emissions categories. These files by component were then converted for 

use with EMSPROC6, thus giving CALGRID users the flexibility to analyze a wide variety of 

emissions control strategies. Additional information on the CALGRID modeling platform 

can be found in NHDES’ “Modeling Protocol for the OTC CALGRID Screening-Level 

Modeling Platform for the Evaluation of Ozone,” May 23, 2007 (Attachment U). 

7.3.4 CALPUFF 

CALPUFF is a non-steady-state Lagrangian puff model that simulates the dispersion, 

transport, and chemical transformation of atmospheric pollutants. Two parallel CALPUFF 

modeling platforms were developed by the Vermont Department of Environmental 

Conservation (VTDEC) and the Maryland Department of the Environment (MDE). The 

VTDEC CALPUFF modeling platform utilized meteorological observation data from the 

National Weather Service (NWS) to drive the CALMET meteorological model. The MDE 

platform utilized the same MM5 meteorological inputs that were used in the modeling done in 

support of the ozone and regional haze SIPs. These two platforms were run in parallel to 

evaluate individual states’ contributions to sulfate levels at Northeast and Mid-Atlantic Class I 

areas. The CALPUFF modeling effort is described in detail in NESCAUM’s report, 

“Contributions to Regional Haze in the Northeast and Mid-Atlantic United States,” August 

2006 (Attachment B). 

References

Pennsylvania State University/National Center for Atmospheric Research. Mesoscale Model 

(MM5). http://www.mmm.ucar.edu/mm5/mm5-home.html. 

Center for Environmental Modeling for Policy Development, University of North Carolina at 

Chapel Hill. Sparse Matrix Operator Kernel Emissions (SMOKE) Model. 

http://www.smoke-model.org/index.cfm. 

Community Modeling and Analysis System (CMAS) Center, University of North Carolina at 

Chapel Hill. Community Multiscale Air Quality (CMAQ) Modeling System. 

http://www.cmaq-model.org. 

ICF International/Systems Applications International. Regional Modeling System for 

Aerosols and Deposition (REMSAD). http://remsad.saintl.com. 

Scire, J.S., Strimaitis, D.G., and Yamartino, R.J. A User’s Guide for the CALPUFF 

Dispersion Model (Version 5). January 2000. 
Connecticut Regional Haze Page 8-1 

State Implementation Plan November 2009 

8.0 UNDERSTANDING THE SOURCES OF HAZE-CAUSING POLLUTANTS 

This section explores the origins, quantities, and roles of visibility-impairing pollutants 

emitted in the eastern United States and Canada that contribute significantly to regional haze at 

MANE-VU’s mandatory Class I areas. 

8.1 Fine-Particle Pollutants 

The pollutants primarily responsible for fine particle formation, and thus contributing to 

regional haze, include SO2, NOX, VOCs, NH3, PM10, and PM2.5. The MANE-VU Contribution 

Assessment (Attachment B), finalized in August 2006, reflects a conceptual model in which 

sulfate emerges as the most important single constituent of haze-forming fine particle 

pollution and the principle cause of visibility impairment across the Northeast region. Sulfate 

alone accounts for anywhere from 1⁄2 to 2⁄3 of total fine particle mass on the 20 percent haziest 

days at MANE-VU Class I Areas. This translates to about 2⁄3 to 3⁄4 of visibility extinction on 

those days. 

Visibility extinction is a measure of the ability of particles to scatter and absorb light. 

Extinction is expressed in units of inverse mega-meters (Mm-1). Figure 8.1 shows the 

dominance of sulfate in visibility extinction calculated from 2000-2004 baseline data for 

seven Northeast Class I Areas. 

Given the dominant role of sulfate in the formation of regional haze in the Northeast and MidAtlantic Regions, MANE-VU concluded that an effective emissions management approach 

would rely heavily on broad-based regional SO2 control measures in the eastern United States. 

The focus on SO2 as MANE-VU’s first priority makes sense not only because of its dominant 

role in regional haze but also because its emission sources are well understood. Moreover, the 

control measures needed for SO2 emission reductions are readily available, cost-effective, and 

could be implemented quickly. On the basis of scientific evidence, it is apparent that the bulk 

of haze-causing pollution can be eliminated by pursuing SO2 emission controls. 

Organic carbon was found to be the next largest contributor to haze after sulfate. In 

comparison with sulfate, the emission sources of organic carbon are diverse, variable, more 

diffuse, and less well understood; and the problem of controlling organic carbon emissions is 

exceedingly complex. For these reasons, MANE-VU considered organic carbon to be the 

subject of possible future control measures, but not a specific target pollutant in the initial 

strategy to mitigate regional haze. 
Connecticut Regional Haze Page 8-2

State Implementation Plan November 2009 

#

#

#

#

#

#

#

Contributions to PM2.5 Extinction at 7 Sites

20% Worst Visibility Days (2000-2004)

Soil

Sea Salt

OC

EC

Nitrate

Sulfate

0

20

40

60

80

100

120

140

160

180

1

1

1

1

1

Extinction (Mm-1)

Dolly Sods

Shenandoah

Brigantine

Lye Brook

Great Gulf

Acadia

Moosehorn

Figure 8.1: Contributions to PM2.5 Extinction at Seven Class I Areas 

8.2 Contributing States and Regions 

The MANE-VU Contribution Assessment used various modeling techniques, air quality data 

analysis, and emissions inventory analysis to identify source categories and states that 

contribute to visibility impairment in MANE-VU and nearby Class I areas. These analyses 

highlight the importance of emissions from outside MANE-VU to visibility impairment inside 

the region. Note that, although there is some variation in the contribution estimates among the 

different assessment methods employed, there is a general consistency of results from one 

method to another. 

Table 8.1 displays the results of just one of the methods used (the REMSAD model) to assess 

state-by-state and regional contributions to annual sulfate impacts in nine Class I areas. 
Connecticut Regional Haze Page 8-3

State Implementation Plan November 2009 

Table 8.1: Percent Contributions (Mass Basis) of Individual States and Regions to Total 

Annual Sulfate Impacts at Northeast Class I Areas (REMSAD) 

Contributing 

State or Region 

Mandatory Class I Area 

Acadia 

ME 

Brigantine 

NJ 

Dolly Sods 

WV 

Great Gulf &

Presidential 

Range – Dry 

River, NH 

Lye Brook 

VT 

Moosehorn

& Roosevelt 

Campobello

ME 

Shenandoah 

VA 

Connecticut 0.76 0.53 0.04 0.48 0.55 0.56 0.08

Delaware 0.96 3.20 0.30 0.63 0.93 0.71 0.61

District of Columbia 0.01 0.04 0.01 0.01 0.02 0.01 0.04

Maine 6.54 0.16 0.01 2.33 0.31 8.01 0.02

Maryland 2.20 4.98 2.39 1.92 2.66 1.60 4.84

Massachusetts 10.11 2.73 0.18 3.11 2.45 6.78 0.35

New Hampshire 2.25 0.60 0.04 3.95 1.68 1.74 0.08

New Jersey 1.40 4.04 0.27 0.89 1.44 1.03 0.48

New York 4.74 5.57 1.32 5.68 9.00 3.83 2.03

Pennsylvania 6.81 12.84 10.23 8.30 11.72 5.53 12.05

Rhode Island 0.28 0.10 0.01 0.11 0.06 0.19 0.01

Vermont 0.13 0.06 0.00 0.41 0.95 0.09 0.01

MANE-VU 36.17 34.83 14.81 27.83 31.78 30.08 20.59

MRPO 11.98 18.16 30.26 20.10 21.48 10.40 26.84

VISTAS 8.49 21.99 36.75 12.04 13.65 6.69 33.86

CenRAP 0.88 1.12 1.58 1.65 1.67 0.82 1.48

Canada 8.69 7.11 3.90 14.84 12.43 7.85 4.75

Other 33.79 16.78 12.70 23.54 18.99 44.17 12.48

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

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

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

than stated. 

Figures 8.2 and 8.3, also borrowed from the Contribution Assessment, illustrate another 

method for identifying and ranking states’ contributions to sulfate at Class I areas using the 

2002 data. This simple technique for deducing the relative impact of emissions from specific 

point sources on specific receptor sites involves calculating the ratio of annual emissions (Q) 

to source-receptor distance (d). The ratio (Q/d) is then multiplied by a factor to account for 

the frequency effect of prevailing winds. The use of this technique is explained in the 

Contribution Assessment (see pages 4-12 to 4-17 of Attachment B).
Connecticut Regional Haze Page 8-4

State Implementation Plan November 2009 

Figure 8.2: Ranked Sulfate Contributions to Northeast Class I Receptors Based on Q/d 

Method (Mass Basis), by Location of Origin 

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

CanadaPAOHINNYMIWVILGAMAKYNCVAMDALTNTXMOFLWINJMESCNHDEKSMNIACTOKMSLANEVTARRIDC

Annual Average Contribution (μg/m3 SO4)

Acadia

Great Gulf

Lye Brook

Moosehorn

Figure 8.3: Ranked Sulfate Contributions to Mid-Atlantic Class I Receptors 

Based on Q/d Method (Mass Basis), by Location of Origin 

0.00

0.10

0.20

0.30

0.40

0.50

0.60

0.70

OHPAWVNCCanadaMDINVAKYGANYILTNMIALNJTXFLDESCMOWIMAMSKSMNOKIALACTNHARNEMEDCRIVT

Annual Average Contribution (μg/m3 SO4)

Brigantine

Dolly Sods

Shenandoah

The first of the Q/d plots covers the four northern Class I areas in MANE-VU. The second 

covers one Class I area in the southern part of MANE-VU and two neighboring Class I areas 

in the VISTAS region. Observe, again, the comparative importance of emissions from 

Canada and from states outside the MANE-VU region.

The ranking of emission contributions to visibility impairment in the MANE-VU Class I 
Connecticut Regional Haze Page 8-5

State Implementation Plan November 2009 

Areas by methods such as these has direct relevance to the consultation process described 

previously in Section 3.0, Regional Planning and Consultation. Using results from the 

REMSAD model, MANE-VU applied the following three criteria to identify states and 

regions for the purposes of consultation on regional haze: 

4. Any state/region that contributed 0.1 μg/m3

 sulfate or greater on the 20 percent worst 

visibility days in the base year (2002), 

5. Any state/region that contributed at least 2 percent of total sulfate observed on the 20 

percent worst visibility days in 2002, and 

6. Any state/region among the top ten contributors on the 20 percent worst visibility days 

in 2002. 

For the purposes of deciding how broadly to consult, the MANE-VU States settled on the 

second of the three criteria: any state/region that contributed at least 2 percent of total sulfate 

observed on the 20 percent worst visibility days in 2002. 

In Figures 8.4 through 8.10, below, states and regions meeting the three listed criteria are 

identified graphically for seven Class I areas: Shenandoah and Dolly Sods are Class I areas in 

the VISTAS region that are impacted by emissions from MANE-VU states; the other five 

Class I areas are in MANE-VU. Note that the IMPROVE monitor at Great Gulf also 

represents the Presidential Range – Dry River Wilderness, and the IMPROVE monitor at 

Moosehorn also represents Roosevelt Campobello International Park. 

Each figure has the following components: 

• On the left is a single bar graph of the IMPROVE-monitored PM2.5 mass concentration 

(μg/m3

) by constituent species for the baseline years 2000-2004. The yellow, bottom 

portion of the bar represents the measured sulfate concentration. 

• The middle component of each figure provides a bar graph of the 2002 total sulfate 

contribution of each state or region as estimated by REMSAD. 

• Finally, the right segment contains three maps showing which states meet the criteria 

described above. 

Connecticut, Rhode Island, Vermont, and the District of Columbia were not identified as 

being among the political or regional units contributing at least 2 percent of sulfate at any of 

the seven Class I areas. However, as participants in MANE-VU, those entities have agreed to 

pursue adoption of regional control measures aimed at visibility improvement on the haziest 

days and prevention of visibility degradation on the clearest days. 
Connecticut Regional Haze Page 8-6

State Implementation Plan November 2009 

Figure 8.4: Modeled 2002 Contributions to Sulfate at Great Gulf, by State 

Great Gulf 

20% Worst Days

0

2

4

6

8

10

12

Great Gulf

Sulfate Nitrate EC OC Sea Salt Soil

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Great Gulf

CANADA

CENRAP

SE_BC

W_BC

N_BC

DC

MS

VT

RI

ME

CT

DE

AL

NJ

WI

SC

TN

VA

IL

MD

GA

NH

KY

NC

MI

WV

IN

MA

NY

PA

OH IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfate

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

μg/m3

#

#

#
Connecticut Regional Haze Page 8-7

State Implementation Plan November 2009 

Figure 8.5: Modeled 2002 Contributions to Sulfate at Brigantine, by State 

Brigantine

20% Worst Days

0

5

10

15

20

25

Brigantine

Sulfate Nitrate EC OC Sea Salt Soil

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Brigantine

CA NA DA

CENRA P

SE_BC

W_BC

N_BC

V T

RI

ME

DC

MS

CT

NH

MA

WI

NY

A L

IL

SC

MI

KY

TN

IN

NJ

DE

GA

WV

MD

V A

NC

OH

PA

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

μg/m3

#

#

#

Figure 8.6: Modeled 2002 Contributions to Sulfate at Lye Brook, by State 

Lye Brook 

20% Worst Days

0

2

4

6

8

10

12

14

16

Lye Brook

Sulfate Nitrate EC OC Sea Salt Soil

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Lye Brook

CANA DA

CENRAP

SE_BC

W_BC

N_BC

DC

RI

MS

ME

CT

V T

NH

WI

DE

SC

A L

NJ

IL

MA

TN

GA

MI

KY

V A

IN

NC

MD

WV

NY

OH

PA

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

μg/m3

#

#

#
Connecticut Regional Haze Page 8-8

State Implementation Plan November 2009 

Figure 8.7: Modeled 2002 Contributions to Sulfate at Acadia, by State 

Acadia 

20% Worst Days

0

2

4

6

8

10

12

Acadia

Sulfate Nitrate EC OC Sea Salt Soil

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

A cadia

CA NA DA

CENRA P

SE_BC

W_BC

N_BC

DC

MS

V T

RI

A L

DE

WI

CT

TN

GA

SC

NJ

V A

IL

KY

MD

MI

NC

NH

IN

WV

ME

NY

PA

OH

MA

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

μg/m3

#

#

#

Figure 8.8: Modeled 2002 Contributions to Sulfate at Moosehorn, by State 

Moosehorn 

20% Worst Days

0

2

4

6

8

10

12

Moosehorn

Sulfate Nitrate EC OC Sea Salt Soil

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Moosehorn

CA NA DA

CENRAP

SE_BC

W_BC

N_BC

MS

DC

V T

RI

A L

CT

WI

DE

SC

TN

GA

NJ

V A

MI

IL

KY

NH

MD

NC

IN

WV

ME

NY

OH

PA

MA

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

μg/m3

#

#

#
Connecticut Regional Haze Page 8-9

State Implementation Plan November 2009 

Figure 8.9: Modeled 2002 Contributions to Sulfate at Shenandoah, by State 

Shenandoah 

20% Worst Days

0

2

4

6

8

10

12

14

16

18

20

Shenandoah

Sulfate Nitrate EC OC Sea Salt Soil

IMPROVE mass 00-04

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Shenandoah

CANADA

CENRAP

SE_BC

W_BC

N_BC

VT

RI

ME

DC

MS

NH

CT

MA

NJ

DE

SC

WI

AL

TN

IL

GA

NY

NC

MI

MD

VA

KY

IN

WV

PA

OH Threshold options

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

REMSAD 2002 Contribution to Sulfate

#

#

#

μg/m3

Figure 8.10: Modeled 2002 Contributions to Sulfate at Dolly Sods, by State 

Dolly Sods 

20% Worst Days

0

2

4

6

8

10

12

14

16

18

20

Dolly Sods

Sulfate Nitrate EC OC Sea Salt Soil

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Dolly Sods

CA NA DA

CENRA P

SE_BC

W_BC

N_BC

RI

V T

ME

DC

CT

NH

MA

MS

DE

NJ

WI

NY

MD

SC

MI

IL

V A

A L

TN

NC

GA

IN

KY

PA

WV

OH

0.1 μg/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfate

#

#

#

μg/m3
Connecticut Regional Haze Page 8-10

State Implementation Plan November 2009 

8.3 Emission Sources and Characteristics 

As previously mentioned, the major pollutants responsible for regional haze are SO2, NOX, 

VOCs, NH3, PM10, and PM2.5. The following is a description of the sources (e.g., point, area, 

and mobile) and characteristics of pollutant emissions contributing to haze in the eastern 

United States. Emissions data and graphics presented for the purposes of this section are 

taken from the MANE-VU 2002 Baseline Emissions Inventory, Version 2.0 (note that the 

more recent MANE-VU 2002 Baseline Emissions Inventory, Version 3.0, released in April 

2006, has superseded Version 2.0 for modeling purposes). Although the emissions inventory 

database also includes carbon monoxide (CO), this primary pollutant is not considered here 

because it does not contribute to regional haze. 

8.3.1 Sulfur Dioxide (SO2) 

SO2 is the primary precursor pollutant for sulfate particles. Sulfate particles commonly 

account for more than 50 percent of particle-related light extinction at northeastern Class I 

areas on the clearest days and for as much as 80 percent or more on the haziest days. Hence, 

SO2 emissions are an obvious target of opportunity for reducing regional haze in the eastern 

United States. Combustion of coal and, to a lesser extent, of certain petroleum products 

accounts for most anthropogenic SO2 emissions. In fact, in 1998, a single source category – 

coal-burning power plants – was responsible for two-thirds of total SO2 emissions nationwide 

(NESCAUM, 2001a). 

Figure 8.11 shows SO2 emissions in the MANE-VU states as extracted from the 2002 

MANE-VU inventory (MARAMA, 2005). 

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

0.0

0.2

0.4

0.6

0.8

1.0

1.2

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

MV 2002 v.3
Connecticut Regional Haze Page 8-11

State Implementation Plan November 2009 

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

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

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

electricity, industrial power, and heat – dominate SO2 emissions in the region. 

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

Bar Graph = Percentage Fractions of Four Source Categories 

Line Graph = Total Annual Emissions (106

 tpy) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.0

0.2

0.4

0.6

0.8

1.0

1.2

million t/y

AREA NONROAD ONROAD POINT Emission

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

declines in annual SO2 emissions through 2002 compared with those from previous 

inventories. 

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

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

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

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

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

 

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

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

limits to a greater number of power plants. 

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

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

commercial, and institutional boilers as well as residential heating sources. By contrast, onroad and non-road mobile sources make a relatively minor contribution to overall SO2

emissions in the region (NESCAUM, 2001a). 
Connecticut Regional Haze Page 8-12

State Implementation Plan November 2009 

8.3.2 Volatile Organic Compounds (VOC) 

Existing emissions inventories generally refer to volatile organic compounds (VOCs) as 

hydrocarbons whose volatility in the atmosphere makes them particularly important to ozone 

formation. From a regional haze perspective, there is less concern with the volatile organic 

gases emitted directly to the atmosphere than with the secondary organic aerosols (SOAs) that 

VOCs form after undergoing condensation and oxidation. Thus the VOC inventory category 

is of interest primarily because of the organic carbon component of PM2.5. 

After sulfate, organic carbon generally accounts for the next largest share of fine particle mass 

and particle-related light extinction at northeastern Class I sites. The term organic carbon 

encompasses a large number and variety of chemical compounds that may be emitted directly 

from emission sources as components of primary PM or that may form in the atmosphere as 

secondary pollutants. The organic carbon present at Class I areas includes a mix of species, 

including pollutants originating from anthropogenic (i.e., manmade) sources as well as 

biogenic hydrocarbons emitted by vegetation. Recent efforts to cut back on manmade organic 

carbon emissions have been undertaken mainly for the purpose of reducing summertime 

ozone formation in urban centers. Future efforts to make further reductions in organic carbon 

emissions may be driven by programs that address fine particles and visibility. 

Understanding the source regions and transport dynamics for organic carbon in MANE-VU 

and nearby Class I areas is likely to be more complex than for sulfate. This complexity 

derives from the large number and diversity of organic carbon species, the wide variation in 

their transport characteristics, and the fact that a given species may undergo numerous 

complex chemical reactions in the atmosphere. Thus, the organic carbon contribution to 

visibility impairment at most Class I areas in the region is likely to include manmade 

pollution from nearby sources, manmade pollution transported from a distance, and biogenic 

emissions – especially terpenes from coniferous forests. 

As shown in Figure 8.13, the VOC inventory is dominated by mobile and area sources. Onroad mobile sources of VOCs include evaporative emissions from transportation fuels and 

exhaust emissions from gasoline passenger vehicles and diesel-powered, heavy-duty vehicles. 

VOC emissions may also originate from a variety of area sources (including those that use 

organic solvents, architectural coatings, and dry cleaning fluids) as well as from some point 

sources (e.g., industrial facilities and petroleum refineries). 

Biogenic VOCs (not included in Figure 8.13) may play an important role within the rural 

settings typical of Class I areas. The oxidation of hydrocarbon molecules containing seven or 

more carbon atoms is generally the most significant pathway for the formation of lightscattering organic aerosol particles (Odum et al., 1997). Smaller reactive hydrocarbons that 

may contribute significantly to urban smog (ozone) are less likely to play a role in organic 

aerosol formation, although it is noted that high ozone levels can have an indirect effect on 

visibility by promoting the oxidation of other available hydrocarbons, including biogenic 

emissions (NESCAUM, 2001a). In short, further work is needed to characterize the organic 

carbon contribution to regional haze in the MANE-VU states and to develop emissions 

inventories that will be of greater value for visibility planning purposes. As pointed out in 

Subsection 8.1 above, organic carbon could be the subject of future control measures to 

mitigate regional haze but is not the focus of initial planning. 
Connecticut Regional Haze Page 8-13

State Implementation Plan November 2009 

Figure 8.13: 2002 Volatile Organic Compound (VOC) Emissions, by State 

Bar Graph = Percentage Fractions of Four Source Categories 

Line Graph = Total Annual Emissions (106

 tpy) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1.6

AREA NONROAD ONROAD POINT Emission

8.3.3 Oxides of Nitrogen (NOX) 

NOX emissions contribute to visibility impairment in the eastern U.S. by forming lightscattering nitrate particles. Nitrate generally accounts for a substantially smaller fraction of 

fine particle mass and related light extinction than sulfate and organic carbon at northeastern 

Class I areas. Notably, nitrate may play a more important role in urban settings and in the 

wintertime. In addition, NOX may have an indirect effect on summertime visibility by virtue 

of its role in the formation of ozone, which in turn promotes the formation of secondary 

organic aerosols (NESCAUM, 2001a). 

Since 1980, nationwide emissions of NOX from all sources have shown little change. 

Emissions increased by 2 percent between 1989 and 1998 (EPA, 2000a). To a large extent, 

increases from the industrial and power plant combustion sectors have been offset by 

emission reductions from transportation source controls implemented during the same time 

period. Figure 8.14 shows NOX emissions in 2002 for each state in the MANE-VU region. In 

the several years just prior to 2002, most MANE-VU states experienced declining NOX

emissions. 

Power plants and mobile sources generally dominate state and national NOX emissions 

inventories. Nationally, power plants account for more than one-quarter of all NOX

emissions, amounting to over six million tons annually. The electric sector plays an even 

larger role in parts of the industrial Midwest, where power plants contribute significantly to 
Connecticut Regional Haze Page 8-14

State Implementation Plan November 2009 

NOX emissions. By contrast, mobile sources dominate the NOX inventories for more 

urbanized MANE-VU states, as shown in Figure 8.15. In these states, on-road mobile sources 

(i.e., highway vehicles) represent the largest NOX source category. Emissions from non-road 

(i.e., off-highway) mobile sources, primarily diesel-powered engines, also make up a 

substantial fraction of the inventory. 

Figure 8.14: Annual Nitrogen Oxide (NOX) Emissions, by State 

0.0

0.2

0.4

0.6

0.8

1.0

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

MV 2002 v.3
Connecticut Regional Haze Page 8-15

State Implementation Plan November 2009 

Figure 8.15: 2002 Nitrogen Oxide (NOX) Emissions, by State 

Bar Graph = Percentage Fractions of Four Source Categories 

Line Graph = Total Annual Emissions (106

 tpy) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

0.0

0.3

0.6

0.9

AREA NONROAD ONROAD POINT Emission

8.3.4 Primary Particulate Matter (PM10 and PM2.5) 

Directly emitted, or “primary,” particles (as distinct from secondary particles that form in the 

atmosphere through chemical reactions involving precursor pollutants such as SO2 and NOX) 

can also contribute to regional haze. For regulatory purposes, a distinction is made between 

particulate matter (PM) with an aerodynamic diameter less than or equal to 10 micrometers 

(PM10) and smaller particles with an aerodynamic diameter less than or equal to 2.5 

micrometers (PM2.5). 

Figures 8.16 and 8.17 show PM10 and PM2.5 emissions, respectively, for the MANE-VU states 

as reported for the 2002 base year. Most states showed a steady decline in annual PM10

emissions in the years leading up to the 2002 inventory. By contrast, emission trends for 

primary PM2.5 were more variable. 

Crustal sources are significant contributors of primary PM emissions. This category includes 

fugitive dust emissions from construction activities, paved and unpaved roads, and 

agricultural tilling. Typically, monitors estimate PM10 emissions from these types of sources by 

measuring the horizontal flux of particulate mass at a fixed downwind sampling location 

within perhaps 10 meters of a road or field. Comparisons between estimated emission rates 

for fine particles using these types of measurement techniques and observed concentrations of 

crustal matter in the ambient air at downwind receptor sites suggest that physical or chemical 

processes remove a significant fraction of crustal material relatively quickly. As a result, it 

rarely entrains into layers of the atmosphere where it can be transported to downwind receptor 

locations. Because of this discrepancy between estimated emissions and observed ambient 
Connecticut Regional Haze Page 8-16

State Implementation Plan November 2009 

concentrations, modelers typically reduce estimates of total PM2.5 emissions from all crustal 

sources by applying a factor of 0.15 to 0.25 to the total PM2.5 emissions before including them 

in modeling analyses. 

Figure 8.16: Primary Coarse Particle (PM10) Emissions, by State 

 

0.0

0.1

0.2

0.3

0.4

0.5

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

MV 2002 v.3

Figure 8.17: Primary Fine Particle (PM2.5) Emissions, by State

0.00

0.05

0.10

0.15

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

MV 2002 v.3
Connecticut Regional Haze Page 8-17

State Implementation Plan November 2009 

From a regional haze perspective, crustal material generally does not play a major role. On 

the 20 percent best visibility days during the baseline period (2000-2004), crustal PM 

accounted for six to eleven percent of particle-related light extinction at MANE-VU Class I 

sites. On the 20 percent worst visibility days, however, crustal material generally plays a 

much smaller role, ranging from two to three percent visibility extinction, than other hazeforming pollutants. Moreover, the crustal fraction includes materials of natural origin, such as 

soil or sea salt, that is not targeted under the Regional Haze Rule. Of course, the crustal 

fraction can be influenced by construction, agricultural practices, and road maintenance 

(including wintertime salting). Thus, to the extent that these types of activities are found to 

affect visibility at Northeastern Class I areas, control measures to reduce coarse and fine 

particulate matter deriving from crustal material may prove beneficial and are within the 

purview of EPA or state agencies. 

Experience from the western United States, where the crustal component has played a more 

significant role in overall particulate levels, may be applicable to the extent that it is relevant 

to the situation in the eastern states. In addition, a few areas in the Northeast, such as New 

Haven, Connecticut, and Presque Isle, Maine, have had some experience with the control of 

dust and road-salt stemming from regulatory obligations related to their past non-attainment 

status with respect to the NAAQS for PM10. 

Current emissions inventories for the entire MANE-VU area indicate that residential wood 

combustion represents 25 percent of primary fine particle emissions in the region. This 

finding implies that rural sources can play an important role as well as contributions from the 

region’s many populous urban areas. An important consideration in this regard is that 

residential wood combustion occurs mainly in the winter months, while managed or 

prescribed burning activities occur largely in other seasons. The latter category includes 

agricultural field-burning, prescribed burning of forested areas, and miscellaneous burning 

activities such as construction waste burning. Particulate emissions from many of these 

sources can be managed by limiting allowed burning activities to times when favorable 

meteorological conditions can efficiently disperse the emissions. 

Although data are currently limited, Connecticut and other MANE-VU states are concerned 

about the growing use of residential wood stoves by homeowners seeking alternatives to 

petroleum-based fuels for home heating. Over the next several years, CTDEP will continue to 

evaluate monitored particulate matter levels in the state and in particular, assess the smoke 

component of the monitored particulate matter to determine if there is any trend in smoke 

levels in Connecticut. If smoke levels increase significantly, that might be cause for 

evaluating whether additional control measures for this source category might be necessary. 

Figure 8.18, taken from Appendix B of the MANE-VU Contribution Assessment, represents 

the results of source apportionment and trajectory analyses on wood smoke in the area 

extending from the Gulf States to the Northeast. The green-highlighted portion of the map 

depicts the wood smoke source region in the Northeast states. The stars on the map represent 

air monitor sites (including those at several Class I areas) whose data sets were determined to 

be useful to the modeling analysis. 
Connecticut Regional Haze Page 8-18

State Implementation Plan November 2009 

Figure 8.18: Wood Smoke Source Regional Aggregations

Northeast: ACAD, PMRC, LYBR

Mid-Atlantic: WASH, SHEN, JARI

Southeast: GRSM, MACA

MANE-VU’s “Technical Support Document on Agricultural and Forestry Smoke 

Management in the MANE-VU Region,” September 1, 2006 (Attachment V), concluded that 

fire from land management activities was not a major contributor to regional haze in MANEVU Class I Areas, and that the majority of emissions from fires were from residential wood 

combustion. 

Figures 8.19 and 8.20 show that area sources dominate primary PM emissions. (EPA’s 

National Emissions Inventory categorizes residential wood combustion and some other 

combustion sources as area sources.) The relative contribution of point sources is larger in the 

primary PM2.5 inventory than in the primary PM10 inventory because the crustal component of 

particulate emissions (consisting mainly of larger, or coarse, particles) contributes more to 

overall PM10 levels than to PM2.5 levels. At the same time, pollution control equipment 

commonly installed at large point sources is usually more efficient at capturing coarse particle 

emissions. 
Connecticut Regional Haze Page 8-19

State Implementation Plan November 2009 

Figure 8.19: 2002 Primary Coarse Particle (PM10) Emissions, by State 

Bar Graph = Percentage Fractions of Four Source Categories 

Line Graph = Total Annual Emissions (106

 tpy) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.0

0.2

0.4

0.6

million t/y

AREA NONROAD ONROAD POINT Emission

Figure 8.20: 2002 Primary Fine Particle (PM2.5) Emissions, by State 

Bar Graph = Percentage Fractions of Four Source Categories 

Line Graph = Total Annual Emissions (106 tpy) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.00

0.02

0.04

0.06

0.08

0.10

0.12

million t/y

AREA NONROAD ONROAD POINT Emission
Connecticut Regional Haze Page 8-20

State Implementation Plan November 2009 

8.3.5 Ammonia Emissions (NH3) 

Because ammonium sulfate ((NH3)2SO4) and ammonium nitrate (NH3NO3) are significant 

contributors to atmospheric light scattering and fine particle mass, knowledge of ammonia 

emission sources is important to the development of effective regional haze reduction 

strategies. According to 1998 estimates, livestock agriculture and fertilizer use accounted for 

approximately 86 percent of all ammonia emissions to the atmosphere (EPA, 2000b). 

However, improved ammonia inventory data are needed as inputs to the photochemical 

models used to simulate fine particle formation and transport in the eastern United States. 

States were not required to include ammonia in their emissions data collection efforts until 

fairly recently (see the Consolidated Emissions Reporting Rule, 67 CFR 39602, June 10, 

2002). Therefore, emissions data for ammonia do not exist at the same level of detail or 

reliability as exists for other pollutants. 

Ammonium ion (formed from ammonia emissions to the atmosphere) is an important 

constituent of airborne particulate matter, typically accounting for 10–20 percent of total fine 

particle mass. Reductions in ammonium ion concentrations can be instrumental to controlling 

regional haze because such reductions yield proportionately greater reductions in fine particle 

mass. Ansari and Pandis (1998) showed that a one μg/m3 reduction in ammonium ion could 

result in up to a four μg/m3 reduction in fine particulate matter. Decision makers, however, 

must weigh the benefits of ammonia reduction against the significant role it plays in 

neutralizing acidic aerosol.10

To address the need for improved ammonia inventories, MARAMA, NESCAUM, and EPA 

funded researchers at Carnegie Mellon University (CMU) in Pittsburgh to develop a regional 

ammonia inventory (Davidson et al., 1999). This study focused on three issues with respect 

to current emission estimates: 1) a wide range of ammonia emission factors, 2) inadequate 

temporal and spatial resolution of ammonia emissions estimates, and 3) a lack of standardized 

ammonia source categories. 

The CMU project established an inventory framework with source categories, emission 

factors, and activity data that are readily accessible to the user. With this framework, users 

can obtain data in a variety of formats11 and can make updates easily, allowing additional 

ammonia sources to be added or emission factors to be replaced as better information 

becomes available (Strader et al., 2000; NESCAUM, 2001b). 

Figures 8.21 and 8.22 show estimated ammonia emissions for the MANE-VU states in 2002. 

Area and on-road mobile sources dominate the ammonia inventory data. Specifically, 

emissions from agricultural sources and livestock production account for the largest share of 

estimated ammonia emissions in the MANE-VU region, except in the District of Columbia. 

 

10 SO2 reacts in the atmosphere to form sulfuric acid (H2SO4). Ammonia can partially or fully neutralize this strong acid to 

form ammonium bisulfate or ammonium sulfate. If planners focus future control strategies on ammonia and do not 

achieve corresponding SO2 reductions, fine particles formed in the atmosphere will be substantially more acidic than those 

presently observed. 

11 For example, the user will have the flexibility to choose the temporal resolution of the output emissions data or to spatially 

attribute emissions based on land-use data. 
Connecticut Regional Haze Page 8-21

State Implementation Plan November 2009 

The two other sources contributing significant emissions are wastewater treatment systems 

and gasoline exhaust from highway vehicles. 

Figure 8.21: Ammonia (NH3) Emissions, by State 

0.00

0.02

0.04

0.06

0.08

0.10

0.12

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

million t/y

MV 2002 v.3

Figure 8.22: 2002 Ammonia (NH3) Emissions, by State 

Bar Graph = Percentage Fractions of Four Source Categories 

Line Graph = Total Annual Emissions (106

 tpy) 

0%

25%

50%

75%

100%

Connecticut

Delaware

District of Columbia

Maine

Maryland

Massachusetts

New Hampshire

New Jersey

New York

Pennsylvania

Rhode Island

Vermont

0.00

0.01

0.02

0.03

0.04

0.05

0.06

0.07

0.08

0.09

0.10

million t/y

AREA NONROAD ONROAD POINT Emission
Connecticut Regional Haze Page 8-22

State Implementation Plan November 2009 

References 

Ansari, A. S., and Pandis, S.N., “Response of inorganic PM to precursor concentrations,”

Environ. Sci. Technol., 32, 2706-2714, 1998. 

Davidson, C., Strader, R., Pandis, S., and Robinson, A., Preliminary Proposal to MARAMA and 

NESCAUM: Development of an Ammonia Emissions Inventory for the Mid-Atlantic States and 

New England. Carnegie Mellon University, Pittsburgh, PA. 7-Jan. 1999. 

Duyzer, J., “Dry Deposition of Ammonia and Ammonium Aerosols over Heathland,” J. 

Geophys. Res., 99(D9):18,757 – 18,763, 1994. 

NESCAUM, “Regional Haze and Visibility in the Northeast and Mid-Atlantic States,” 

January 2001a. 

NESCAUM, “Development of an Improved Ammonia Emissions Inventory for the United 

States,” December 2001b. 

Odum, J.R., Jungkamp, T.P.W., Griffin, R.J., Flagan, R.C., and Seinfeld, J.H., “The 

Atmospheric Aerosol-forming Potential of Whole Gasoline Vapor,” Science, 276, 96-99, 

1997.

Strader, R., Anderson, N., and Davidson, C., Development of an Ammonia Inventory for the 

Mid-Atlantic States and New England, Progress Report, October 18, 2000, available online: 

http://marama.org/rt_center/MARAMAprogress10-18-00.pdf, 2000. 

EPA, National Air Quality and Emission Trends Report, 1998, EPA 454/R-00-003, available 

online: http://www.epa.gov/oar/aqtrnd98/, 2000a. 

EPA, National Air Pollutant Trends, 1900 – 1998, EPA 454/R-00-002, available online: 

http://www.epa.gov/ttn/chief/trends/trends98/trends98.pdf, 2000b. 

EPA 2005, http://www.epa.gov/ttn/chief/eiinformation.html. 

 
Connecticut Regional Haze Page 9-1 

State Implementation Plan November 2009 

9.0 Best Available Retrofit Technology (BART) 

Section 169A(b)(2)(A) of the Clean Air Act (CAA), as amended August 7, 1977, requires 

states with emissions that are reasonably anticipated to cause or contribute to visibility 

impairment in a Class I area to adopt a plan requiring best available retrofit technology 

(BART) of certain sources. The SIP must include a requirement that each major stationary 

source which was in existence but which had not been in operation for greater than fifteen 

years as of the date of enactment of section 169A(b)(2)(A) and which may reasonably be 

anticipated to cause or contribute to impairment of visibility shall procure, install and operate 

BART for controlling emissions from such source for the purpose of eliminating or reducing 

visibility impairment. On July 6, 2005, EPA issued final Regional Haze Regulations and 

Guidelines for BART Determinations (40 CFR 51) and on October 13, 2006 EPA issued final 

Regional Haze Regulations; Revisions to Provisions Governing Alternative to BART 

Determinations (40 CFR 51). The requirements and implementation of the BART program as 

they apply to air pollution sources in Connecticut are described in this section. 

9.1 BART Overview

The BART program is intended to reduce visibility-impairing emissions of the pollutants 

sulfur dioxide (SO2), nitrogen oxides (NOx) and particulate matter (PM) from large stationary 

sources that were not required to meet certain emission control requirements at the time the 

CAA was amended in 1977. Any SO2, NOx and PM emission reductions will assist states in 

achieving the reasonable progress goals of the Regional Haze program. The BART 

requirement applies to facilities in any of 26 source categories that have units installed and 

operated between 1962 and 1977 with the potential to emit more than 250 tons per year of a 

visibility impairing pollutant (see 64 Federal Register (FR) 35737-35738). States must 

consider five statutory factors when determining BART control requirements for BARTeligible units: 

• Cost of controls, 

• Energy and non-air quality environmental impacts, 

• Existing controls at the source, 

• Remaining useful life of the source, and 

• Visibility improvement reasonably expected from application of controls. 

As set forth in 40 CFR 51.308(e)(2), states may opt to implement or require participation by 

BART sources in an emissions trading program or an alternative measure that will achieve 

greater reasonable progress than BART implementation at all sources subject to BART. In
Connecticut Regional Haze Page 9-2 

State Implementation Plan November 2009 

addition, if such alternative measure has been designed primarily to meet a Federal or State 

requirement other than BART, a more simplified approach can be used to demonstrate that the 

alternative measure will make greater reasonable progress than implementing BART alone. 

CTDEP has determined that the alternative measure, described below, is sufficient for BART 

eligible sources in Connecticut to meet their obligations under EPA’s BART guidance. 

The approach, as employed here by CTDEP, entails establishing a BART benchmark through 

the following measures: 

• Identification of BART-eligible sources, 

• A determination of which BART-eligible sources are subject to BART, 

• A determination of what BART is for each source subject to BART, and 

• A determination of the overall visibility improvement anticipated from the application 

of BART to all sources subject to BART. 

According to the EPA regulations, once the BART benchmark has been established, the state 

can compare the reductions achieved from the alternative measure with the reductions 

achieved from the BART benchmark. If the reductions from the alternative measure are 

greater than the BART benchmark, the state can assume that the alternative measure results in 

greater reasonable progress than BART. 

 

The CTDEP demonstrates here that its existing regulatory programs meet EPA’s alternative 

measure requirements resulting in greater reasonable progress than would be achieved by 

implementing BART. Connecticut’s programs identified to meet the alternative BART 

requirements include the following: 

• For SO2: Regulations of Connecticut State Agencies (RCSA) section 22a-174-19a 

(Control of Sulfur Dioxide Emissions from Power Plants and Other Large Stationary 

Sources of Air Pollution); 

• For NOx: RCSA Section 22a-174-22 (Control of Nitrogen Oxides Emissions), and 

RCSA Section 22a-174-22c (CAIR NOx Ozone Season Trading Program starting in 

May 2009); and 

• For PM: RCSA Section 22a-174-18 (Control of Particulate Matter and Visible 

Emissions). In addition, CTDEP concludes that the requirement for additional PM 

control measures is not reasonably justified from the BART assessment. 

The following sections establish a BART benchmark, provide estimated emission reductions 

achieved from Connecticut’s existing regulatory programs, and show that reductions from 

Connecticut’s existing regulatory programs exceed reductions from the application of BART 

alone.
Connecticut Regional Haze Page 9-3 

State Implementation Plan November 2009 

9.2 Establishing a BART benchmark

As indicated above, the simplified alternative approach to meeting EPA’s BART 

requirements entails establishing a BART benchmark. This includes i) identification of 

BART-eligible sources, ii) a determination of which BART-eligible sources are subject to 

BART, iii) a determination of what BART is for each source subject to BART, and iv) a 

determination of the overall visibility improvement anticipated from the application of BART 

to all sources subject to BART. 

9.2.1 Identification of BART-Eligible Sources

BART-eligible sources in Connecticut were identified in accordance with the description of 

sources potentially subject to BART in Appendix Y of 40 CFR Part 51 (Guidelines for BART 

Determinations Under the Regional Haze Rule). BART-eligible sources must meet the 

following criteria: 

• Major stationary sources which have the potential to emit 250 tons per year or more of 

any visibility impairing air pollutant; 

• From one of 26 identified source categories; and 

• Were built between August 1962 and August 1977. 

The BART-eligible sources initially identified in Connecticut are listed in Table 9.1: 

 

 Table 9.1: Initial list of BART-eligible sources in Connecticut 

Middletown Power LLC, Unit 3, Middletown 

Middletown Power LLC, Unit 4, Middletown 

Montville Power LLC, Unit 6, Montville 

Norwalk Power LLC, Unit 2, Norwalk 

PSEG Power Connecticut LLC, Bridgeport Harbor Station, Unit 3, Bridgeport 

PSEG Power Connecticut LLC, New Haven Harbor Station, Unit 1, New Haven 

Pfizer Inc., Boiler No. 5, Groton 

Pfizer Inc., Boiler No. 8, Groton 

Pfizer Inc., OSP2, Groton 

Cascades Boxboard Group – CT LLC (formerly known as Sprague Paperboard Inc.), PFI Boiler, 

Versailles 
Connecticut Regional Haze Page 9-4 

State Implementation Plan November 2009 

On March 10, 2006, the CTDEP issued Consent Order No. 8262 to Pfizer Inc. This Consent 

Order capped actual aggregated emissions from the boilers and the Organic Synthesis Plant 2 

(OSP2) to less than 250 tpy for each of the air pollutants NOx, SO2 and PM. Therefore, 

Pfizer’s facility is no longer considered BART-eligible. The final list of BART-eligible 

sources in Connecticut along with type of fuel burned, existing controls, and unit and plant 

capacity is shown in Table 9.2. Figures 9.1 and 9.2 display the locations of these BARTeligible sources as well as 2006 potential and actual annual emissions of SO2 and NOx, 

respectively. 
Connecticut Regional Haze Page 9-5 

State Implementation Plan November 2009 

 

Table 9.2: Final list of BART-eligible sources in Connecticut 

Unit/Fuel Unit/Plant 

Capacity 

Existing 

Controls/Sulfur limits 

Middletown Power LLC, Unit 3, Residual Oil, 

Natural Gas 

245 MW/>750 MW ESP, boiler excess air 

control, SNCR/0.3% 

fuel sulfur content* 

Middletown Power LLC, Unit 4, Residual Oil 400 MW/>750 MW Boiler excess air 

control/0.3% fuel sulfur 

content* 

Montville Power LLC, Unit 6, Residual/Distillate 

Oil 

410 MW/<750 MW None/0.3% fuel sulfur 

content* 

Norwalk Power LLC, Unit 2, Residual Oil 172 MW/<750 MW ESP, SNCR/0.3% fuel 

sulfur content* 

PSEG Power Connecticut LLC, 

 Bridgeport Harbor Station, Unit 3, Coal, 

Residual Oil 

410 MW/<750 MW ESP, low-NOx 

concentric firing 

system/0.33 

lb/MMBtu* 

PSEG Power Connecticut LLC, 

New Haven Harbor Station, Unit 1, 

Residual/Distillate Oil, Natural Gas 

465 MW/<750 MW ESP, overfire air, FGR, 

waterwall lances, lowNOx burners/0.3% fuel 

sulfur content* 

Cascades Boxboard Group – CT LLC, PFI 

Boiler, Residual Oil, Natural Gas 

275 MMBtu/hr/NA Low-NOx 

burners/0.5% fuel 

sulfur content or 

quarterly emission rate 

of 0.55 lb/MMBtu 

*Or meet an average emission rate of equal to or less than 0.33 lb/MMBtu for each calendar quarter from a 

single unit or 0.3 lb/MMBtu for each calendar quarter from two or more units.
Connecticut Regional Haze Page 9-6 

State Implementation Plan November 2009 

 Figure 9.1: Connecticut BART Eligible Sources SO2 Emissions 

 

 Figure 9.2: Connecticut BART Eligible Sources NOx Emissions 

 
Connecticut Regional Haze Page 9-7 

State Implementation Plan November 2009 

With the exception of Cascades Boxboard Group’s industrial boiler (PFI), all of the BARTeligible sources in Connecticut are electric generating units (EGUs). 

9.2.2 Determination of which BART-eligible sources are subject to BART

The State of Connecticut is a member of the Mid-Atlantic/Northeast Visibility Union 

(MANE-VU). As part of the consultation process amongst MANE-VU states a policy 

decision was made by the MANE-VU Board in June 2004 that all BART-eligible sources are 

subject to BART. As such, no BART exemptions will be given, meaning all BART-eligible 

sources are included in the full BART review process. 

9.2.3 Determination of what BART is for each source subject to BART

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

technologies for EGUs and Industrial Boilers, costs of NOx, SO2 and PM controls and 

regulatory programs for EGUs and Industrial Boilers, the EPA Guideline for BART 

Determinations, and the MANE-VU BART Workgroup recommended emission limits for 

NOx, SO2 and PM. 

Currently available control technologies for EGUs and Industrial Boilers

NOx

Firing Configurations and Firing Practices 

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

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

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

NOx burners, and fuel substitution/alteration. 

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

possible level while maintaining efficient and environmentally compliant boiler operation. 

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

methods may change the normal operation of the boiler and the effectiveness is boilerspecific. Implementation of these techniques may also reduce operational flexibility; 

however, they may reduce NOx by 10 to 20% from uncontrolled levels. 

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

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

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

combustion zone in which excess air is introduced. 

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

combustion temperature and reducing the formation of thermal NOx. 

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

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

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

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

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

emissions will be. 
Connecticut Regional Haze Page 9-8 

State Implementation Plan November 2009 

Overfire Air 

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

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

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

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

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

NOx emissions by 20-30%. 

Water/Steam Injection 

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

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

Selective Non-Catalytic Reduction (SNCR) 

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

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

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

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

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

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

equipment. There is not as much commercial experience to base effectiveness on a wide 

range of boiler types; however, in limited applications, NOx reductions of 35 to 60% have 

been achieved. 

Selective Catalytic Reduction (SCR) 

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

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

located at various positions in the process including before an air heater and particulate 

control device, or downstream of the air heater, particulate control device, and flue gas 

desulfurization systems. The performance of SCR is influenced by flue gas temperature, fuel 

sulfur content, ammonia-to-NOx ratio, inlet NOx concentration, space velocity, and catalyst 

condition. NOx emission reductions of 75 to 90% have been achieved through the use of SCR 

on oil-fired boilers operating in the U.S. 

SO2 

Wet Flue Gas Desulphurization (FGD) 

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

a calcium sulfate compound. These solid sulfate compounds are then removed in downstream 

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

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

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

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

saleable gypsum product. 

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

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

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

among the commercially proven wet FGD systems.
Connecticut Regional Haze Page 9-9 

State Implementation Plan November 2009 

Low-Sulfur Fuels 

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

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

occurring or the result of coal cleaning. 

PM

Mechanical Collectors 

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

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

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

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

Electrostatic Precipitators (ESPs) 

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

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

can then be collected by washing the sides of the precipitator or knocking it so that the 

particles fall down into a collector. Existing ESPs are typically 40 to 60% efficient. New or 

rebuilt ESPs can achieve collection efficiencies of more than 99%. 

Fabric Filters 

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

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

and operational characteristics including particle size distribution, particle cohesion 

characteristics, and particle electrical resistivity. Operational parameters that affect collection 

efficiency include air-to-cloth ratio, operating pressure loss, cleaning sequence, interval 

between cleaning, and cleaning intensity. The structure of the fabric filter, filter composition, 

and bag properties also affect collection efficiency. Collection efficiencies of baghouses may 

be more than 99%. 

Fuel Substitution 

Cleaner fuels will result in less PM emissions. 

Scrubbing Systems 

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

the physical or chemical absorption of particles or gaseous pollutants. Scrubbing systems 

have been shown to reduce PM emissions by 50-60%. 

Costs of SO2, NOx and PM Controls for EGUs and Industrial Boilers

According to NESCAUM’s Assessment of Control Options for BART-Eligible Sources 

(Attachment Z), SO2 control for previously uncontrolled EGU boilers is highly cost effective 

with operational costs in the range of $100-200 per ton of SO2 removed. Costs for NOx 

removal range from $200-500/ton for some of the low yield techniques to $1000 to $1500/ton 

for SCR with 90-95 percent removal efficiency. A cost-effectiveness indicator (e.g., $/ton) is 

difficult to address for PM control because the range of PM reductions for different fuels and 

processes is very wide. One of the main parameters dictating the “sizing” and hence, costs of 

a PM control device, is the quantity of flue gas it must handle. As a result, it is more 

appropriate to generalize capital costs per actual cubic feet per minute (ACFM) of gas flow 

and is given on a “$/ACFM” basis. PM control costs range from $1-$40/ ACFM of gas flow.
Connecticut Regional Haze Page 9-10 

State Implementation Plan November 2009 

Many of the same control technologies for EGUs are applicable to industrial boilers, but 

industrial boilers have a wider range of sizes than EGUs and often operate over a wider range 

of capacities. Cost estimates for the same technologies will generally range, depending on the 

capacity of the boiler and typical operating conditions, with high end cost estimates for NOx

removal going over $10,000/ton. 

Costs of Compliance with Connecticut’s Existing Regulations: RCSA section 22a-174-19a

(Control of SO2 Emissions from Power Plants and other large stationary sources of air 

pollution), RCSA section 22a-174-22 (Control of NOx Emissions) and RCSA section 22a174-22c (CAIR NOx Ozone Season Trading Program)

Residual oil is a byproduct of the refining process and is produced in several grades that can 

be blended to meet a specified fuel sulfur content limit. The premium cost for lower sulfur 

residual fuel oil (<1%S) has averaged approximately 15 % over the past three years, however, 

on occasion, the price for low and higher sulfur residual fuel has been minimal. For example, 

according to the U.S. Energy Information Administration, the August average U.S. wholesale 

price of lower sulfur residual fuel oil was $66.61 /barrel while the higher sulfur residual fuel 

oil (>1%) was priced at $65.81 /barrel 

(http://tonto.eia.doe.gov/dnav/pet/pet_pri_spt_s1_d.htm). 

For NOx, sources complying with RCSA Section 22a-174-22 and RCSA Section 22a-174-22c 

through emissions trading, costs of compliance are directly related to costs of NOx discrete 

emission reduction credits (DERCs) and/or allowances. NOx DERC and allowance prices 

vary because they are currencies of market-based programs. In March 2004 NOx allowance 

prices were approximately $2000/ton; CAIR NOx Ozone Season allowance prices as of 

November 2009 are approximately $130/ton. 

EPA Guideline for BART Determinations/MANE-VU BART Workgroup recommended 

emission limits 

EPA’s Guideline for BART Determinations (40 CFR 51, Appendix Y) establishes 

presumptive SO2 and NOx emission limits for 750 megawatt (MW) and greater power plants. 

Middletown Power LLC is the only Connecticut BART-eligible facility that is greater than 

750 MW. All of Connecticut’s BART-eligible units are oil-fired, with the exception of 

Bridgeport Harbor Station Unit 3, which is coal-fired. 

 
Connecticut Regional Haze Page 9-11 

State Implementation Plan November 2009 

For each oil-fired EGU at a 750 MW power plant, regardless of size, EPA recommends that, 

for SO2 control purposes, states evaluate limiting the sulfur content of the fuel oil burned to 1 

percent or less by weight. For NOx control purposes at power plants with a generating 

capacity in excess of 750 MW currently using selective non-catalytic reduction (SNCR) for 

part of the year (Middletown Unit 3), EPA suggests that use of such controls year round is 

BART. 

States are not required to follow EPA’s guidelines when doing BART determinations for 

other types of sources. However, for a currently uncontrolled coal-fired EGU at a power plant 

smaller than 750 MW, EPA claims that SO2 control levels of either 95% or 0.15 lbs/MMBtu 

are generally cost-effective and could be considered in BART determinations considering the 

five factors specified in CAA section 169A(g)(2). For NOx, EPA recommends that for other 

sources currently using SNCR to reduce NOx emissions during part of the year (i.e., Norwalk 

Unit 2), states consider requiring the use of such controls year round. For coal-fired EGUs 

greater than 200 MW located at power plants of 750 MW capacity or less and operating 

without post-combustion controls, EPA provides a NOx emission rate of 0.62 lb/MMBtu as a 

cost-effective level to meet for wet-bottom tangential-fired units burning bituminous coal 

(i.e., PSEG Bridgeport Harbor Unit 3). For oil-fired and gas-fired EGUs larger than 200 MW 

at plants smaller than 750 MW (Montville 6, New Haven Harbor 1), EPA believes that 

installation of combustion control technology to control NOx is generally highly cost-effective 

and should be considered in the determination of BART. 

Additionally, as part of the regional consultation process, the MANE-VU BART Workgroup 

established recommended BART emission limits for various types of sources (NESCAUM 

Five-Factor Analysis of BART-Eligible Sources (6/1/07) (Attachment W)). Table 9-3 

includes the MANE-VU BART Workgroup recommended BART emission limits for nonCAIR EGUs and industrial boilers; such units are the only types of BART-eligible units in 

Connecticut. Since Connecticut is only subject to the CAIR NOx ozone season program, the 

BART-eligible EGUs in Connecticut are considered to be non-CAIR EGUs. 
Connecticut Regional Haze Page 9-12 

State Implementation Plan November 2009 

Table 9.3: MANE-VU BART workgroup recommended BART emission limits for nonCAIR EGUs and industrial boilers 

 SO2 NOx PM 

Non-CAIR EGUs Coal – 95% control or 

0.15 lb/MMBtu 

Oil – 95% control or 

0.33 lb/MMBtu (0.3% 

fuel sulfur limit) 

o In NOx SIP call area, 

extend use of controls to 

year-round 

o 0.1 – 0.25 lb/MMBtu, 

depending on coal and 

boiler type 

0.02 – 0.04 

lb/MMBtu 

Industrial Boilers 90% control, MACT 

acid gas control level, 

ICI-RACT, or 0.5% 

fuel sulfur limit (0.55 

lb/MMBtu) 

0.1 – 0.4 lb/MMBtu, depending 

on boiler and fuel type 

0.02 – 0.04 

lb/MMBtu 

9.2.4 Determination of the overall visibility improvement anticipated from the 

application of BART to all MANE-VU sources subject to BART

MANE-VU has conducted modeling to assess the visibility improvement from controlling all 

MANE-VU BART-eligible sources. In one assessment, they modeled the collective visibility 

improvement from controlling all BART-eligible sources (SO2, NOx and PM) with individual 

impacts, as determined from screening modeling, of less than 0.1 deciviews (dv). This 

modeling predicted a maximum collective improvement of only 0.3 dv at MANE-VU Class I 

areas. Both Norwalk Harbor Unit 2 and the Cascades Boxboard Group PFI boiler have 

individual impacts of less than 0.1 dv at MANE-VU Class I areas. 

MANE-VU also modeled the individual impacts on visibility at MANE-VU Class I areas 

from each BART-eligible source on two CALPUFF Model platforms using two different 

meteorological data sets, NWS and MM5 (see modeling results in Attachment X). The two 

platforms modeled three different natural background visibility conditions (best, average, 

worst) for three pollutants (SO2, NOx and PM) in order to determine where the maximum 

Class I impacts would occur for each BART-eligible source in the MANE-VU region. 

According to the 2002 individual impact modeling, Bridgeport Harbor Unit 3, New Haven 

Harbor Unit 1, Middletown Unit 3 and Montville Unit 6 had visibility impacts greater than 0.1 

dv on at least one Class I area. 
Connecticut Regional Haze Page 9-13 

State Implementation Plan November 2009 

MANE-VU has concluded that a visibility impact in the range of 0.2 to 0.3 dv or greater from 

an individual source would represent a “significant” impact at MANE-VU Class I areas on an 

average basis. This significant impact threshold is more stringent than the 0.5 dv BART 

applicability contribution threshold in EPA’s BART Guidelines. Based on MANE-VU’s 

modeling of 2002 emissions, only two of Connecticut’s BART-eligible units, Bridgeport 

Harbor Station Unit 3 and New Haven Harbor Station Unit 1, had annual average visibility 

impacts greater than 0.2 dv on a Class I area in 2002. For Bridgeport Harbor Station, 

maximum visibility impacts occurred at Brigantine with total extinction from all pollutants 

ranging from 0.40 to as high as 0.84 dv with corresponding sulfate contribution ranging from 

0.32 to 0.67 dv. For New Haven Harbor Station, maximum visibility impacts were also at 

Brigantine and ranged from 0.35 to 0.74 dv of combined extinction from all pollutants with 

corresponding sulfate contribution ranging from 0.29 to 0.61 dv. The visibility impacts from 

these facilities would now be significantly lower due to implementation of Connecticut’s SO2 

emissions reduction program, instituted in 2002 and 2003, that greatly reduced the SO2

emissions and, hence, the visibility impacts from these sources. This is because Connecticut’s 

SO2 limits from these sources were reduced to 0.55 lb SO2/MMBtu in 2002 and to 0.33 lb 

SO2/MMBtu in 2003 (see summary of RCSA section 22a-174-19a in Subsection 9.3.1). Prior 

to 2002 SO2 limits for these sources ranged as high as 1.1 lb SO2/MMBtu, with the exception 

of Middletown Unit 3, which has been limited by order to a 0.55 lb SO2/MMBtu emission rate 

since 1981. None of Connecticut’s BART-eligible EGUs appear on the list of top 167 electric 

generating emission points contributing to visibility impairment in MANE-VU (Attachment 

E). 

Another indication of the relative importance of Connecticut’s point source emissions as a 

potential for impacting regional haze at Class I areas is shown in Figure 9.3. Clearly, SO2 

emissions from point sources in Connecticut are relatively small compared with point source 

emissions in other states. 
Connecticut Regional Haze Page 9-14 

State Implementation Plan November 2009 

Figure 9.3: 

9.3 Connecticut’s Alternative Measures

During the last several years Connecticut has developed additional regulatory measures aimed 

at reducing emissions of SO2 and NOx from a large universe of in-state sources. As 

demonstrated below, such measures achieve greater emissions reductions than would be 

achieved through the installation and operation of BART alone. Table 9.4 lists the 

Connecticut sources, including Connecticut’s seven BART-eligible sources (highlighted), that 

are addressed in the following discussions on Connecticut’s SO2 and NOx Programs for 

Alternative BART. 
Connecticut Regional Haze Page 9-15 

State Implementation Plan November 2009 

Table 9.4: Universe of Sources Addressed in Connecticut’s SO2 and NOx Programs for Alternative BART (P

Program Source, Unit ID, Location, Size) (BART-eligible units are highlighted; Acid Rain Program units are boldf

AES Thames, Unit A, Montville, 200 MW Milford Power Company LLC 1, Milford, 272 AES Thames, Unit B, Montville, 200 MW Milford Power Company LLC 2, Milford, 272 Algonquin Power Windsor Locks, 38 MW Montville Power LLC, Unit 5, Montville, 81 MConnecticut Jet Power, Branford, 20 MW Montville Power LLC, Unit 6, Montville, 410 MBridgeport Energy 1, Bridgeport, 170 MW PSEG Power Connecticut LLC, Unit 1, New HBridgeport Energy 2, Bridgeport, 170 MW Norwalk Power LLC, Unit 1, Norwalk, 172 MW PSEG Power Connecticut LLC, Unit 2, Bridgeport, 170 MW Norwalk Power LLC, Unit 2, Norwalk, 172 MW PSEG Power Connecticut LLC, Unit 3, Bridgeport, 410 MW Norwalk Power LLC, Unit 10, Norwalk, 20 MW PSEG Power Connecticut LLC, Unit 4, Bridgeport, 22 MW Norwich DPUC, Norwich, 20 MW Capitol District Energy Center, Hartford, 55 MW Pfizer Inc, Boiler 5, Groton, 399 MMBtu/hr Cascades Boxboard Group - Connecticut LLC, Versailles, 275 MMBtu/hr Pfizer Inc, Boiler 8, Groton, 267 MMBtu/hr Connecticut Jet Power, Cos Cob 10, Greenwich, 20 MW Pratt & Whitney Cogen, East Hartford, 32 MW Connecticut Jet Power, Cos Cob 11, Greenwich, 20 MW CRRA, South Meadow 11A, Hartford, 20 MW Connecticut Jet Power, Cos Cob 12, Greenwich, 20 MW CRRA, South Meadow 11B, Hartford, 20 MW Devon Power LLC, Unit 7, Milford, 109 MW CRRA, South Meadow 12A, Hartford, 20 MW Devon Power LLC, Unit 8, Milford, 109 MW CRRA, South Meadow 12B, Hartford, 20 MW Devon Power LLC, Unit 10, Milford, 20 MW CRRA, South Meadow 13A, Hartford, 20 MW Devon Power LLC, Unit 11, Milford, 40 MW CRRA, South Meadow 13B, Hartford, 20 MW Devon Power LLC, Unit 12, Milford, 40 MW CRRA, South Meadow 14A, Hartford, 20 MW Devon Power LLC, Unit 13, Milford, 40 MW CRRA, South Meadow 14B, Hartford, 20 MW Devon Power LLC, Unit 14, Milford, 40 MW Connecticut Jet Power, Torrington Terminal, TorrConnecticut Jet Power, Franklin Drive, Torrington, 20 MW FirstLight Power Resources Services, Tunnel, PreLake Road Generating Company 1, Killingly, 264 MW Wallingford Energy 1, Wallingford, 50 MW Lake Road Generating Company 2, Killingly, 264 MW Wallingford Energy 2, Wallingford, 50 MW Lake Road Generating Company 3, Killingly, 264 MW Wallingford Energy 3, Wallingford, 50 MW Middletown Power LLC, Unit 2, Middletown, 117 MW Wallingford Energy 4, Wallingford, 50 MW Middletown Power LLC, Unit 3, Middletown, 245 MW Wallingford Energy 5, Wallingford, 50 MW Middletown Power LLC, Unit 4, Middletown, 400 MW Waterside Power 4, Stamford, 23.2 MW Middletown Power LLC, Unit 10, Middletown, 20 MW Waterside Power 5, Stamford, 23.2 MW  Waterside Power 7, Stamford, 23.2 MW 
Connecticut Regional Haze Page 9-16 

State Implementation Plan November 2009 

9.3.1 Connecticut’s SO2 Program for Alternative BART

RCSA section 22a-174-19a is Connecticut’s regulation limiting SO2 emissions. It became 

effective on December 28, 2000 and included a two-tiered timeframe for reducing SO2 

emissions from large EGUs and industrial sources (the approximately 59 sources referenced 

in Table 9.4; the exact number of sources may vary). All of the BART-eligible sources in 

Connecticut are currently subject to these regulations. 

Summary of RCSA Section 22a-174-19a

Tier One. Starting on January 1, 2002, all sources subject to Connecticut’s Post-2002 NOx 

Budget Program (all sources listed in Table 9.4) were required to: 

• Combust liquid fuel, gaseous fuel or a combination of each, provided that each fuel 

possesses a fuel sulfur limit of equal to or less than 0.5% sulfur, by weight; 

• Meet an average emission rate of equal to or less than 0.55 pounds of SO2 per MMBtu 

for each calendar quarter for an affected unit at the premises; or 

• Meet an average emission rate of equal to or less than 0.5 pounds of SO2 per MMBtu 

calculated for each calendar quarter, if such owner or operator averages the emissions 

from two or more affected units at the premises. 

Tier Two. Starting on January 1, 2003, all sources in Connecticut that are Acid Rain Sources 

under Title IV of the Clean Air Act and are subject to Connecticut’s Post-2002 NOx Budget 

Program (30 boldfaced sources in Table 9.4) shall: 

• Combust liquid fuel, gaseous fuel or a combination of each, provided that each fuel 

possesses a fuel sulfur limit of equal to or less than 0.3% sulfur, by weight; 

• Meet an average emission rate of equal to or less than 0.33 pounds of SO2 per 

MMBtu for each calendar quarter for an affected unit at a premises; or 

• Meet an average emission rate of equal to or less than 0.3 pounds SO2 per MMBtu 

calculated for each calendar quarter, if such owner or operator averages the 

emissions from two or more affected units at a premises. 

Prior to January 1, 2005 CTDEP allowed sources subject to the January 1, 2003 emission 

rates to meet such emission rates by using SO2 discrete emission reduction credits certified by 

CTDEP or EPA’s SO2 Acid Rain Program allowances; also known as emissions credit 

trading. Connecticut General Statute (CGS) section 22a-198 suspended SO2 emissions credit 

trading starting on January 1, 2005. As part of its PM2.5 SIP revision on November 18, 2008, 

CTDEP submitted parts of RCSA section 22a-174-19a to EPA in order to make the fuel sulfur 

limits of Connecticut’s alternative BART program federally enforceable. CTDEP’s request 

for EPA to approve this SIP is pending. In the meantime, CTDEP has proposed revisions to 

RCSA section 22a-174-19a to ensure consistency with state statute provisions (CGS section 

22a-198) and will submit the revisions to EPA as a SIP revision once they become finalized. 

Additionally (but with no need for it being made a federally enforceable part of this SIP), 

starting on January 1, 2002, each Post-2002 NOx Budget Program source that is also a Title 
Connecticut Regional Haze Page 9-17 

State Implementation Plan November 2009 

IV source was required to retire one ton of SO2 allowances, rounded up to the next whole ton, 

for each ton of SO2 emitted in the state of Connecticut. This provision has resulted in 37,462 

tons of SO2 allowances retired between 2002-2006. 

All of Connecticut’s BART-eligible sources are included in the Post-2002 NOx Budget 

Program (subject sources are listed in Table 9.4), which has now been rolled into the CAIR 

NOx Ozone Season Trading Program. All of CT’s BART-eligible EGUs are also Title IV 

sources. Therefore, in accordance with Tier 2 of RCSA section 22a-174-19a described above, 

all of Connecticut’s BART-eligible EGUs are subject to requirements that are equivalent to 

the MANE-VU BART workgroup’s recommended SO2 BART limit for oil-fired non-CAIR 

EGUs (0.33 lb/MMBtu or 0.3% fuel sulfur limit). 

The BART-eligible industrial boiler at Cascades Boxboard Group-CT LLC is subject to the 

January 1, 2002 SO2 emission rate in RCSA section 22a-174-19a, which is the same as the 

MANE-VU BART workgroup’s recommended SO2 BART limit for industrial boilers (0.55 

lb/MMBtu or 0.5% fuel sulfur limit). EPA’s BART guidelines for oil-fired units recommend 

evaluation of limiting the sulfur content of the fuel oil burned to 1 percent or less by weight. 

Therefore all of the oil-fired BART eligible units are meeting the more stringent MANE-VU 

BART workgroup’s SO2 BART recommendations. Bridgeport Harbor 3, with a SO2 emission 

limit of 0.3 or 0.33 lb SO2/MMBtu (depending on the regulatory option selected), is the only 

coal-fired BART eligible source in Connecticut. The MANE-VU BART workgroup’s 

recommended BART limit for coal-fired non-CAIR EGUs is 0.15 lb/MMBtu. EPA’s 

suggested, but not required, emission rate is the same. While Bridgeport Harbor Unit 3’s SO2

limit does exceed the recommendations of the MANE-VU BART workgroup and EPA, as 

described below, the net effect of Connecticut’s SO2 program is to produce greater emission 

reductions from all BART-eligible units than would be achieved through the installation and 

operation of BART alone. Furthermore, Connecticut’s only 750 MW BART-eligible power 

plant, Middletown Power LLC, is subject to a more stringent fuel sulfur limit (0.33 

lb/MMBtu) than EPA’s presumptive BART guideline limit for oil-fired units of 1 percent or 

less by weight fuel oil sulfur content. All of Connecticut’s BART-eligible EGUs measure 

SO2 emissions with continuous emission monitoring systems (CEMS) pursuant to 40 CFR 75. 

Analysis of CT’s Alternative BART Program for SO2

Attachment X contains a spreadsheet with the 2001, 2002 and 2006 SO2 actual and potential 

(ton per year and ton per day) emissions for all units in the Post-2002 NOx Budget Program. 

Where 2006 potential emissions did not decrease from 2002 potential emission levels, the 

unit’s allowable or permitted level did not decrease. Tables 9.5 and 9.6 show the 2001, 2002,
Connecticut Regional Haze Page 9-18 

State Implementation Plan November 2009 

2006 SO2 potential emissions (both tons per year and tons per day) from the BART-eligible 

units. For comparison purposes, the presumptive 2012 MANE-VU BART workgroup and 

EPA BART potential emissions are provided. Table 9.7 shows the 2001, 2002 and 2006 SO2 

actual emissions from the BART-eligible units. 
Connecticut Regional Haze Page 9-19 

State Implementation Plan November 2009 

Table 9.5: SO2 Annual Potential Emissions @ 8760 Hours (tpy) 

BART-eligible 

Unit/Location 

2001* 2002* 2006* MANE-VU 

BART 

workgroup 

presumptive 

BART 2012 

EPA 

presumptive 

BART 2012 

Middletown Unit 

3, Middletown 

5709** 5709 3426 3426 11419 

Middletown Unit 

4, Middletown 

11284** 11284 6770 6770 22568 

Montville Unit 6, 

Montville 

22442 11221 6733 6733 22442 

Norwalk Unit 2, 

Norwalk 

8557 4278 2567 2567 8557 

Bridgeport Harbor 

Unit 3, Bridgeport 

18212 9877 5926 2694 2694*** 

New Haven 

Harbor Unit 1, 

New Haven 

20508 10282 6169 6169 20508 

Cascades 

Boxboard Group 

PFI Boiler, 

Versailles 

1325 662 662 662 1325 

Total 88037 53313 32253 29021 89513 

*Based on the lower of RCSA section 22a-174-19a regulatory limits or federally enforceable 

permit (New Source Review) conditions. 

**Fuel sulfur limited to 0.5% in Consent Order no. 7024. 

***While this level of control (95% removal or 0.15 lb SO2/MMBtu) is not required by EPA 

guidelines, it is recommended that such level of control be considered when determining 

BART. 
Connecticut Regional Haze Page 9-20 

State Implementation Plan November 2009 

Table 9.6: SO2 Daily Potential Emissions @ 24 Hours (tpd) 

BART-eligible 

Unit/Location 

2001* 2002* 2006* MANE-VU 

BART 

workgroup 

presumptive 

BART 2012 

EPA 

presumptive 

BART 2012 

Middletown Unit 3, 

Middletown 

15.6 15.6 9.4 9.4 31.3** 

Middletown Unit 4, 

Middletown 

30.9 30.9 18.5 18.5 61.8** 

Montville Unit 6, 

Montville 

61.5 30.7 18.4 18.4 61.5 

Norwalk Unit 2, 

Norwalk 

23.4 11.7 7.0 7.0 23.4 

Bridgeport Harbor 

Unit 3, Bridgeport 

49.9 27.1 16.2 7.4 7.4*** 

New Haven Harbor 

Unit 1, New Haven 

56.2 28.2 16.9 16.9 56.2 

Cascades Boxboard 

Group PFI Boiler, 

Versailles 

3.6 1.8 1.8 1.8 3.6 

Total 241.1 146 88.2 79.4 245.2 

*Based on the lower of RCSA section 22a-174-19a regulatory limits or federally enforceable 

permit (New Source Review) conditions. 

**Fuel sulfur limited to 0.5% in Consent Order no. 7024. 

***While this level of control (95% removal or 0.15 lb SO2/MMBtu) is not required by EPA 

guidelines, it is recommended that such level of control be considered when determining 

BART. 
Connecticut Regional Haze Page 9-21 

State Implementation Plan November 2009 

Table 9.7: SO2 Actual Annual Emissions (tpy) 

Source/Unit/Location 2001 2002 2006 

Middletown Unit 3, 

Middletown 

1830 269 124 

Middletown Unit 4, 

Middletown 

1015 308 123 

Montville Unit 6, 

Montville 

2182 794 217 

Norwalk Unit 2, 

Norwalk 

1701 322 374 

Bridgeport Harbor Unit 

3, Bridgeport 

10429 4024 2808 

New Haven Harbor Unit 

1, New Haven 

9543 4010 689 

Cascades Boxboard 

Group, PFI Boiler, 

Versailles 

251 0.5 215 

Total 26,951 9727 4550 

 

Presumptive BART potential emission levels for 2012 (tpy) in Table 9.5 were calculated by 

multiplying the MANE-VU BART workgroup and EPA recommended BART emission rates 

in lb/MMBtu by the design capacity of the unit in MMBtu/hr by 8760 hrs/year as follows: 

• For Bridgeport Harbor 3, the sole coal-burning unit, 0.15 lb/MMBtu, the MANE-VU 

BART workgroup’s and EPA’s recommended SO2 emission rate for coal-burning 

units, was used. 

• For the five oil-burning EGUs, the MANE-VU BART workgroup’s and EPA’s 

recommended BART emission rates of 0.33 lb/MMBtu and 1.1 lb/MMBtu 

respectively, were used in the calculations. 

• MANE-VU BART workgroup post-BART SO2 potential emissions for Cascades 

Boxboard Group – Connecticut LLC were assumed not to change after 2002 because 

the source became subject to RCSA section 22a-174-19a in 2002 (0.55 lb/MMBtu) 

and the allowable SO2 limit did not change after that date so the 2006 potential 

emissions remain the same. 
Connecticut Regional Haze Page 9-22 

State Implementation Plan November 2009 

Figure 9.4 is a map of Connecticut designating 2001, 2002 and 2006 SO2 potential emissions 

from all Post-2002 NOx Budget Program sources and 2001, 2002 and 2006 SO2 potential 

emissions from BART-eligible sources. 

Figure 9.4: 

As shown in Table 9.8, by comparing SO2 potential emission reductions since 2002 from all 

Post-2002 NOx Budget Program sources subject to RCSA section 22a-174-19a (89,537 tons 

minus 60,304 tons equals 29,233 tons) with SO2 potential post-BART emission reductions 

from BART-eligible sources since 2002 (53,313 tons minus 29,021 tons equals 24292), it is 

apparent that Connecticut’s existing SO2 regulatory requirements achieve approximately 

4,841 tons of greater reductions than estimated reductions from BART alone. 
Connecticut Regional Haze Page 9-23 

State Implementation Plan November 2009 

Table 9.8: Comparison of SO2 Potential Emissions and Reductions since 2002 

from all Post-2002 NOx Budget Program sources vs. BART-eligible sources 

alone (tpy) 

SO2 potential emissions from all 

Post-2002 NOx Budget Program 

sources 

Year=2002 Year=2006 Reduction 

in potential 

emissions 

89,537 60,304 29,233 

SO2 potential emissions from BARTeligible sources alone 

 Year=2012 

53,313 29,021 24,292 

Additional reductions beyond BART 

alone 

 4,841 

Table 9.9 shows the reductions in actual SO2 emissions from all Post-2002 NOx Budget 

Program sources and all BART-eligible sources since 2001. Note the significant reduction in 

actual SO2 emissions starting in 2002 (effective year of Tier 1 of RCSA section 22a-174-19a) 

and continuing in 2006 (Tier 2 of RCSA section 22a-174-19a was effective in 2003). 

Attachment X contains maps of reductions in actual SO2 emissions since 2001 from all Post2002 NOx Budget Program sources as well as all BART-eligible sources (both Connecticutspecific and as related to Class I areas).

Table 9.9: Comparison of SO2 Actual Emissions and Reductions since 2001 from all 

Post-2002 NOx Budget Program sources vs. BART-eligible sources alone (tpy) 

SO2 actual emissions from all 

Post-2002 NOx Budget Program 

sources 

Year=2001 Year=2002 Year=2006 Reduction in 

actual emissions 

since 2001 

35,625 13,056 7,146 28,479 

SO2 actual emissions from 

BART-eligible sources alone 

26,951 9,727 4,549 22,402 

Additional reductions beyond 

BART-eligible sources alone 

 6,077 

40 CFR 51.308(e)(3) provides a process for determining whether an alternative measure 

makes greater reasonable progress than would be achieved through the installation and 

operation of BART. If the geographic distribution of emissions reductions is similar between 
Connecticut Regional Haze Page 9-24 

State Implementation Plan November 2009 

an alternative measure and BART, the comparison of the two measures may be made on the 

basis of emissions alone. The alternative measure may be deemed to make greater reasonable 

progress than BART if it results in greater emissions reductions than requiring sources subject 

to BART to install, operate and maintain BART. In this case, the geographic distribution of 

emissions reductions is similar (see map in Figure 9.4) and greater emissions reductions than 

BART are achieved by the alternative measure. Figure 9.5 shows 2001, 2002 and 2006 SO2 

potential emissions from all Post-2002 NOx Budget Program sources and 2001, 2002 and 

2006 SO2 potential emissions from BART-eligible sources as related to nearby Class I areas. 

 

Figure 9.5: (With Class I Areas) 

Timing. 

Because CTDEP’s SO2 regulatory requirements were effective in 2002/2003, greater air 

quality benefit has been realized than from the BART timing requirements. EPA requires 

compliance with BART emission limitations no later than 5 years after EPA approves the 

state’s regional haze SIP (70 FR 39172); such SIPs were due to EPA in December of 2007. 

Therefore, Connecticut and its neighboring states will have benefited from reduced SO2

emissions for many years compared with when such reductions are required by EPA’s BART 
Connecticut Regional Haze Page 9-25 

State Implementation Plan November 2009 

rule. As can be seen in Tables 9.8 and 9.9, emissions reductions from Connecticut’s 

Alternative BART Program for SO2 occurred during the first implementation period of the 

regional haze rule, 2000 through 2018. 

9.3.2 Connecticut’s NOx Program for Alternative BART

Most of the BART-eligible units in Connecticut installed NOx reduction technology during 

the early to mid 1990’s in response to Connecticut’s ozone reduction strategies, whereby 

lower NOx emission limits were promulgated. As described below, CTDEP has concluded 

that the NOx emission limits contained in the existing regulations are at least as stringent in 

reducing NOx emissions as BART controls alone. 

Summary of Revisions to RCSA Sections 22a-174-22, 22a, 22b and 22c

Pursuant to the ozone reasonably available control technology (RACT) provisions of the 1990 

Clean Air Act Amendments, in 1995, CTDEP adopted NOx control regulations (RCSA 

section 22a-174-22) achieving substantial reductions in 24-hour NOx emission rates from a 

variety of sources, including the BART-eligible units. The maximum allowable 24-hour NOx

emission rate for cyclone furnaces (including Middletown Unit 3) was reduced by 52%, the 

maximum allowable 24-hour NOx emission rate for existing coal-fired boilers (Bridgeport 

Unit 3) was reduced by 58% and the maximum allowable 24-hour NOx emission rate for no. 6 

oil-fired boilers (including Middletown Unit 4, Montville Unit 6, Norwalk Unit 2, New Haven 

Harbor Unit 1 and Cascades Boxboard’s PFI boiler) was reduced by 17% when compared to 

previously adopted NOx limits. 

Since 1999, CTDEP has adopted several NOx budget trading programs which progressively 

reduced allowances allocated to Connecticut’s NOx budget sources during the summer ozone 

season. RCSA section 22a-174-22a limited the summer NOx emissions budget to 5866 tons 

beginning in 1999 and RCSA section 22a-174-22b reduced the summer NOx budget further to 

4466 tons beginning in 2003. All of Connecticut’s BART-eligible units are currently subject 

to the Post-2002 NOx Budget Program (RCSA section 22a-174-22b sources listed in Table 

9.4) and are also included in the CAIR NOx Ozone Season Trading Program starting in 2009 

pursuant to RCSA section 22a-174-22c. The CAIR NOx Ozone Season Trading Program 

includes a NOx budget for Connecticut sources of 2691 tons that is not to be exceeded during 

the ozone season (May 1st through September 30th each year). Implementation of the CAIR 

Program (2691 tons of summer season NOx) will result in a 76% reduction from the estimated 

11203 tons of ozone season NOx emissions from NOx Budget Program sources in 1990. 

In addition to these ozone season requirements for EGUs 15 MW and greater and large 

industrial sources, RCSA section 22a-174-22(e)(3) (adopted in 2000) required that, starting in 

October 2003, sources subject to RCSA section 22a-174-22 that are also NOx Budget 

Program sources meet a non-ozone seasonal NOx emission rate of 0.15 lb/MMBtu. 

Therefore, all of Connecticut’s NOx Budget Program sources (listed in Table 9.4), including 

all of Connecticut’s BART-eligible sources, are subject to year-round NOx emission 

restrictions. Pursuant to RCSA section 22a-174-22, CTDEP allows sources subject to the 24-

hour and non-ozone season NOx emission limits to use NOx discrete emission reduction 

credits or NOx Budget Program allowances to comply with the subject emission limits. Table 

9.10 shows applicable NOx limits for the BART-eligible units and Table 9.11 shows NOx

allowances allocated to these sources under the various emissions trading programs.
Connecticut Regional Haze Page 9-26 

State Implementation Plan November 2009 

 Table 9.10: Historical NOx limits for BART-eligible Units (lb/MMBtu)1, 2, 3, 4 

BART-eligible Unit Pre-1995 24-hr NOx limit 24-hr NOx limits as of 5/31/95

Middletown Unit 3 0.9 (oil) 0.25 (no. 6 oil)/0.20 (no. 2 oil, 

gas) 

Middletown Unit 4 0.3 (oil) 0.25 (no. 6 oil)/0.20 (no. 2 oil) 

Montville Unit 6 0.3 (oil) 0.25 (no. 6 oil)/0.20 (no. 2 oil) 

Norwalk Unit 2 0.3 (oil) 0.25 (no. 6 oil)/0.20 (no. 2 oil) 

Bridgeport Harbor 

Unit 3 

0.9 (coal)/0.3 (oil) 0.38 (coal)/0.25 (no. 6 oil)/0.20 

(no. 2 oil) 

New Haven Harbor 

Unit 1 

0.3 (oil)/0.9 (gas) 0.25 (no. 6 oil)/0.20 (no. 2 oil, 

gas) 

Cascades PFI Boiler 0.3 (oil)/0.9 (gas) 0.25 (no. 6 oil)/0.20 (gas) 

1

Starting in May 1999 all of the BART-eligible units were in Phase I of the NOx Budget Program (see 

Table 9.11) with the additional ozone-season budget constraint (5866 tons) equating to an approximate 

0.20 lb/MMBtu NOx emission rate. 

2

Starting in May 2003 all of the BART-eligible units were in Phase II of the NOx Budget Program 

(NOx SIP Call) with the additional ozone-season budget constraint (4477 tons, later revised to 4466 

tons) equating to an approximate 0.15 lb/MMBtu NOx emission rate.

3

Starting in October 2003 all of the BART-eligible units were also required to meet a non-ozone 

seasonal NOx limit of 0.15 lb/MMBtu, with a credit trading compliance option.

4

Starting in 2009 all of the BART-eligible units are subject to the CAIR NOx Ozone Season Trading 

Program with an additional ozone-season budget constraint (2691 tons) equating to an approximate 

0.14 lb/MMBtu NOx emission rate. 
Connecticut Regional Haze Page 9-27 

State Implementation Plan November 2009 

 Table 9.11: NOx Ozone Season Allowances Allocated to BART-eligible Units 

BART-eligible Unit 1999 NOx Budget 

Program (5866 tons) 

2005 NOx SIP Call 

(4466 tons) 

2009 CAIR (2691 

tons) 

Middletown Unit 3 379 188 124 

Middletown Unit 4 122 24 60 

Montville Unit 6 320 86 59 

Norwalk Unit 2 375 186 88 

PSEG Bridgeport Unit 

3 

1111 2568 741 

PSEG New Haven 

Unit 1 

965 399 154 

Cascades PFI Boiler 85 71 81 

Total 3357 3522 1307 

For oil-fired EGUs at 750 MW or larger power plants, EPA’s BART Guideline recommends 

states should consider requiring the use of controls year-round for units currently using SNCR 

for part of the year. The only BART-eligible units at a 750 MW power plant in Connecticut, 

Middletown Units 3 and 4, both have boiler excess air control for NOx and Middletown Unit 3 

also has SNCR for NOx control purposes. For oil-fired and gas-fired EGUs larger than 200 

MW, EPA believes that installation of current combustion control technology is generally 

highly cost-effective and should be considered in BART determinations. 

The MANE-VU BART workgroup’s recommended NOx BART emission limits for nonCAIR EGUs are to extend the use of controls to year-round in the NOx SIP Call area and 

operate in an emission limit range of 0.1 – 0.25 lb/MMBtu of heat input, depending on coal 

and boiler type. For industrial boilers, the MANE-VU BART workgroup’s recommended 

NOx BART emission limit range is 0.1 – 0.4 lb/MMBtu, depending on boiler and fuel type 

(consistent with OTC control strategies and NOx SIP Call emission limits). Pursuant to the 

CAIR NOx Ozone Season Trading Program and RCSA section 22a-174-22(e)(3), all of 

Connecticut’s BART-eligible sources are subject to year-round NOx emission rates of 0.14 

lb/MMBtu (ozone season) and 0.15 lb/MMBtu (non-ozone season). All of Connecticut’s 

BART-eligible sources monitor NOx emissions with CEMS pursuant to 40 CFR 75. 

Analysis of CT’s Alternative BART Program for NOx

EPA states “participation in either the annual or seasonal CAIR NOx cap-and-trade program is 
Connecticut Regional Haze Page 9-28 

State Implementation Plan November 2009 

a necessary condition for relying on EPA’s determination that states can substitute CAIR for 

BART for NOx.” (71 FR 60623) Connecticut finalized its CAIR regulation for participation 

in the CAIR NOx Ozone Season Trading Program (CAIR Program) in 2009 and submitted its 

CAIR SIP Revision to EPA. This SIP revision was approved by EPA on January 24, 2008 

(73 FR 4105). While it is unknown at this time how EPA will resolve the remand of CAIR, it 

is assumed that whatever changes EPA makes will result in reduction levels at least as 

stringent as CAIR. As part of its PM2.5 SIP revision on November 18, 2008, CTDEP 

submitted RCSA section 22a-174-22(e)(3) to EPA in order to make the 0.15 lb/MMBtu nonozone seasonal limit for NOx Budget Program sources federally enforceable. The approval 

request is pending. 

As weight of evidence that Connecticut’s NOx control programs achieve better than BART 

reductions, there are three elements that should be considered: 

• DERC Trading. Sources using NOx discrete emission reduction credits 

(DERCs) in order to comply with the 24-hour and non-ozone seasonal limits in 

RCSA section 22a-174-22 are required to retire an additional 5% of DERCs 

beyond the regulatory limit as a design margin in order to simulate real-world 

controlled conditions. Sources generating NOx DERCs through over control are 

required to retire 10% of DERCs generated for the benefit of the environment. 

• CAIR Budget Reduction. EPA required that an additional source (Exeter 

Energy), not previously in CTDEP’s NOx Budget Programs, be added to 

CTDEP’s CAIR Program without increasing the budget of NOx allowances 

available to the State. Exeter Energy typically emits approximately 50 tons of 

NOx per ozone season. The addition of another source to the CAIR universe 

reduced allocations available for other CAIR Program sources, including all of 

the BART-eligible EGUs. In addition, Connecticut is the only state with a CAIR 

budget that does not decrease in 2015 (however, this may change as a result of 

the CAIR remand). Connecticut’s CAIR budget was obtained by using overly 

conservative NOx SIP Call calculated budget levels prior to the February 1999 

memorandum of understanding between Massachusetts, Rhode Island and 

Connecticut (64FR49987, September 15, 1999) and subsequent revised NOx SIP 

Call budget levels, so in essence, Connecticut is required to meet a 2015 

equivalent CAIR budget in 2009. 

• CAIR Allocations. CTDEP is changing the allocation methodology that was 

previously used in its NOx Budget Programs for the CAIR Program. Starting in 

2012, unless the CAIR remand necessitates a change, all megawatt hours of 

electricity generated by CAIR Program sources will be treated equally for the
Connecticut Regional Haze Page 9-29 

State Implementation Plan November 2009 

purpose of allocating allowances, and the less efficient EGUs, including all of 

the BART-eligible EGUs, will receive substantially fewer allowances than they 

received under the NOx Budget Programs, thereby encouraging further NOx

reducing measures such as controls and/or repowering. 

Attachment X contains a spreadsheet that lists all of the Post-2002 NOx Budget Program units 

that are also subject to the non-ozone seasonal emission limit of 0.15 lb/MMBtu and shows 

the NOx potential emissions from 1994, 2002 and 2006. Where 2006 potential emissions did 

not decrease from 2002 potential emission levels, the unit’s allowable or permitted level did 

not decrease. As can be seen in Table 9.12, NOx potential and actual emissions have 

decreased since 1994 as a result of revised RCSA section 22a-174-22 (Control of NOx) 

requirements and additional reductions since 2002 have been achieved as a result of the 

RCSA section 22a-174-22(e)(3) non-ozone seasonal emission limit. 

Table 9.12: Potential and Actual NOx Emissions from all Post-2002 NOx Budget 

Program Units (tpy) 

 1994 2002 2006 

Potential Emissions 89812 46188 34833 

Actual Emissions 13411 6150 5346 

Figure 9.6 contains a map of Connecticut designating NOx potential emissions in 1994, 2002 

and 2006 from all Post-2002 NOx Budget Program units by county as well as all BARTeligible units. As with SO2, the geographic distribution of emissions is similar when 

comparing NOx reductions between the alternative measure and requiring sources subject to 

BART to install, operate, and maintain BART. 
Connecticut Regional Haze Page 9-30 

State Implementation Plan November 2009 

Figure 9.6: 

Figure 9.7 shows 1994, 2002 and 2006 NOx potential emissions from all Post-2002 NOx

Budget Program sources and 1994, 2002 and 2006 NOx potential emissions from BARTeligible sources as related to nearby Class I areas. 
Connecticut Regional Haze Page 9-31 

State Implementation Plan November 2009 

Figure 9.7: (With Class I Areas) 

Attachment X contains maps of reductions in actual NOx emissions since 1994 from all Post2002 NOx Budget Program sources as well as all BART-eligible sources (both Connecticutspecific and as related to Class I areas).

Tables 9.13 and 9.14 show the 1994 (pre-RCSA section 22a-174-22 revisions), 2002 and 

2006 NOx potential emissions (both tons per year and tons per day) from BART-eligible units. 

In order to show reductions achieved as a result of the 2003 non-ozone seasonal limit, both 

ozone season and non-ozone season numbers are provided for 2006. Table 9.15 shows the 

1994, 2002 and 2006 NOx actual emissions from the BART-eligible units. By comparing 

NOx potential emissions reductions since 1994 from all Post-2002 NOx Budget Program 

sources with NOx potential emissions reductions since 1994 from BART-eligible units, it is 

evident that Connecticut’s existing NOx regulatory requirements achieve greater NOx

reductions than from BART alone (This is also illustrated in Figure 9.6).
Connecticut Regional Haze Page 9-32 

State Implementation Plan November 2009 

 

 Table 9.13: NOx Potential Emissions* (tpy) 

BART-eligible 

Unit/Fuel 

1994 

(tpy)

 2002 

(tpy)

2006 tons 

per ozone 

season 

2006 tons 

per nonozone season 

2006 annual 

tons 

Middletown Unit 

3/No. 6 oil 

8329 3980 1668 806 2474 

Middletown Unit 

4/No. 6 oil 

5691 4742 1988 1653 3641 

Montville Unit 6/No. 

6 oil 

6121 5101 2138 1778 3916 

Norwalk Unit 2/No. 

6 oil 

2334 1945 815 678 1493 

Bridgeport Harbor 

Unit 3/coal 

16162 6824 2860 1565 4425 

New Haven Harbor 

Unit 1/No. 6 oil 

4661 4661 1959 1629 3588 

Cascades Boxboard 

PFI Boiler/No. 6 oil 

361 301 126 105 231 

Total 43659 27554 11554 8214 19768 

*Based on the lower of RCSA section 22a-174-22 regulatory limits or federally enforceable permit 

(New Source Review) conditions. 

 
Connecticut Regional Haze Page 9-33 

State Implementation Plan November 2009 

 Table 9.14: NOx Potential Emissions (tons per day)* 

BART-eligible 

Unit/Fuel 

 1994 2002 2006 Ozone 

Season 

2006 Non-ozone 

Season 

Middletown Unit 

3/No. 6 oil 

22.8 10.9 10.9 3.80 

Middletown Unit 

4/No. 6 oil 

15.6 13.0 13.0 7.80 

Montville Unit 

6/No. 6 oil 

15.9 13.3 13.3 7.97 

Norwalk Unit 

2/No. 6 oil 

6.48 5.40 5.40 3.24 

PSEG Bridgeport 

Unit 3/coal 

44.3 18.7 18.7 7.38 

PSEG New 

Haven Unit 

1/No. 6 oil 

12.8 12.8 12.8 7.68 

Cascades PFI 

Boiler/No. 6 oil 

0.989 0.84 0.84 0.495 

 Total 119.7 75.2 75.2 38.6 

*Based on the lower of RCSA section 22a-174-22 regulatory limits or federally enforceable permit 

(New Source Review) conditions. 

Table 9.15: NOx Actual Emissions (tpy) 

BART-eligible Unit Pre-RACT (1994) 2002 2006 

Middletown Unit 3 1293 468 406 

Middletown Unit 4 274 145 145 

Montville Unit 6 307 312 147 

Norwalk Unit 2 802 82 203 

PSEG Bridgeport Unit 

3 

3654 1689 2085 

PSEG New Haven 

Unit 1 

1802 1143 369 

Cascades PFI Boiler 462 215 288 

Total 8594 4054 3643 
Connecticut Regional Haze Page 9-34 

State Implementation Plan November 2009 

Table 9.16 shows the NOx reduction in potential emissions between 2002 and 2006 from all 

Post-2002 NOx Budget Program sources as compared with the reduction in NOx potential 

emissions from BART-eligible sources alone. The “low end” and “high end” numbers 

referenced in the “Year-2012” column in Table 9.16 are based on the MANE-VU BART 

workgroup’s recommended emission limit range of 0.1 lb/MMBtu (low end) to 0.25 

lb/MMBtu (high end) for non-CAIR EGUs and 0.1 lb/MMBtu (low end) to 0.4 lb/MMBtu 

(high end) for industrial boilers, depending on coal and boiler type. 

Table 9.16: Comparison of NOx Potential Emissions and Reductions since 2002 from all 

Post-2002 NOx Budget Program sources vs. BART-eligible sources alone (tpy)* 

NOx potential emissions from all 

Post-2002 NOx Budget Program 

sources 

Year=2002 Year=2006 Reduction in 

potential 

emissions 

46,188 34,833 11,355 

NOx potential emissions from 

BART-eligible sources alone 

 

 Year=2012 

27,554 High end- 24,434 

Low end- 9,701 

3,120 

17,853 

*It should be noted that between 1994 and 2006 NOx potential emissions from all sources included in 

the Post-2002 NOx Budget Program were reduced from 89,812 tons to 34,833 tons (a difference of 

54,979 tons). Assuming the high end and low end levels of control referenced above in 2012, NOx

potential emissions from BART-eligible sources alone since 1994 would be reduced from 43,659 tons 

to 24,434 tons for the high end level of control (a difference of 19,225 tons) and to 9,701 tons for the 

low end level of control (a difference of 33,958 tons). 

Table 9.17 shows the reductions in actual NOx emissions from all Post-2002 NOx Budget 

Program sources and BART-eligible sources since 1994. Again, Connecticut’s existing NOx 

program has resulted in considerably more NOx reductions (3,114 tons) than BART control 

alone. 

Table 9.17: Comparison of NOx Actual Emissions and Reductions since 1994 from all 

Post-2002 NOx Budget Program sources vs. BART-eligible sources alone (tpy) 

NOx actual emissions from all 

Post-2002 NOx Budget Program 

sources 

Year=1994 Year=2002 Year=2006 Reduction in 

actual emissions 

since 1994 

13,411 6,150 5,346 8,065 

NOx actual emissions from 

BART-eligible sources alone 

 8,594 4,054 3,643 4,951 

Additional reductions beyond 

BART-eligible sources alone 

3,114 
Connecticut Regional Haze Page 9-35 

State Implementation Plan November 2009 

Timing

Greater air quality benefits for the citizens of Connecticut and neighboring states have been 

realized from the early implementation of CTDEP’s NOx regulatory requirements than would 

have occurred under EPA’s BART implementation requirements (five years after EPA 

approval of CTDEP’s regional haze SIP). As can be seen in Tables 9.13 through 9.17, 

emissions reductions from Connecticut’s Alternative BART Program for NOx occurred during 

the first implementation period of the regional haze rule, 2000 through 2018. 

9.3.3 BART Requirements for PM

Sections 9.3.1. and 9.3.2. of this SIP demonstrated that Connecticut’s existing SO2 and NOx

regulations meet the requirements of alternative BART for SO2 and NOx. This section 

describes BART for primary PM through a qualitative analysis of the five factors: i) existing 

controls, ii) visibility improvement reasonably expected from implementation of controls, iii) 

cost of controls, iv) remaining useful life of the source, and v) energy and non air quality 

impacts from controls. 

EPA’s BART guidelines for 750 MW and greater power plants do not contain presumptive 

emission limits for PM. The MANE-VU BART workgroup’s recommended BART emission 

limits for PM (measured as particles less than 2.5 microns in diameter, or PM2.5) are emission 

rate ranges of 0.02-0.04 lb/MMBtu for non-CAIR EGUs and 0.02-0.07 lb/MMBtu for 

industrial boilers. 

Existing controls at sources

Table 9.18 shows the registration/permit status and existing PM controls at BART-eligible 

units in Connecticut. 

Table 9.18: Registration/Permit Status and Existing Primary PM Controls at BARTEligible Units 

BART-eligible Unit Registration/Permit Status Existing Primary PM 

Controls** 

Middletown Unit 3 Registration, Title V ESP 

Middletown Unit 4 NSR*, Title V None 

Montville Unit 6 Registration, Title V None 

Norwalk Unit 2 Registration, Title V ESP 

PSEG Bridgeport Unit 3 NSR*, Title V ESP 

PSEG New Haven Unit 1 NSR*, Title V ESP 

Cascades PFI Boiler Registration, Title V None 

*Federally enforceable New Source Review permit 

**Also see Table 9.2 for existing PM precursor pollutant controls 
Connecticut Regional Haze Page 9-36 

State Implementation Plan November 2009 

Upon renewal or revision of the Title V permits for Middletown Unit 3, Norwalk Power Unit 

2, PSEG Power Bridgeport Unit 3 and PSEG Power New Haven Harbor Unit 1, existing ESP 

controls will be included as an applicable requirement pursuant to 40 CFR Part 51 (BART). 

PSEG Bridgeport Unit 3 also installed a baghouse for mercury control, which was fully 

operational in July 2008, thereby achieving concomitant PM reduction benefits. 

RCSA section 22a-174-18 includes PM emission limits of 0.10 lb/MMBtu for natural gas and 

0.14 lb/MMBtu for no. 6 oil for registered sources (Middletown Unit 3, Montville Unit 6, 

Norwalk Unit 2, Cascades PFI boiler). For permitted sources (Middletown Unit 4, PSEG 

Bridgeport Unit 3 and PSEG New Haven Unit 1), RCSA section 22a-174-18 includes a PM 

emission limit of 0.10 lb/MMBtu. However, the PSEG Bridgeport and New Haven units have 

more stringent PM permit emission limits than are specified by RCSA section 22a-174-18 for 

some fuels. The specific permitted PM emission rate for PSEG Bridgeport Unit 3 operating 

on coal is 0.06 lb/MMBtu and the specific permitted PM emission rates for PSEG New Haven 

Unit 1 are 0.061 lb/MMBtu operating on residual oil and 0.003 lb/MMBtu operating on 

natural gas. CTDEP submitted the current version of RCSA section 22a-174-18 to EPA for 

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

Visibility improvement reasonably expected from application of controls

MANE-VU’s 2002 individual unit modeling shows that none of Connecticut’s PM emissions 

from BART-eligible sources have a significant visibility impact on any Class I area (see Table 

9.19). 

Table 9.19: MANE-VU modeling of individual unit emissions for 2002 

Federal Class 1 area with maximum 

simulated impact 

Highest simulated PM10 impact on 20% 

best days (delta-deciview) with impacting 

BART-eligible unit 

Brigantine Wilderness 0.0000 (Middletown Unit 3) 

Lye Brook Wilderness 0.0025 (Middletown Unit 4) 

Acadia National Park 0.0005 (Montville Unit 6) 

Brigantine Wilderness 0.0002 (Norwalk Unit 2) 

Brigantine Wilderness 0.0035 (PSEG Bridgeport Unit 3) 

Brigantine Wilderness 0.0012 (PSEG New Haven Unit 1) 

Acadia National Park 0.0004 (Cascades PFI Boiler) 

The PM emission limits in RCSA section 22a-174-18 and Connecticut’s BART-eligible 

source permits (Middletown Unit 4, PSEG Bridgeport Unit 3 and PSEG New Haven Unit 1) 

are less stringent than the MANE-VU BART workgroup’s recommended BART emission 

limits for PM. However, as can be seen in Table 9.19, the highest individual PM visibility 

impact (0.0035 delta-deciview) is significantly less than the 0.1 deciview individual impact 

MANE-VU warrants worthy of consideration of BART controls (see Section 4.1 of the 

MANE-VU Five-Factor Analysis of BART-Eligible Sources, Attachment W). 

Cost of controls

Table 9.20 shows the cost of PM controls per year for those BART-eligible units without PM 

controls as well as actual PM emissions for 2005. Numbers were calculated by using the 

range of control technologies and cost per actual cubic feet per minute (ACFM) of gas flow 

values provided in NESCAUM’s Assessment of Control Technology Options for BARTEligible Sources (March 7, 2005) (Attachment Z) and ACFM values provided in the 2005
Connecticut Regional Haze Page 9-37 

State Implementation Plan November 2009 

emission statements. 

 Table 9.20: Cost of PM Controls and 2005 Actual PM Emissions 

Capital Cost 

Ranges ($)

Fixed & Variable 

O&M Cost Ranges 

($/year) 

2005 Actual PM 

Emissions (tons) 

Middletown Unit 4 20,496,000-

68,320,000 

683,200-3,416,000 46 

Montville Unit 6 20,220,000-

67,400,000 

674,000-3,370,000 18 

Cascades PFI Boiler 120,000-4,800,000 48,000-324,000 42 

Given the very high cost per ton reduced for the remaining BART-eligible units without PM 

controls (the EGUs (Middletown Power Unit 4 and Montville Power Unit 6) are loadfollowing units that operate infrequently), along with the lack of PM contribution evidence 

from MANE-VU’s modeling, the existing conditions in Connecticut with respect to PM 

control are deemed to be equivalent to BART. 

Remaining useful life of the source

The MANE-VU BART workgroup’s recommendation on the remaining useful life factor is 

that BART-eligible sources with reasonable control options available should either control 

emissions from the BART-eligible sources prior to 2013 or accept a federally enforceable 

permit limitation or retirement date prior to each state’s public notice and hearing processes 

and FLM review of BART SIP elements. The weight of this factor was not taken into 

consideration for this analysis. 

Energy and non-air quality environmental impacts

No significant energy or non-air quality environmental benefits or dis-benefits associated with 

PM controls were identified. 

In conclusion, further primary PM control beyond the controls already implemented by 

Connecticut’s BART-eligible units is deemed not warranted at this time as such measures are 

not cost-effective and the visibility contribution from Connecticut’s BART-eligible units with 

respect to PM is insignificant. 
Connecticut Regional Haze Page 9-38 

State Implementation Plan November 2009 

9.4 Reasonably Attributable Visibility Impairment

40 CFR 51.302(c) provides for general plan requirements in cases where the affected Federal 

Land Manager has notified the state that Reasonably Attributable Visibility Impairment 

(RAVI) exists in a Class I Area in the state. Based on the modeling conducted by MANE-VU 

and consultations with Federal Land Managers, there are no RAVI sources in Connecticut or 

the other MANE-VU states. 

9.5 Conclusion

CTDEP’s existing regulatory programs for SO2, NOx and PM reductions achieve a greater 

visibility improvement than BART alone because the recommended MANE-VU BART 

workgroup or EPA presumptive BART emission rate levels have been applied to a larger 

universe of sources (that includes the BART-eligible units) than the seven BART-eligible 

units in Connecticut. In addition, CTDEP’s current regulatory levels were effective many 

years earlier than would be required by BART. The geographic distribution of sources 

limited by existing emission reduction requirements in Connecticut is equivalent to the 

geographic distribution of BART-eligible units. 

 

From a regional haze perspective, SO2 is the pollutant with the most impact on visibility, and 

CTDEP has substantially reduced SO2 emissions with the implementation of RCSA section 

22a-174-19a. From 2002-2006, Connecticut SO2 emissions from sources subject to RCSA 

section 22a-174-19a reduced by approximately 45%. 

Connecticut’s BART-eligible units are all subject to year-round NOx emission limitations. In 

terms of primary PM, further control beyond the controls already implemented by 

Connecticut’s BART-eligible units is deemed not warranted at this time as such measures are 

not cost-effective and the visibility contribution from Connecticut’s BART-eligible units with 

respect to primary PM is insignificant (see NWS and MM5 modeling results in Attachment 

X). 

CTDEP has submitted to EPA the non-ozone seasonal NOx limit provisions of RCSA section 

22a-174-22, the fuel sulfur content provisions of RCSA section 22a-174-19a and the primary 

PM emission limits of RCSA section 22a-174-18 in order to make such provisions federally 

enforceable. In addition, CTDEP commits to incorporating as applicable requirements 

existing PM controls into Title V permit renewals for BART purposes. 
Connecticut Regional Haze Page 10-1 

State Implementation Plan November 2009 

10.0 REASONABLE PROGRESS GOALS 

40 CFR 51.308(d)(1) of the Regional Haze Rule requires states with Class I areas to establish, 

for each Class I area within the state, reasonable progress goals (RPG) toward achieving 

natural visibility conditions. On June 1, 2007, the U.S. Environmental Protection Agency 

(EPA) released final guidance to be used by states in setting reasonable progress goals. The 

goals must provide for visibility improvement on the days of greatest visibility impairment 

and ensure no visibility degradation on the days of least visibility impairment for the duration 

of the State Implementation Plan (SIP) period. 

As provided in 40 CFR 51.308(d)(1)(iv), the state must consult with other states in the setting 

of reasonable progress goals. The rule states: 

“In developing each reasonable progress goal, the State must consult with those States which may 

reasonably be anticipated to cause or contribute to visibility impairment in the mandatory Class I 

Federal area. In any situation in which the State cannot agree with another such State or group of 

States that a goal provides for reasonable progress, the State must describe in its submittal the 

actions taken to resolve the disagreement. In reviewing the State’s implementation plan submittal, 

the Administrator will take this information into account in determining whether the State’s goal for 

visibility improvement provides for reasonable progress towards natural visibility condition.” 

Connecticut does not have any Class I areas, but because Connecticut may reasonably be 

anticipated to cause or contribute to visibility impairment in MANE-VU Class I areas, it 

consulted with MANE-VU states with Class I areas: New Hampshire, Maine, Vermont and 

New Jersey. A description of the consultation process is found in Section 3.0, Regional 

Planning and Consultation. Connecticut agrees with the reasonable progress goals established 

by New Hampshire, Maine, Vermont and New Jersey (see Subsection 10.2). As referred to in 

Subsection 2.1, emissions from Connecticut sources also impact Class I areas in West 

Virginia and Virginia, albeit to a much lesser extent than impacts on MANE-VU Class I 

areas. 

The Regional Haze Rule also requires each Class I state to consider four factors in setting 

reasonable progress goals: cost, time needed for compliance, energy and non-air quality 

environmental impacts, and remaining useful life. In addition, the state must show that it 

considered the uniform rate of improvement and the emission reduction measures needed to 

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

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

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

proposed. 

10.1 Calculation of Uniform Rate of Progress 

As a benchmark to aid in developing reasonable progress goals, MANE-VU compared 

baseline visibility conditions to natural visibility conditions at each MANE-VU Class I area. 

The difference between baseline and natural visibility conditions for the 20 percent worst days 

was used to determine the uniform rate of progress that would be needed during each 

implementation period in order to attain natural visibility conditions by 2064. Table 10.1 

presents baseline visibility, natural visibility, and required uniform rate of progress for each 

MANE-VU Class I area. Visibility values are expressed in deciviews (dv), where each 

single-unit deciview decrease would represent a barely perceptible improvement in visibility. 
Connecticut Regional Haze Page 10-2

State Implementation Plan November 2009 

Table 10.1: Uniform Rate of Progress Calculation (all values in deciviews) 

Class I Area 

2000-2004 

Baseline 

Visibility 

(20% Worst 

Days) 

Natural 

Visibility 

(20% Worst 

Days) 

Total 

Improvement 

Needed by 

2018 

Total 

Improvement 

Needed by 

2064 

Uniform 

Annual Rate of 

Improvement 

Acadia National Park 22.9 12.4 2.4 10.5 0.174 

Moosehorn Wilderness and 

Roosevelt Campobello 

International Park 

21.7 12.0 2.3 9.7 0.162 

Great Gulf Wilderness and 

Presidential Range – Dry River 

Wilderness 

22.8 12.0 2.5 10.8 0.180 

Lye Brook Wilderness 24.5 11.7 3.0 12.8 0.212 

Brigantine Wilderness 29.0 12.2 3.9 16.8 0.280 

Note: Both natural conditions and baseline visibility for the 5-year period from 2000 through 2004 were calculated in conformance with an 

alternative method recommended by the IMPROVE Steering Committee.12 

The reasonable progress goals established for MANE-VU’s Class I Areas, described later in 

Subsection 10.2, are expected to provide visibility improvements in excess of the uniform 

rates of progress shown above. 

10.2 Identification of (Additional) Reasonable Control Measures 

Connecticut and the other MANE-VU states have identified specific emission control 

measures – beyond those which individual states or RPOs had already made commitments to 

implement – that would be reasonable to undertake as part of a concerted strategy to mitigate 

regional haze. The proposed additional control measures were incorporated into the regional 

strategy adopted by MANE-VU on June 20, 2007, to meet the reasonable progress goals 

established in this SIP. The basic elements of this strategy are described in the MANE-VU 

“Ask” (see Subsection 3.2.2, Regional Planning and Consultation). States targeted for 

coordinated actions toward achieving these goals include all of the MANE-VU states plus 

Georgia, Illinois, Indiana, Kentucky, Michigan, North Carolina, Ohio, South Carolina, 

Tennessee, Virginia, and West Virginia.13 

In addition to including proposed emission controls in the eastern United States, MANE-VU 

determined that it was reasonable to include anticipated emission reductions in Canada in the 

modeling used to set reasonable progress goals. This determination was based on evaluations 

conducted before and during the consultation process (see description of relevant 

 

12 “Baseline and Natural Visibility Conditions, Considerations and Proposed Approach to the Calculation of Baseline and 

Natural Visibility Conditions at MANE-VU Class I Areas,” NESCAUM, December 2006. 

13 In addition, Vermont identified at least one source in Wisconsin as a significant contributor to visibility impairment at the 

Lye Brook Wilderness Class I Area.
Connecticut Regional Haze Page 10-3

State Implementation Plan November 2009 

consultations in Subsection 3.2.1). Specifically, the modeling accounts for six coal-burning 

EGUs in Canada having a combined output of 6,500 MW that are scheduled to be shut down 

and be replaced by nine natural gas turbine units equipped with selective catalytic reduction 

(SCR) by 2018. 

The process of identifying reasonable measures and setting reasonable progress goals is 

described in the subsections which follow. Further elaboration on the reasonable measures 

which make up the Connecticut/MANE-VU long-term strategy is provided in Section 11.0 of 

this SIP. Under this plan, the affected states will have a maximum of 10 years to implement 

reasonable and cost-effective control measures to reduce primarily SO2 and NOX emissions. 

For a description of how proposed emission control measures were modeled to estimate 

resulting visibility improvements, see Subsection 10.3, Visibility Affects of (Additional) 

Reasonable Control Measures. 

10.2.1 Rationale for Determining Reasonable Controls 

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

reasonable progress goals for each Class I area, the state must consider the costs of 

compliance, the time necessary for compliance, the energy and non-air quality environmental 

impacts of compliance, and the remaining useful life of any potentially affected sources. The 

SIP must include a demonstration showing how these factors were taken into consideration in 

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

consideration is required by the Clean Air Act. 

Focus on SO2: MANE-VU conducted a Contribution Assessment (Attachment B) and 

developed a conceptual model that showed the dominant contributor to visibility impairment 

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

formed from emissions of SO2. While other pollutants, including organic carbon, will need to 

be addressed in order to achieve the national visibility goals, MANE-VU’s contribution 

assessment suggested that an early emphasis on SO2 would yield the greatest near-term 

benefit. Therefore, it is reasonable to conclude that the additional measures considered in 

setting reasonable progress goals require reductions in SO2 emissions. 

Contributing Sources: The MANE-VU Contribution Assessment indicates that emissions 

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

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

for about 15 to 25 percent each. Point sources dominated the inventory of SO2 emissions. 

Therefore, MANE-VU’s long-term strategy includes additional measures to control sources of 

SO2 both within the MANE-VU region and in other states that were determined to contribute 

to regional haze at MANE-VU Class I Areas. 

The Contribution Assessment documented the source categories most responsible for 

visibility degradation at MANE-VU Class I Areas. As described in Section 11.0, Long-Term 

Strategy, there was a collaborative effort between the Ozone Transport Commission and 

MANE-VU to evaluate a large number of potential control measures. Several measures that 

would reduce SO2 emissions were identified for further study. 

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

Inc., “Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas,” 

Final, July 9, 2007, otherwise known as the Reasonable Progress Report (Attachment Y). 
Connecticut Regional Haze Page 10-4

State Implementation Plan November 2009 

This report provides an analysis of the four statutory factors for five major source categories: 

EGUs; ICI boilers; cement and lime kilns; heating oil combustion; and residential wood 

combustion. Table 10.2 summarizes the results of MANE-VU’s four-factor analysis for the 

source categories considered. 

Table 10.2: Summary of Results from Four-Factor Analysis of Different Source Categories 

Source 

Category 

Primary 

Regional 

Haze 

Pollutant 

Control Measure(s) 

Average Cost in 

2006 dollars 

(per ton of 

pollutant 

reduction)

Compliance 

Timeframe 

Energy and NonAir Quality 

Environmental 

Impacts 

Remaining 

Useful Life

Electric 

Generating 

Units 

SO2 Switch to a low-sulfur coal (generally 

<1% sulfur); switch to natural gas 

(virtually 0% sulfur); coal cleaning; 

flue gas desulfurization (FGD), 

including wet, spray-dry, or dry. 

$775-$1,690

based on IPM® 

v.2.1.9 * 

$170-$5,700 based 

on available 

literature

2-3 years following 

SIP submittal 

Fuel supply issues, 

possible permitting 

issues, reduced 

electricity production 

capacity, wastewater 

issues 

50 years or 

more 

Industrial, 

Commercial, 

Institutional 

Boilers 

SO2 Switch to a low-sulfur coal (generally 

<1% sulfur); switch to natural gas 

(virtually 0% sulfur); switch to a 

lower-sulfur oil; coal cleaning; 

combustion controls; flue gas 

desulfurization (FGD), including wet, 

spray-dry, or dry.

$130-$11,000

based on available 

literature; 

dependent on size. 

2-3 years following 

SIP submittal 

Fuel supply issues, 

potential permitting 

issues, control device 

energy requirements, 

wastewater issues 

10-30 years

Cement and 

Lime Kilns 

SO2 Fuel switching; flue gas 

desulfurization (FGD), including wet, 

spray-dry, or dry; advanced flue gas 

desulfurization (FGD).

$1,900-$73,000 

based on available 

literature; 

dependent on size.

2-3 years following 

SIP submittal 

Control device 

energy requirements, 

wastewater issues 

10-30 years

Heating Oil SO2 Switch to lower-sulfur fuel

(varies by state) 

$550-$750 based on 

available literature; 

high degree of 

uncertainty with this 

cost estimate 

Currently feasible; 

capacity issues may 

influence timeframe 

for implementation 

of new fuel standards 

Increased 

furnace/boiler 

efficiency, reduced 

furnace/boiler 

maintenance 

requirements

18-25 years

Residential 

Wood 

Combustion 

PM State implementation of NSPS,

ban on resale of uncertified devices, 

installer training certification or 

inspection program, pellet stoves, 

EPA Phase II certified RWC devices, 

retrofit requirement, accelerated 

changeover requirement or 

inducement 

$0-$10,000 based on 

available literature 

Several years, 

depending on 

mechanism for 

emission reductions 

Increased efficiency 

of combustion 

device, reduced 

greenhouse gas 

emissions 

10-15 years

* Integrated Planning Model® CAIR versus CAIR plus analysis conducted for MARAMA/MANE-VU by ICF Consulting, L.L.C.

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

Report, consulted with one another about possible control measures, and concluded by 

adopting the statements known as the MANE-VU Ask. These statements identify the control 

measures that would be pursued toward improving visibility in the region. The following 

discussions focus on the four basic control strategies chosen by MANE-VU and included in 

the modeling to establish the reasonable progress goals: 

 1.) BART, 

 2.) Low-sulfur fuel oil requirements, 

 3.) Emission reductions from specific EGUs, and 

 4.) Additional measures determined to be reasonable. 
Connecticut Regional Haze Page 10-5

State Implementation Plan November 2009 

10.2.2 Best Available Retrofit Technology Controls 

The MANE-VU states have identified approximately 100 BART-eligible sources in the 

region. Most of these facilities are already controlling emissions in response to other federal 

or state air programs or are likely to install emission controls under new programs. 

Previously, EPA determined that CAIR fulfilled the BART requirement for all EGUs in 

participating CAIR states. Although CAIR has been remanded to EPA, the determination that 

CAIR=BART is still in place. Connecticut anticipates that those same units will be covered 

by successor legislation or new rulemaking in the redesign of CAIR. A complete compilation 

of BART-eligible sources in the MANE-VU region is available in Appendix A of MANEVU’s “Assessment of Control Technology Options for BART-Eligible Sources,” March 2005, 

also known as the BART Report (Attachment Z). 

To assess the benefits of implementing BART in the MANE-VU region, NESCAUM 

estimated emission reductions for twelve BART-eligible sources in MANE-VU states that 

would probably be controlled as a result of BART requirements alone. These sources include 

one EGU and eleven non-EGUs. The affected sources were identified by a survey of states’ 

staff members, who furnished data on the potential control technologies and expected control 

levels for these sources under BART implementation. The twelve sources are listed in Table 

10.3 along with their 2002 baseline and 2018 estimated emissions. Information on these 

sources was incorporated into the 2018 emissions inventory projections that were used in the 

modeling to set reasonable progress goals. 

Table 10.3: Estimated Emissions from BART-Eligible Facilities in MANE-VU States 

(Facilities Likely to be Controlled as a Result of BART Alone) 

State Facility Name Unit 

Name SCC Code

Plant ID 

(MANE-VU 

Inventory)

Point ID 

(MANE-VU 

Inventory)

Facility 

Type 

2002 

SO2

Emissions 

(tons) 

2018 

SO2

Emissions 

(tons) 

MD EastAlco Aluminum 28 30300101 021-0005 28 Metal 

Production 1,506 1,356 

MD Eastalco Aluminum 29 30300101 021-0005 29 Metal 

Production 1,506 1,356 

MD Lehigh Portland 

Cement 39 30500606 013-0012 39 Portland Cement 9 8 

MD Lehigh Portland 

Cement 16 30500915 021-0003 16 Portland 

Cement 1,321 1,189 

MD Lehigh Portland 

Cement 17 30500915 021-0003 17 Portland Cement 976 878 

MD Westvaco Fine Papers 2 10200212 001-0011 2 Paper and 

Pulp 8,923 1,338 

ME Wyman Station Boiler 3 10100401 2300500135 004 EGU 616 308 

ME SAPPI Somerset Power 

Boiler 1 10200799 2302500027 001 Paper and Pulp 2,884 1,442 

ME Verso Androscoggin 

LLC 

Power 

Boiler 1 10200401 2300700021 001 Paper and Pulp 2,964* 1,482 

ME Verso Androscoggin 

LLC 

Power 

Boiler 2 10200401 2300700021 002 Paper and 

Pulp 3,086* 1,543 

NY Kodak Park Division U00015 10200203 8261400205 U00015 Chemical 

Manufacturer 23,798 14,216 

NY Lafarge Building 

Materials, Inc 41000 30500706 4012400001 041000 Portland 

Cement 14800 4440 
Connecticut Regional Haze Page 10-6

State Implementation Plan November 2009 

Note: Many additional sources in MANE-VU are BART-eligible but are expected to be controlled as a result of other 

emission reduction programs (e.g., state-specific multi-pollutant programs, a redesigned CAIR, etc.). 

*Data for 1999 baseline year. 

Best Available Retrofit Technology is Reasonable: BART controls are part of the strategy 

for improving visibility at MANE-VU Class I Areas. MANE-VU prepared reports to provide 

states with information about available control technologies (e.g., MANE-VU’s BART Report 

referenced above), estimated cost ranges, and other factors associated with those controls. 

The reasonable progress goals established in this regional haze SIP assume that states whose 

emissions affect Class I areas in MANE-VU will make determinations demonstrating the 

reasonableness of BART controls for sources in their states. 

10.2.3 Low-Sulfur Fuel Strategy 

The MANE-VU region, especially the Northeast, is heavily reliant on distillate oil for home 

space heating, with more than 4 billion gallons used, according to 2006 estimates from the 

Energy Information Administration14. Likewise, the heavier residual oils are widely used by 

non-EGU sources and, to a lesser extent, the EGU sector. The sulfur content of distillate fuels 

currently averages above 2,000 ppm (0.2 percent). Although the sulfur content of residual 

oils varies by source and region, it can exceed 2.0 percent in the Northeast. Combustion of 

distillate and residual fuel in the MANE-VU states resulted in SO2 emissions totaling 

approximately 380,000 tons in 2002. 

As the second component of MANE-VU’s long-term strategy, the member states agreed to 

pursue measures that would require the sale and use of fuel oils having reduced sulfur content. 

This strategy would be implemented in two phases: 

• Phase 1 would require reducing the sulfur content in distillate (#1 and # 2) fuel oils 

from current levels of 2,000 to 2,300 ppm (0.20 to 0.23 percent) to a maximum of 500 

ppm (0.05 percent) by weight. It would also restrict the sale of heavier blends of 

residual (# 4, #5, and # 6) fuel oils that have sulfur content greater than 2,500 ppm 

(0.25 percent) and 5,000 ppm (0.5 percent) by weight, respectively. 

• Phase 2 would require further reducing the sulfur content of the distillate fraction from 

500 ppm (0.05 percent) to 15 ppm (0.0015 percent) while keeping the sulfur limits on 

residual oils at first-phase levels. 

The two phases are to be introduced in sequence with slightly different timing for an inner zone 

of MANE-VU states15 and the remainder of MANE-VU states. While all MANE-VU states 

have agreed to pursue implementation of both phases to full effect by the end of 2018, it is 

possible that not every state can make a firm commitment to these measures today. States are 

expected to review the situation by the time of the first five-year regional haze SIP progress 

report. 

Reductions in sulfur dioxide emissions will occur as a direct consequence of the low-sulfur 

fuel strategy. For both phases combined, it is estimated that SO2 emissions in the MANE-VU 

region will decline from 2002 levels by 168,222 tons per year for combustion of light 

 

14 U.S. Department of Energy, EIA, Table F3a, at http://www.eia.doe.gov/emeu/states/sep_fuel/html/fuel_use_df.html. 

15 The inner zone includes New Jersey, Delaware, New York, and possibly portions of eastern Pennsylvania. 
Connecticut Regional Haze Page 10-7

State Implementation Plan November 2009 

distillates and by 42,875 tons per year for combustion of the heavier fuels. Together, these 

reductions represent a 35 percent decrease in the projected 2018 SO2 emissions inventory for 

non-EGU sources in the region. 

NESCAUM analyzed the two program phases separately for MANE-VU, but it is the 

combined benefit of implementing both phases that is relevant to the question of visibility 

improvement by 2018. To estimate the effects of the low-sulfur fuel strategy, MANE-VU 

applied the expected sulfur dioxide emission reductions to all non-EGU sources burning #1, 

#2, #4, #5, or #6 fuel oil. These emission reductions would result directly from the lowering 

of fuel sulfur content from original levels to 0.0015 percent for #1 and #2 oil, to 0.25 percent 

for #4 oil, and to 0.5 percent for #5 and #6 oil. 

The reduction in SO2 emissions by 2018 will yield corresponding reductions in sulfate 

aerosol, the main culprit in fine-particle pollution and regional haze. The full benefit of 

MANE-VU’s low-sulfur fuel strategy is represented in Figure 10.1, which displays the 

estimated average reductions in 24-hr PM2.5 concentration as calculated by the CMAQ model 

for the combined first and second phases of the program. 

Figure 10.1: Average Change in 24-hr PM2.5 Due to Low-Sulfur Fuel Strategy 

(Phases I and 2 Combined) Relative to OTB/OTW (values in μg/m3

) 

Low-Sulfur Fuel Oil Requirements are Reasonable: The MANE-VU Contribution Assessment 

documented source apportionment analyses that linked visibility impairment in MANE-VU 
Connecticut Regional Haze Page 10-8

State Implementation Plan November 2009 

Class I Areas with SO2 emissions from sources burning fuel oil. The reasonable assumption 

underlying the low-sulfur fuel oil strategy is that refiners can, by 2018, produce home heating 

and fuel oils that contain 50 percent less sulfur for the heavier grades (#4 and #6 residual oil), 

and 75 to 99.25 percent less sulfur in #2 fuel oil (also known as home heating oil, distillate, or 

diesel fuel) at an acceptably small increase in price to the consumer. 

Four-Factor Analysis – Low-Sulfur Fuel Oil Strategy: The MANE-VU Reasonable Progress 

Report discussed the four factors as they apply to low-sulfur fuel use for ICI boilers and 

residential heating systems. MANE-VU’s Reasonable Progress Report identified switching to 

a lower-sulfur fuel oil as an available SO2 control option that would achieve 50 to 90 percent 

reductions in SO2 emissions from ICI Boilers. The report also noted that home heating oil use 

generates an estimated 100,000 tons of SO2 emissions in the Northeast each year and that SO2

emissions would decline in proportion to reductions in fuel sulfur content. The following 

discussion summarizes information concerning the four factors for the low-sulfur fuel 

strategy.

1) Low-Sulfur Fuel Oil Strategy – Costs of Compliance: The MANE-VU Reasonable 

Progress report noted that because of requirements for motor vehicle fuels, refineries have 

already performed the capital investments required for the production of low-sulfur diesel 

(LSD) and ultra-low sulfur diesel (ULSD). The report estimated a cost per ton of SO2

removed by switching to lower-sulfur fuel would range from $554 to $734 per ton (converted 

from 2001 to 2006 dollars using a conversion factor of 1.1383). In some seasons and some 

locations, low-sulfur diesel is actually less expensive than higher-sulfur diesel fuel. (See 

Chapter 8 of the Reasonable Progress Report.) 

The sulfur content of #4 and #6 fuels can also be cost-effectively reduced. Residual oil is 

essentially a byproduct of the refining process and is produced in several grades that can be 

blended to meet a specified fuel sulfur content limit. New York Harbor residual fuel prices 

for the week ending March 21, 2008, ranged from a low of $71.38 a barrel for 2.0 and 2.2 

percent sulfur fuel to a high of $91.38 per barrel for 0.3 percent sulfur fuel16. 

While the costs of achieving the projected emissions reductions with the low-sulfur fuel 

strategy are somewhat uncertain, they are believed to be reasonable in comparison with the 

costs of controlling other sectors. Some MANE-VU states are proceeding with low-sulfur oil 

requirements much sooner than 2018; however, all of the MANE-VU states concur that a lowsulfur oil strategy is both reasonable and achievable within the MANE-VU region by no later 

than 2018. MANE-VU has concluded that the cost of requiring the use of lower-sulfur fuels 

is reasonable. 

2) Low-Sulfur Fuel Oil Strategy – Time Necessary for Compliance: MANE-VU’s Reasonable 

Progress Report indicated that furnaces and boilers would not have to be retrofit and would 

not require expensive control technologies to burn ULSD distillate fuel oil. Therefore, the 

time necessary for compliance would be determined by the availability of the fuel. 

 

16 During this same period, low-pour (low-temperature, reduced viscosity) residual fuel oil with a 0.5 percent sulfur content 

sold for $80.83 per barrel. Residual oil with a fuel sulfur content limit of 0.7 percent and 1.0 percent traded at $75.13 and 

$72.63, respectively. 
Connecticut Regional Haze Page 10-9

State Implementation Plan November 2009 

The MANE-VU Reasonable Progress Report notes that, on a national scale, more ULSD is 

produced than both LSD and high-sulfur fuel, and concludes that the United States has the 

infrastructure to produce adequate stocks of these fuels. NESCAUM’s report, “Low Sulfur 

Heating Oil in the Northeast States: An Overview of Benefits, Costs, and Implementation 

Issues,” December 2005 (Attachment AA) observes that the federal rules for heavy duty 

highway diesel fuel are flexible, so that if there is a shortage of 15 ppm fuel, the 15 to 500 

ppm fuel could be used to relieve the shortage. With this flexibility, the report concludes that 

the likelihood of a fuel shortage in the short term due to use of ULSD for heating oil is 

diminished. The volatile nature of heating supply and demand presents unique challenges to 

the fuel oil industry. The success of a low-sulfur fuel oil program is predicated on meeting 

these challenges. The Northeast states are assessing a variety of business strategies and 

regulatory approaches that could be used to minimize any potential adverse supply and price 

impacts that could result from a regional 500 ppm sulfur standard for heating oil. Suppliers 

can increase pre-season reserves of low-sulfur product. Blending domestically produced 

biodiesel into heating oil offers opportunity to reduce imports, stabilize supplies and minimize 

supply-related price spikes. 

Potential supply disruptions and price spikes for residual fuels are a particular concern for 

several northern MANE-VU states. Maine, New Hampshire, and Massachusetts receive a 

significant percentage of their residual fuel supplies from offshore sources during the winter 

months, when barge traffic from New York Harbor is interrupted because of severe weather. 

At these times, residual oil is often imported directly from foreign sources (e.g., Venezuela 

and Russia), and stakeholders have expressed concerns that the supply of low-sulfur residual 

fuels may be insufficient to satisfy demand during these periods. While the potential for 

disruptions in the supply of residual fuels is greater than that for distillate oil, these 

disruptions would affect only a limited number of states during extreme weather events. 

MANE-VU has identified several mechanisms that could be implemented to address 

disruptions, including seasonal averaging and emergency waivers. A seasonal averaging 

approach would reduce potential supply constraints by allowing the use of higher-sulfur fuel 

during periods of peak demand (and limited supply), and then requiring the increased sulfur 

content of these fuels to be offset through the use of a lower-sulfur fuel at other times. This 

approach would provide regulatory certainty and greater flexibility during the winter months 

when fuel supplies may be subject to weather-related disruptions, but at a cost of increased 

recordkeeping and compliance monitoring. Since many states already have statutory 

authority to waive fuel sulfur limits in an emergency, states could also utilize their 

discretionary powers to address short-term supply disruptions. 

The strategy adopted by Connecticut and the other MANE-VU states proposes to phase in the 

required use of lower-sulfur fuels over the next 10 years, providing adequate time for full 

implementation. 

3) Low-Sulfur Fuel Oil Strategy – Energy and Non-Air Quality Environmental Impacts of 

Compliance: According to MANE-VU’s Reasonable Progress Report, reducing the sulfur 

content of fuel oil would have a variety of beneficial consequences for boilers and furnaces 

using this fuel. Low-sulfur distillate fuel is cleaner burning and emits less particulate matter, 

thereby reducing the rate of fouling of heating units and allowing longer time intervals 

between cleanings. The MANE-VU report cites a study by the New York State Energy 
Connecticut Regional Haze Page 10-10

State Implementation Plan November 2009 

Research and Development Authority (NYSERDA) that showed that boiler deposits are 

reduced by a factor of two by lowering the fuel sulfur content from 1,400 ppm to 500 ppm. 

The use of low-sulfur oil could extend the useful life of a source by reducing the maintenance 

required because low-sulfur oil is less damaging to the combustion equipment. The report 

also notes that decreasing sulfur levels in fuel would enable manufacturers to develop more 

efficient furnaces and boilers by using more advanced condensing equipment that recovers 

energy normally lost to the heating of water vapor in the exhaust gases. 

Furthermore, SO2 controls would have beneficial environmental impacts by reducing acid 

deposition and helping to decrease ambient concentrations of PM2.5. Reductions in PM2.5

resulting from use of low-sulfur fuels could help nonattainment areas meet health-based 

National Ambient Air Quality Standards. 

4) Low-Sulfur Fuel Oil Strategy – Remaining Useful Life of Any Potentially Affected Sources: 

Residential furnaces and boilers have finite life spans, but they do not need to be replaced to 

burn low- or ultra-low-sulfur fuel oil. The Energy Research Center estimates that the average 

life expectancy of a residential heating oil boiler is 20-25 years. As noted above, use of lowsulfur fuel is less damaging to equipment and could therefore extend the useful life of an oilfired residential furnace or boiler. 

Available information on the remaining useful life of ICI boilers indicates a wide range of life 

expectancies, depending on unit size, capacity factor, and level of maintenance performed. 

(Capacity factor is defined as the actual amount of energy a boiler generates in one year 

divided by the total amount it could generate if it ran full time at full capacity.) The typical 

life expectancy of an ICI boiler ranges from 10 years to more than 30 years. As in the case of 

residential units, use of lower-sulfur fuels could extend the life span of an ICI boiler. 

10.2.4 Targeted EGU Strategy for SO2 Reduction 

EGUs are the single largest sector contributing to visibility impairment at MANE-VU’s Class 

I Areas. SO2 emissions from power plants continue to dominate the emissions inventory. 

Sulfate formed through atmospheric processes from SO2 emissions are responsible for over 

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

visibility (see MANE-VU’s Contribution Assessment, Attachment B). 

To ensure that EGU control measures are targeted at those units having the greatest impact on 

visibility at MANE-VU Class I Areas, a modeling analysis was conducted to identify the 

individual sources responsible for the highest contributions to visibility degradation. 

Accordingly, MANE-VU developed lists of the 100 EGU emission points (stacks) having the 

largest impacts at each MANE-VU Class I Area during 2002. The combined list for all seven 

MANE-VU Class I Areas identified a total of 167 distinct emission points. These 167 stacks 

are spread across the Northeast, Southeast, and Midwest (Figure 10.2). 
Connecticut Regional Haze Page 10-11

State Implementation Plan November 2009 

Figure 10.2: Location of 167 EGU Stacks Contributing the Most to 

Visibility Impairment at MANE-VU Class I Areas 

Note: Some facilities have more than one stack. 

After consultations with its member states and with other RPOs, MANE-VU requested a 90-

percent reduction in SO2 emissions from the top 167 stacks by no later than 2018 (see the 

MANE-VU “Ask”). NESCAUM’s preliminary modeling for MANE-VU showed that SO2

emission reductions of this magnitude from the targeted facilities would produce substantial 

improvements in ambient 24-hour PM2.5 concentrations. Assuming a control level equal to 10 

percent of the 2002 baseline emissions (i.e., 90-percent emission reduction), NESCAUM used 

CMAQ to model sulfate concentrations in 2018 after implementation of controls. The modeled 

sulfate values were then converted to estimates of PM2.5 concentration. Figure 10.3 displays the 

predicted average change in 24-hr PM2.5. 

The map in Figure 10.3 illustrates the reductions in fine-particle pollution in the Eastern U.S. 

that would result from implementation of the targeted EGU strategy for SO2. Improvements in 

PM2.5 levels would occur throughout the MANE-VU region and portions of the VISTAS and 

MRPO regions, especially along the Ohio River Valley. 
Connecticut Regional Haze Page 10-12

State Implementation Plan November 2009 

Figure 10.3: Preliminary Estimate of Average Change in 24-hr PM2.5 Resulting from a 

90-Percent Reduction in SO2 Emissions from the Top 167 EGU Stacks 

Affecting MANE-VU Class I Areas 

Although the reductions would be both advantageous and potentially large, MANE-VU 

determined, after further consultation with affected states, that it was unreasonable to expect 

that the full 90-percent reduction in SO2 emissions would be achieved by 2018. Therefore, 

additional modeling was conducted to assess the more realistic scenario in which emissions 

would be controlled by the individual facilities and/or states to levels already projected to take 

place by that date. At some facilities, the actual emission reductions are anticipated to be 

greater or less than the 90 percent benchmark. For details, see Alpine Geophysics’ report for 

MARAMA entitled, “Documentation of 2018 Emissions from Electric Generating Units in 

the Eastern United States for MANE-VU’s Regional Haze Modeling, Final Report,” August 

16, 2009 (Attachment H).

Targeted EGU SO2 Reduction Strategy Controls are Reasonable: MANE-VU identified 

specific EGU stacks that were significant contributors to visibility degradation at MANE-VU 

Class I Areas in 2002 based on CALPUFF modeling analyses documented in the Contribution 

Assessment. MANE-VU obtained information about existing and planned controls on 

emissions from those stacks. These analyses and information on proposed EGU controls are 

presented in MANE-VU’s Reasonable Progress Report and the Contribution Assessment as 

well as in Section 6.0, Emissions Inventory, and Section 11.0, Long-Term Strategy section of 

this SIP. 
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State Implementation Plan November 2009 

Based on information gathered from the states and regional planning organizations, MANEVU anticipated that emissions from many of the targeted EGU stacks would be subject to 

EPA’s Clean Air Interstate Rule (CAIR). However, because CAIR is a cap-and-trade program, 

it was not possible to predict with certainty which of the 167 stacks would be controlled under 

CAIR in 2018. Given the remand of CAIR, it is less possible to predict with certainty what 

controls will be in place in 2018. 

Four-Factor Analysis – Targeted EGU SO2 Reduction Strategy: The following discussion 

addresses each of the four factors with respect to the strategy of controlling specific EGUs. 

Information is taken primarily from the MANE-VU Reasonable Progress Report (Attachment 

Y) and MANE-VU BART Report (Attachment Z). 

1) Targeted EGU SO2 Reduction Strategy – Costs of Compliance: Technologies to control the 

precursors of regional haze are commercially available today. Because EGUs are the most 

significant stationary source of SO2, NOX, and PM, they have been subject to extensive 

federal and state regulations to control all three pollutants. The technical feasibility of control 

technologies has been successfully proven for a substantial number of small (e.g., 100 MW) 

to very large (over 1,000 MW) boilers burning different types of coal. Over the last few 

years, the cost data clearly indicate that many technologies provide substantial and costeffective emission reductions.

Both wet and dry scrubbers are in wide commercial use in the U.S. for controlling SO2

emissions from coal-fired power plants. The capital costs for new or retrofit wet or dry 

scrubbers are higher than the capital costs for NOX and PM controls. Capital costs for 

scrubbers ranged from $180/kW for large units (greater than 600 MW) to as high as $350/kW 

for small units (200 to 300 MW). (See pages 2-22 through 2-25 of the BART Report, 

Attachment Z). However, the last few years have seen a general trend of declining capital 

costs attributable to vendor competition and technology maturation. Also, the costeffectiveness (in dollars per ton of emissions removed) is very attractive because the high 

sulfur content of the coal burned results in very large amounts of SO2 removed by the control 

devices. The typical cost is in the range of 200 to 500 dollars per ton of SO2 removed, 

although the cost rises steeply for small units burning lower-sulfur coal and operating at low 

capacity factors. For any plant, overall cost-effectiveness depends mainly on the baseline precontrolled SO2 emission rate (or fuel sulfur content), size and capacity factor of the unit, and 

capital costs of flue gas desulfurization (generally ranging from $150 to $200/kW). 

The MANE-VU Reasonable Progress Report reviewed options for controlling coal-fired EGU 

boilers, including switching to lower-sulfur coal, switching to natural gas, coal cleaning, and 

flue gas desulfurization (FGD). The most effective control option (but not necessarily 

appropriate for all installations) is FGD, which can achieve up to 95 percent reduction in SO2

emissions. The costs of different technologies vary considerably among units and were 

estimated to range from as low as $170/ton to as high as $5,700/ton. Table 10.4 summarizes 

the estimated costs of controlling SO2 emissions, expressed in dollars per ton of SO2 removed. 
Connecticut Regional Haze Page 10-14

State Implementation Plan November 2009 

Table 10.4: Estimated Cost Ranges for SO2 Control Options for Coal-Fired EGU Boilers 

(2006 dollars per ton of SO2 removed) 

To predict future emissions and further evaluate the costs of emission controls for electric 

generating units, MANE-VU and other RPOs have followed the example of the US 

Environmental Protection Agency (EPA) in using the Integrated Planning Model (IPM®), an 

integrated economic and emissions model for EGUs. This model projects electricity supplies 

based on various assumptions while at the same time developing least-cost solutions to 

electrical generating needs within specified emissions targets. IPM also provides estimates of 

the costs of complying with various policy requirements. 

EPA developed IPM version 2.1.9 and used this model to evaluate the impacts of CAIR and 

the Clean Air Mercury Rule (CAMR). CAMR was also vacated by the federal courts and is 

no longer in effect. Recently, EPA updated their input data and developed IPM v.3.0. 

However, because of time constraints, all MANE-VU runs were based on EPA IPM v.2.1.9 

with changes made to the input assumptions. As stated previously, CAIR has recently been 

remanded to EPA and it is unknown at this time when EPA will propose a revised or new rule 

in accordance with the court’s July 11, 2008 decision. 

The RPOs collaborated with one another to update the inputs to IPM v.2.1.9 using more 

current data on the EGUs and more realistic fuel prices. The resulting IPM run is called 
Connecticut Regional Haze Page 10-15

State Implementation Plan November 2009 

VISTAS PC_1f. This IPM run serves as the basis for regional air quality modeling for ozone 

and haze SIPs in MANE-VU and the OTC. 

MANE-VU, through MARAMA, contracted with the consulting firm ICF Resources, L.L.C. 

to prepare two new IPM runs, as documented in “Comparison of CAIR and CAIR Plus 

Proposal using the Integrated Planning Model (IPM®),” Final Draft Report, May 30, 2007 

(Attachment BB). The first run, known as the MARAMA CAIR Base Case run (also known 

as MARAMA_5c), was based on the VISTAS PC_1f run and underlying EPA IPM v.2.1.9 

with some updated information on fuel prices, control constraints, etc. The second run, called 

the MARAMA CAIR Plus run (also known as MARAMA_4c), was similarly based on 

VISTAS PC_1f run and the underlying EPA IPM v.2.1.9. The MARAMA CAIR Plus run 

included updated information used in the VISTAS run but assumed lower NOX emission caps 

and higher SO2 retirement ratios. 

Based on the modeling results, MANE-VU estimates that the marginal cost of SO2 emission 

reductions (the cost of reducing one additional ton of emissions) ranges from $640/ton in 

2008 to $1,392/ton in 2018 (see Table 6, “Allowance Prices (Marginal Costs) of Emissions 

Reductions...,” in Attachment BB). 

Costs will vary for individual plants to reduce emissions by 90 percent, as recommended in 

the MANE-VU Ask. However, this strategy provides states with flexibility to pursue controls 

on specific sources as appropriate and to control emissions from alternative sources, if 

necessary, to meet the 90 percent target established in the Ask. 

Given the importance of SO2 emissions from specific EGUs to visibility impairment in 

MANE-VU Class I Areas, the MANE-VU Commissioners, after weighing all factors – the 

availability of technology to reduce emissions, the estimated costs of controls, the costs of 

alternative measures, the flexibility to achieve alternative reductions if necessary, etc. – 

concluded that the costs of the targeted EGU strategy are reasonable. Connecticut agrees with 

this conclusion. 

2) Targeted EGU SO2 Reduction Strategy – Time Necessary for Compliance: MANE-VU’s 

Reasonable Progress Report indicates that, generally, sources are given a 2- to 4-year phase-in 

period to comply with new rules. Under Phase I of the NOX SIP call, EPA provided a 

compliance date of about 31⁄2 years from the SIP submittal date. Most MACT standards allow 

a 3-year compliance period. Under Phase II of the NOX SIP Call, EPA provided for 2-year 

compliance period from the SIP submittal date. MANE-VU Class I states conclude that there 

is more than sufficient time between 2008 and 2018 for affected states to adopt requirements 

and for affected sources to install necessary controls. Connecticut agrees with this 

conclusion.

3) Targeted EGU SO2 Reduction Strategy – Energy and Non-Air Quality Environmental 

Impacts of Compliance: The MANE-VU Reasonable Progress Report identified several 

energy and non-air quality impacts from additional EGU controls. Large-scale fuel switching 

could potentially impact fuel supplies. Flue gas desulfurization systems may generate 

wastewater and sludge (which is sometimes recycled as a useful byproduct). On the other 

hand, SO2, NOX, and ammonia controls would have beneficial environmental impacts by 

reducing acid deposition and nitrogen deposition to water bodies and natural land areas. 

Emission reductions for these pollutants would also produce decreases in ambient levels of 
Connecticut Regional Haze Page 10-16

State Implementation Plan November 2009 

PM2.5 and result in corresponding health benefits. Similarly, mercury emissions may be 

reduced by the addition of controls for other pollutants. MANE-VU Class I states conclude 

that the energy and non-air quality impacts of additional EGU controls are reasonable. 

Connecticut agrees with this conclusion. 

4) Targeted EGU SO2 Reduction Strategy – Remaining Useful Life of Any Potentially Affected 

Sources: As noted in the MANE-VU Reasonable Progress Report, remaining useful life 

estimates of EGU boilers indicate a wide range of operating lifetimes, depending on unit size, 

capacity factor, and level of maintenance performed. Typical life expectancies range to 50 

years or more. Additionally, implementation of air pollution regulations over the years has 

necessitated emission control retrofits that have increased the expected life spans of many 

EGUs. The lifetime of an EGU may be extended through repair, re-powering, or other 

strategies if the unit is more economical to run than to replace with power from other sources. 

Extending facility lifetime may be particularly likely for a unit serving an area with limited 

transmission capacity to bring in other power. 

10.2.5 Non-EGU SO2 Emissions Reduction Strategy for Non-MANE-VU States 

In addition to the measures described above (i.e., BART, low-sulfur fuel, and targeted EGU 

controls), MANE-VU asked states in neighboring regional planning organizations to consider 

further non-EGU emission reductions comparable to those achieved by MANE-VU states 

through application of MANE-VU’s low-sulfur fuel strategy. Previous modeling indicated 

that the MANE-VU low-sulfur fuel strategy would achieve a greater than 28-percent 

reduction in non-EGU SO2 emissions by 2018. After consultation with other states and 

consideration of comments received, MANE-VU decided to include, in the latest modeling 

for the VISTAS and MRPO regions, implementation of control measures capable of achieving 

SO2 emission reductions equivalent to MANE-VU’s 28-percent reduction in non-EGU SO2

emissions in 2018. 

To model the effects of this strategy on visibility at MANE-VU Class I Areas, MANE-VU 

had to make reasonable assumptions about where the requested emission reductions would 

occur in the VISTAS and MRPO states without knowing precisely how those reductions 

would be realized. As a way to represent approximately a 28-percent reduction in non-EGU 

SO2 emissions, the following reductions were modeled: 

• For control measures in VISTAS and MRPO states: 

− Coal-fired ICI boilers: SO2 emissions were reduced by 60 percent. 

− Oil-fired ICI boilers: SO2 emissions were reduced by 75 percent. 

− ICI boilers lacking fuel specification: SO2 emissions were reduced by 50 percent. 

• For additional controls only in the VISTAS states: SO2 emissions from other oil-fired 

area sources were reduced by 75 percent (based on the same SCCs identified in 

MANE-VU’s oil strategies list). 

This modeling scenario represents just one example of realistic strategies that states outside of 

MANE-VU could employ to meet the non-EGU SO2 emissions reductions requested by 

MANE-VU. 
Connecticut Regional Haze Page 10-17

State Implementation Plan November 2009 

A number of non-MANE-VU states have not included, or may not include, the requested 28-

percent reduction in non-EGU SO2 emissions in their initial SIPs. The MANE-VU states 

encourage EPA to hold these states responsible for satisfying the MANE-VU Ask in the 

course of preparing their first five-year progress reports in order to meet the CAA national 

goal of remedying any existing visibility impairment in Class I areas. 

Non-EGU SO2 Emission Reduction Measures Outside MANE-VU are Reasonable: After 

EGUs, ICI boilers are the next largest class of SO2 emitters. ICI boilers are thus a logical 

choice among non-EGU sources for consideration of additional SO2 control measures. 

ICI Boiler Control Options: Air pollution reduction and control technologies for ICI boilers 

have advanced substantially over the past 25 years. However, according to a 1998 survey of 

industrial boilers by EPA (2004), only 2 percent of gas-fired boilers and 3 percent of oil-fired 

boilers had installed any kind of air pollution control device. A larger percentage of coalfired boilers had installed air pollution controls: specifically, 47 percent had installed some 

type of control device, mainly to control particulate matter (PM). Post-combustion SO2

controls were used by less than one percent of industrial boilers in 1998, with the exception of 

boilers firing petroleum coke (2 percent of boilers using this fuel had acid scrubbers). A small 

percentage of industrial boilers had combustion controls in place in 1998, although additional 

low-NOX firing systems may have been installed since that date. 

Almost all SO2 emission control technologies fall into the category of reducing SO2 after its 

formation as opposed to minimizing its formation during combustion. The method of SO2

control appropriate for any individual ICI boiler is dependent upon the type of boiler, type of 

fuel, capacity utilization, and the types and staging of other air pollution control devices. 

However, cost-effective emission reduction technologies for SO2 are available and are 

effective in reducing emissions from the exhaust gas stream of ICI boilers. Post-combustion 

SO2 control is accomplished by reacting the SO2 in the gas with a reagent (usually calcium- or 

sodium-based) and removing the resulting product (a sulfate/sulfite) for disposal or 

commercial use, depending on the particular technology. SO2 reduction technologies are 

commonly referred to as flue gas desulfurization (FGD) and are usually described in terms of 

the process conditions (wet versus dry), byproduct utilization (throwaway versus saleable) 

and reagent utilization (once-through versus regenerable). 

The exceptions to the nearly universal use of post-combustion controls are found in fuel 

switching, coal cleaning, and fluidized bed boilers, in which limestone is added to the fuel in 

the combustion chamber. Both pre- and post-combustion SO2 emission control alternatives 

for ICI boilers are outlined in Table 10.5. Further description of these technology options is 

available in Chapter 4 of the MANE-VU Reasonable Progress Report (Attachment Y). 

The SO2 removal efficiency of these controls varies from 20 to 99+ percent depending on the 

fuel type and control technology. For coal-fired boilers, options include switching to lowsulfur coal, coal cleaning, wet FGD, dry FGD, and spray dryers. The overall SO2 reductions 

vary from a low of 20 to 25 percent for fuel switching to a high of 60 to 95 percent for wet 

FGD and spray dry FGD. The majority of control strategies, however, are capable of 

achieving a 60 percent or greater reduction. Thus, assuming that coal-fired ICI boilers adopt 

varying levels of controls, with most choosing a 50- to 70- percent reduction strategy and 

fewer choosing either the 20-percent or the 90-percent reduction strategy, the region-wide 

average would be likely to fall in the vicinity of a 60- percent reduction in SO2 emissions. 
Connecticut Regional Haze Page 10-18

State Implementation Plan November 2009 

This assumption is validated by data showing that wet FGD systems represent 85 percent of 

the FGD systems in use in the United States and that these systems have an average SO2

removal efficiency of 78 percent. MANE-VU’s modeling of a 60-percent reduction in SO2

emission from coal-fired ICI boilers is therefore reasonable. 

Table 10.5: Available SO2 Control Options for ICI Boilers 

For oil-fired boilers, options include switching to a lower-sulfur fuel (e.g., oil or natural gas), 

dry FGD, and spray dryers. The overall SO2 reductions vary from a low of 40 to 60 percent 

for dry FGD to a high of 60 to 95 percent for spray dry FGD. For comparison, the MANEVU low-sulfur fuel strategy assumes a 50- to 90- percent reduction in SO2 emissions from oilfired ICI boilers. Assuming a normal distribution of control strategies chosen by the sources, 

MANE-VU’s modeling of an average 75-percent reduction in SO2 emission from oil-fired ICI 

boilers is reasonable. 

For ICI boilers in which a fuel was not specified, a 50-percent reduction in SO2 emissions was 

assumed. ICI boilers in this category include those outside the MANE-VU region for which 

the current inventory did not specify the type of fuel burned. Because a response from the 

MRPO was not received, this assumption also encompasses some of the uncertainty regarding 

the implementation of MANE-VU’s non-EGU Ask. Given the paucity of data, a lower 

reduction in SO2 emissions (50 percent) was assumed for this category than for coal- or oilTechnology Description Applicability Performance 

Flue Gas Desulfurization 

(FGD) - Dry

Powdered lime or other 

suitable sorbent is injected 

directly into flue gas

Applicable primarily for 

boilers currently firing low 

to medium sulfur fuels

40-60% reduction in SO2 

emissions

Flue Gas Desulfurization 

(FGD) - Spray Dry

A fine mist containing lime or 

other suitable sorbent is 

injected directly into flue gas

Applicable primarily for 

boilers currently firing low 

to medium sulfur fuels

60-95%+ reduction in SO2 

emissions 

Flue Gas Desulfurization 

(FGD) - Wet

SO2 is removed from flue 

gas by dissolving it in a lime 

or limestone slurry. (Other 

alkaline chemical are 

sometimes used) 

Applicable to all coal-fired 

ICI boilers

30-95%+ reduction in SO2 

emissions 

Combustion Control A reactive material, such as 

limestone or bi-carbonate, is 

introduced into the 

combustion chamber along 

with the fuel

Applicable to pulverized 

coal-fired boilers and 

circulating fluidized bed 

boilers 

40%-85% reductions in SO2 

emissions

Coal Cleaning Coal is washed to remove 

some of the sulfur and ash 

prior to combustion 

Potential control measure 

for all coal-fired ICI boilers 

20-25% reduction in SO2 

emissions

Switch to a Lower Sulfur Oil Replace higher-sulfur 

residual oil with lower-sulfur 

distillate oil. Alternatively, 

replace medium sulfur 

distillate oil with ultra-low 

sulfur distillate oil

Potential control measure 

for all oil-fired ICIs 

currently using higher 

sulfur content residual or 

distillate oils 

50-80% reduction in SO2 

emissions by switching to a 

lower-sulfur oil 

Switch to Natural Gas 

(virtually 0% sulfur)

Replace coal combustion 

with natural gas

Potential control measure 

for all coal-fired ICIs 

Virtually eliminate SO2 

emissions by switching to 

natural gas 

Switch to a Low Sulfur Coal 

(generally <1% sulfur)

Replace high-sulfur 

bituminous coal combustion 

with lower-sulfur coal

Potential control measure 

for all coal-fired ICIs 

currently using coal with 

high sulfur content 

50-80% reduction in SO2 

emissions by switching to a 

lower-sulfur coal
Connecticut Regional Haze Page 10-19

State Implementation Plan November 2009 

fired ICI boilers. Implementation of one or more of the suggested SO2 control options to 

achieve, on average, a 50-percent reduction in SO2 emissions at these sources is a reasonable 

assumption. 

For emissions from other area oil-combustion sources in the VISTAS region, an SO2 

reduction of 75 percent was assumed. This reduction is equal to the reduction that would 

result from implementing the MANE-VU low-sulfur fuel strategy for this sector. The fourfactor analysis for the low-sulfur fuel strategy was described in Subsection 10.2.3. 

Four-Factor Analysis – Non-EGU SO2 Emission Reduction Measures Outside MANE-VU: 

Based on the survey of available technologies outlined above and the four-factor analyses 

summarized below, MANE-VU concludes that each of the strategies assumed for modeling 

purposes to meet the MANE-VU Ask of a 28-percent reduction in non-EGU SO2 emissions is 

reasonable. States should have no difficulty in meeting this benchmark in light of the control 

efficiencies that are attainable at reasonable costs with retrofit technologies that are available 

for ICI boilers today. 

1) Non-EGU SO2 Emission Reduction Measures outside MANE-VU – Costs of Compliance: 

Industrial boilers have a wider range of sizes than EGUs and often operate over a wider range 

of capacities. Thus, cost estimates for the same technologies will generally span a relatively 

larger range, and costs for an individual boiler will depend on the capacity of the boiler and 

typical operating conditions. In general, cost-effectiveness increases as boiler size and 

capacity factor (a measure of boiler utilization) increases. 

MANE-VU’s Reasonable Progress Report (Attachment Y) provides emission control cost 

estimates for ICI boilers in the range of $130 to $11,000 per ton of SO2 removed, a very wide 

spread due to the variability of sources and control options in this category. All costs 

presented below for emission controls on ICI boilers are borrowed from this report. Dollar 

amounts originated from EPA publications cited in the report and are restated in 2006 dollars 

using appropriate adjustment factors found at www.inflationdata.com. 

◊ Cost of Fuel Switching: Although fuel switching can be a very effective means of 

controlling SO2 emissions (reductions of 50 to 99.9 percent are possible), burning low-sulfur 

fuel may not be technically feasible or economically practical as an SO2 control option for 

every ICI coal-fired boiler. Factors impacting applicability include the characteristics of the 

plant and the particular type of fuel change being considered. Additionally, switching to a 

lower-sulfur coal can affect fuel handling systems, boiler performance, PM control 

effectiveness, and ash handling systems. Oil-fired boilers switching to a lower-sulfur fuel of 

the same grade (e.g., switching from #6 fuel oil at 2.0% S to #6 fuel oil at 0.5% S) do not 

typically encounter these issues. (See Subsection 10.2.3 for a discussion of the costs and 

issues associated with switching to low-sulfur fuel oil.) 

The costs of coal fuel switching, including substitution or blending with a low-sulfur coal, can 

be attributed to two main factors: the cost of low-sulfur coal compared to higher-sulfur coal 

(including consideration of the coal’s heating value), and the cost of necessary boiler or coalhandling equipment modifications. Many plants will be able to switch from high-sulfur to 

low-sulfur bituminous coal without serious difficulty, but switching from bituminous to 

subbituminous coal may require potentially significant investments and modifications to an 

existing plant. Even if a lower-sulfur fuel is available, it may not be cost competitive if it 
Connecticut Regional Haze Page 10-20

State Implementation Plan November 2009 

must be supplied in small quantities or transported long distances from the supplier. It also 

may be more cost-effective to burn a higher-sulfur fuel supplied by nearby suppliers and to 

use a post-combustion control device. 

Switching from coal combustion to natural gas combustion virtually eliminates SO2

emissions. It is technically feasible to switch from coal to natural gas, but it is currently 

uneconomical to consider this option for large ICI boilers because of the fuel quantity 

necessary and the price of natural gas. Natural gas is roughly seven times the price of coal in 

terms of heating value (price per million Btus). 

◊ Cost of Coal Cleaning: The World Bank, an organization which assists with economic and 

technological needs in developing countries, reports that the cost of physically cleaning coal 

varies from $1 to $10 per ton of coal cleaned, depending on the coal quality, the cleaning 

process used, and the degree of cleaning desired. In most cases, the costs were found to be 

between $1 and $5 per ton of coal cleaned. Coal cleaning typically results in a 20- to 25-

percent reduction in SO2 emissions and increases the heating value of the fuel by a small 

amount. 

◊ Cost of Combustion Controls: Dry sorbent injection (DSI) systems have lower capital and 

operation costs than post-combustion FGD systems because of the simplicity of the DSI 

design, lower water use needs, and smaller land area requirements. Table 10.6 presents the 

estimated costs of adding DSI-based SO2 emission controls to ICI boilers for different boiler 

sizes, fuel types, and capacity factors. 

Table 10.6: Estimated Costs of Dry Sorbent Injection (DSI) for ICI Boilers (2006 dollars) 

Fuel 

SO2

Reduction 

(%) 

Capacity 

Factor 

(%) 

Cost-Effectiveness ($/ton of SO2 removed) 

100 

MMBtu/hr 

250 

MMBTU/hr 

1,000 

MMBTU/hr 

2%-Sulfur Coal 40 

14 4,686 3,793 2,979 

50 1,312 1,062 834 

83 772 624 490 

3.43%-Sulfur Coal 40 

14 2,732 2,212 1,737 

50 765 619 486 

83 450 364 286 

2%-Sulfur Coal 85 

14 2,205 1,786 1,402 

50 617 500 392 

83 363 294 231 

3.43%-Sulfur Coal 40 

14 1,286 1,040 818 

50 360 291 229 

83 212 171 134 

◊ Cost of FGD: Installation of post-combustion SO2 controls in the form of FGD has several 

impacts on facility operations, maintenance, and waste handling procedures. FGD systems 

generally require substantial land area for construction of the absorber towers, sorbent tanks, 

and waste handling equipment. The facility costs therefore depend on the cost and 

availability of space for construction of the FGD system. In addition, significant quantities of 

waste material may be generated that require disposal. The costs may be mitigated, however, 

by utilization of a forced oxidation FGD process that produces commercial-grade gypsum, 

which may be sold as a raw material for other commercial processes. 
Connecticut Regional Haze Page 10-21

State Implementation Plan November 2009 

Table 10.7 presents the total estimated cost-per-ton of adding FGD-based SO2 emission 

controls to ICI boilers for different boiler sizes, fuel types, and capacity factors. There is no 

indication that these cost data include possible revenues from gypsum sales, which would 

partially offset the costs of FGD controls. 

Carbon dioxide is also emitted as a byproduct of FGD; therefore, the impacts of increased 

carbon emissions associated with this technology would need to be considered. CO2 emissions 

will become more of an issue in the future if they are limited under climate change mitigation 

strategies. Given the uncertainty of such future strategies, costs related to increased carbon 

emissions from FGD cannot yet be assessed. 

MANE-VU’s request for a 28-percent reduction in non-EGU SO2 emissions allows states 

flexibility in determining which sources to control, so that the most cost-effective control 

measures can be adopted and implemented over the next 10 years. Given the wide range of 

control options and costs available for this purpose, MANE-VU has concluded that the 

request for a 28-percent reduction in non-EGU SO2 emissions is reasonable. Connecticut 

concurs with this conclusion. 

Table 10.7: Estimated Costs of Flue Gas Desulfurization for ICI Boilers (2006 dollars) 

Fuel Technology 

SO2

Reduction 

(%) 

Capacity 

Factor 

(%) 

Cost-Effectiveness ($/ton of SO2 removed) 

100 

MMBtu/hr 

250 

MMBTU/hr 

1,000 

MMBTU/hr 

High-Sulfur 

Coal FGD (dry) 40 

14 3,781 2,637 1,817 

50 1,379 1,059 828 

83 1,006 814 676 

LowerSulfur Coal FGD (dry) 40 

14 4,571 3,150 2,119 

50 1,605 1,207 928 

83 1,147 906 744 

Coal FGD 

(spray dry) 85 

14 4,183 2,786 1,601 

50 1,290 899 567 

83 843 607 407 

High-Sulfur 

Coal 

FGD 

(spray dry) 85 

14 3,642 2,890 1,909 

50 1,116 875 601 

83 709 563 398 

LowerSulfur Coal FGD (wet) 40 

14 4,797 3,693 2,426 

50 1,415 1,106 751 

83 892 705 492 

Oil FGD (wet) 40 

14 10,843 8,325 5,424 

50 2,269 1,765 1,184 

83 1,371 1,079 740 

2) Non-EGU SO2 Emission Reduction Measures outside MANE-VU – Time Necessary for 

Compliance: For pre- and post-combustion SO2 emission controls, engineering and 

construction lead times will vary between 2 and 5 years, depending on the size of the facility 

and specific control technology selected. Generally, sources are given a 2- to 4- year phase-in 

period to comply with new rules, as previously described, and states generally have a 2-year 

period for compliance with RACT rules. 
Connecticut Regional Haze Page 10-22

State Implementation Plan November 2009 

For the purposes of this review, it is assumed that a 2-year period after SIP submittal is 

adequate for pre-combustion controls (fuel switching or cleaning), and a 3-year period is 

adequate for the installation of post-combustion controls. MANE-VU has therefore 

concluded that there is sufficient time between 2008 and 2018 for affected states to adopt 

emission control requirements and for affected sources to install the necessary controls to 

meet MANE-VU’s requested SO2 emission reductions from non-EGU sources. Connecticut 

concurs with this conclusion. 

3) Non-EGU SO2 Emission Reduction Measures Outside MANE-VU – Energy and Non-Air 

Quality Environmental Impacts of Compliance: The primary energy impact of pre- or postcombustion control alternatives is a potential increase in electricity usage. Fuel switching and 

cleaning do not significantly affect the efficiency of the boiler itself, but require additional 

energy to clean or blend coal. FGD systems typically operate with high-pressure drops across 

the control equipment and therefore consume significant amounts of electricity to operate 

blowers and circulation pumps. In addition, some combinations of FGD technology and plant 

configuration may require flue gas reheating to prevent physical damage to equipment, 

resulting in higher fuel usage. 

The primary non-air environmental impacts of fuel switching derive from transportation of 

the fuel. Secondary environmental impacts derive from waste disposal and material handling 

operations (e.g. fugitive dust). For FGD systems, the generation of wastewater and sludge 

from the SO2 removal process is a consideration. Wastewater from the FGD systems will 

increase sulfate, metals, and solids loading at the receiving wastewater treatment facility, 

resulting in potential impacts to operating cost, energy requirements, and effluent water 

quality. Processing of the wastewater sludge can require energy for stabilization and/or 

dewatering, and transporting the dewatered sludge to a landfill has additional environmental 

implications. 

Fuel switching to a low-sulfur distillate fuel oil has a variety of beneficial consequences for 

ICI boilers. Low-sulfur distillate fuel is cleaner burning and emits less particulate matter, 

which reduces the rate of fouling of heating units substantially and permits longer time 

intervals between cleanings. According to a study conducted by NYSERDA (reference 10 in 

Attachment AA), boiler deposits are reduced by a factor of two by lowering the fuel sulfur 

content from 1,400 ppm to 500 ppm. These reductions in buildup of deposits result in longer 

service intervals between cleanings. 

Reducing SO2 emissions from ICI boilers would have positive environmental and health 

impacts. SO2 controls would reduce acid deposition, helping to preserve aquatic life, forests, 

and crops as well as buildings and sculptures made of acid-sensitive materials. These 

emission reductions would also help to decrease ambient levels of PM2.5, a significant 

contributor to premature morbidity and illness in individuals with heart or lung conditions. 

MANE-VU has concluded that the energy and non-air environmental impacts of controlling 

SO2 emissions from ICI boilers are justified in light of the beneficial impacts on regional haze, 

fine particulate air pollution, acid rain, and equipment operation, as described above. 

Connecticut concurs with this conclusion. 
Connecticut Regional Haze Page 10-23

State Implementation Plan November 2009 

4) Non-EGU SO2 Emission Reduction Measures Outside MANE-VU – Remaining Useful Life 

of Any Potentially Affected Sources: Available information for remaining useful life estimates 

of ICI boilers indicates a wide range of life expectancies, depending on unit size, capacity 

factor, and level of maintenance performed. Typical life spans range from about 10 years to 

over 30 years. However, the remaining useful life of a specific source is highly variable; and 

older units are not likely to be retrofitted with expensive emission controls. Given the typical 

range of life expectancies of ICI boilers, the technical options available, and the flexibility 

that non-MANE-VU states would have to meet the Ask, MANE-VU has concluded that a 28-

percent reduction in non-EGU SO2 emissions is reasonable. Connecticut concurs with this 

conclusion. 

10.3 Visibility Effects of (Additional) Reasonable Control Measures 

MANE-VU’s evaluations included modeling to estimate the effects on visibility of the 

MANE-VU Ask. The results of this work are summarized below. 

NESCAUM performed preliminary modeling as described in the report entitled “MANE-VU 

Modeling for Reasonable Progress Goals, Model Performance Evaluation, Pollution 

Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment G). 

NESCAUM also conducted more recent, revised modeling to assess the effects of all haze 

reduction strategies combined. The latter modeling is described in NESCAUM’s “2018 

Visibility Projections,” May 13, 2008 (Attachment Q). 

The NESCAUM modeling demonstrates that significant visibility benefits will accrue from 

implementation of the additional reasonable control measures described in Subsection 10.2, 

above. Figures 10.4 and 10.5 describe the results of this modeling. In the first of the two 

figures, the light yellow bars represent expected visibility at MANE-VU Class I Areas in 

2018. Comparison of these values with the 2018 “glide slope” values (the plum-colored 

second bars from the left) shows that all areas are expected to experience visibility 

improvements that meet or exceed the uniform rate of progress calculated for each area. The 

second figure shows that, for the 20 percent of days having best visibility, expected visibility 

in 2018 will be better than it is today at all locations. 

In conclusion, the reasonable progress goals for Class I areas proposed by the MANE-VU 

states are found to be consistent with the stated national goals of preventing further visibility 

degradation while making timely progress toward achieving natural visibility conditions in 

Class I areas by 2064. 
Connecticut Regional Haze Page 10-24

State Implementation Plan November 2009 

Figure 10.4: Demonstration of Required and Reasonable Visibility Progress 

for 20 Percent Worst Visibility Days 

Visibility Progress for 20% Worst Days 

0

5

10

15

20

25

30

35

Acadia Brigantine Great Gulf Lye Brook Moosehorn

Visibility (deciviews)

2002 Baseline 2018 Glideslope 2018 Projected Progress Natural

(Visibility Improvements Must be Made at Reasonable Rate)

Figure 10.5: Demonstration of Required Maintenance or Improvement of Visibility for 

20 Percent Best Visibility Days 

Visibility Progress For 20% Best Days

0

2

4

6

8

10

12

14

16

Acadia Brigantine Great Gulf Lye Brook Moosehorn

Visibility (deciviews)

2002 Baseline 2018 Projected Progress

(Baseline Visibility Must be Maintained or Improved)

References 

U.S. Environmental Protection Agency, National Emission Standards for Hazardous Air 

Pollutants for Industrial/ Commercial/Institutional Boilers and Process Heaters, http://cascade.epa.gov/RightSite/dk_public_collection_detail.htm?ObjectType=dk_docket_collection&cid=OAR-2002-

0058&ShowList=items&Action=view (Accessed Feb. 25, 2004)
Connecticut Regional Haze Page 11-1 

State Implementation Plan November 2009 

11.0 LONG-TERM STRATEGY 

40 CFR 51.308(d)(3) of the Regional Haze Rule requires the State of Connecticut to submit a 

long-term strategy that addresses regional haze visibility impairment for all mandatory Class I 

federal areas outside the state that may be affected by emissions from within the state. 

Affected areas include the seven designated Class 1 areas within the MANE-VU region: Great 

Gulf Wilderness, Presidential Range - Dry River Wilderness, Acadia National Park, 

Moosehorn Wilderness, Roosevelt Campobello International Park, Lye Brook Wilderness, 

and Brigantine Wilderness. As presented in Section 3.0, Regional Planning and Consultation, 

Connecticut consulted with other states to develop the coordinated emission management 

strategies contained in this SIP. The following describes how Connecticut meets the long-term 

strategy requirements of the Regional Haze Rule. 

Connecticut’s long-term strategy includes enforceable emission limitations, compliance 

schedules, and other measures necessary to achieve the reasonable progress goals described in 

Section 10.0. Additional measures may be reasonable to adopt at a later date after further 

consideration and review. In developing this long-term strategy, Connecticut also considered 

the requirements of the Clean Air Act, Section 110 (a)(2)(D)(i)(II), pertaining to interstate and 

international transport of pollutants. CTDEP has previously addressed this issue in 

Connecticut’s “Transport SIP Revision,” submitted to EPA on March 13, 2007. As that 

document observed, states must include provisions in their implementation plans to prohibit 

any source or activity from emitting air pollutants in amounts that would interfere with 

another state’s ability to prevent significant deterioration of air quality and visibility. The 

long-term strategy presented herein is designed to protect visibility in Connecticut as well as 

areas downwind from Connecticut. 

11.1 Overview of Strategy Development Process 

The regional strategy development process identified reasonable measures that would reduce 

emissions contributing to visibility impairment at Class I areas by 2018 or earlier. The 

process of identifying potential emission reduction measures and the technical basis for the 

long-term strategy are discussed in this section. As a MANE-VU member and participant, 

Connecticut supported several technical analyses undertaken to assist the MANE-VU states in 

deciding which regional haze control measures to pursue. These analyses are documented in 

the following reports: 

• NESCAUM, “Contributions to Regional Haze in the Northeast and Mid-Atlantic 

United States,” August 2006, otherwise known as the Contribution Assessment 

(Attachment B). 

• ICF Resources, L.L.C., “Comparison of CAIR and CAIR Plus Proposal Using the 

Integrated Planning Model®,” Final Draft Report, May 30, 2007, otherwise known as 

the CAIR Plus Report (Attachment BB); 

• MACTEC Federal Programs, Inc., “Assessment of Reasonable Progress for Regional 

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

Reasonable Progress Report (Attachment Y);
Connecticut Regional Haze Page 11-2 

State Implementation Plan November 2009 

• NESCAUM, “Five-Factor Analysis of BART-Eligible Sources: Survey of Options for 

Conducting BART Determinations,” June 1, 2007 (Attachment W); and 

• NESCAUM, “Assessment of Control Technology Options for BART-Eligible 

Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp 

Facilities,” March 2005, otherwise known as the BART Report (Attachment Z). 

MANE-VU reviewed a wide range of potential control measures aimed at reducing regional 

haze by the 2018 milestone. The process of choosing a set of control measures started in late 

2005. OTC selected a contracting firm to assist with the analysis of ozone and regional haze 

control measure options and provided the contractor with a master list of some 900 potential 

control measures based on experience and previous state implementation plan work. With the 

help of an internal OTC Control Measures Workgroup, the contractor narrowed the list of 

regional haze control measures for further consideration by MANE-VU. 

MANE-VU then developed an interim short list of possible control measures for regional 

haze. The identified control measures can be divided into three general categories: 

• Beyond-CAIR sulfate reductions and related control measures targeted at specific 

EGUs in the eastern United States, 

• Low-sulfur heating oil for ICI boilers and residential sources (i.e., boilers and 

furnaces), and 

• Emission controls on ICI boilers (both coal- and oil-fired); lime and cement kilns; 

residential wood stoves; and outdoor burning (including outdoor wood boilers). 

The next step was to further refine this list, with the aid of several of the reports named above. 

The CAIR Plus Report documents MANE-VU’s assessment of the costs of CAIR and 

provides a cost analysis for additional SO2 and NOX controls at sources in the eastern United 

States. The Reasonable Progress Report documents the assessment of control measures for 

EGUs and the other source categories selected for analysis. Further analysis is provided in 

the second of the two NESCAUM documents referenced above pertaining to BART controls.

The beyond-CAIR strategy for EGUs rose to the top of the list because the Contribution 

Assessment showed that EGU sulfate emissions have, by far, the largest impact on visibility 

in the MANE-VU Class I Areas. Similarly, a low-sulfur oil strategy gained traction after a 

NESCAUM-initiated conference with refiners and fuel-oil suppliers concluded that such a 

strategy could realistically be implemented within the next 10 years. Thus, the low-sulfur 

heating oil option for the residential and commercial sectors and the control measures option 

for the oil-fired ICI boiler sector merged into an overall strategy requiring the use of lowsulfur oil. Under this strategy, low-sulfur oil would be required for all residential and 

commercial heating units and all ICI boilers burning #2, #4, or #6 fuel oils. 

During MANE-VU’s internal consultation meeting in March 2007, member states reviewed 

the interim list of control measures to make additional refinements. States determined, for 

example, that there may be too few coal-fired ICI boilers in MANE-VU for these sources to 

be included in a regional strategy, but that they could be covered in programs adopted by 

individual states. The member states also decided that lime and cement kilns, of which there 

are few in the MANE-VU region, are most likely to be handled via the BART determination
Connecticut Regional Haze Page 11-3 

State Implementation Plan November 2009 

process. Residential wood burning and outdoor wood boilers remained on the list for those 

states where localized visibility impacts are a consideration even though emissions from these 

sources are primarily organic carbon and direct particulate matter. Finally, it was decided that 

the issue of outdoor wood burning should be examined further on a state-by-state basis 

because of concerns related to enforcement and penetration of existing state regulations. 

Connecticut currently regulates outdoor word burning through statute at CGS 22a-174(f) and 

regulation at RCSA 22a-174-17. 

11.2 Technical Basis for Strategy Development 

40 CFR 51.308(d)(3)(iii) requires Connecticut to document the technical basis for the state’s 

apportionment of emission reductions necessary to meet reasonable progress goals in each 

Class I area affected by Connecticut’s emissions. Connecticut relied on technical analyses 

developed by MANE-VU to demonstrate that Connecticut’s emission reductions, when 

coordinated with those of other states and tribes, are sufficient to achieve reasonable progress 

goals in Class I areas affected by emissions originating in Connecticut. 

The emission reductions necessary to meet reasonable progress goals in Class I areas affected 

by Connecticut are described in the following documents: 

• NESCAUM, “Baseline and Natural Background Visibility Conditions: Considerations 

and Proposed Approach to the Calculation of Baseline and Natural Background 

Visibility Conditions at MANE-VU Class I Areas,” December 2006 (Attachment L); 

• NESCAUM, “The Nature of the Fine Particle and Regional Haze Air Quality 

Problems in the MANE-VU Region: A Conceptual Description,” Final, November 2, 

2006 (Attachment CC); 

• NESCAUM, “Contributions to Regional Haze in the Northeast and Mid-Atlantic 

United States,” August 2006, otherwise known as the Contribution Assessment 

(Attachment B). 

• ICF Resources, L.L.C., “Comparison of CAIR and CAIR Plus Proposal Using the 

Integrated Planning Model®,” Final Draft Report, May 30, 2007, otherwise known as 

the CAIR Plus Report (Attachment BB); 

• MACTEC Federal Programs, Inc., “Assessment of Reasonable Progress for Regional 

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

Reasonable Progress Report (Attachment Y); 

• NESCAUM, “Five-Factor Analysis of BART-Eligible Sources: Survey of Options for 

Conducting BART Determinations,” June 1, 2007 (Attachment W); 

• NESCAUM, “Assessment of Control Technology Options for BART-Eligible 

Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp 

Facilities,” March 2005, otherwise known as the BART Report (Attachment Z); 

• NESCAUM, “MANE-VU Modeling for Reasonable Progress Goals: Model Performance 

Evaluation, Pollution Apportionment, and Control Measure Benefits,” February 7, 2008 

(Attachment G); and 

• NESCAUM, “2018 Visibility Projections,” May 13, 2008 (Attachment Q).
Connecticut Regional Haze Page 11-4 

State Implementation Plan November 2009 

As described in Attachment G, the “beyond on the way” scenario – defined by CAIR with 

other “on the books” measures and the limitation of fuel sulfur content to 500 ppm for all No. 

2 “distillate” fuel oil sold in the MANE-VU region – is sufficient to achieve visibility 

improvement beyond the so-called “uniform rate of progress” defined by uniform visibility 

improvement between now and 2064, the planning horizon for the regional haze program. 

However, it should be noted that USEPA guidance for setting reasonable progress goals asks 

states to consider reviewing all measures identified through the four factor analysis process 

(see Section 10.2.1) and to adopt each measure that is determined to be reasonable. 

As described in Subsection 11.1, above, Connecticut worked with other members of the 

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

emission reduction strategies covering a wide range of sources of SO2 and other pollutants 

contributing to regional haze. 40 CFR 51.308(d)(3)(v) requires states to consider several 

factors in developing their long-term strategies. Operating within this framework and using 

available information about emissions and potential impacts, the MANE-VU Reasonable 

Progress Workgroup selected the following source categories for detailed analysis: 

• Coal and oil-fired EGUs) 

• Point and area source ICI boilers; 

• Cement kilns and lime kilns; 

• Sources capable of using low-sulfur heating oil; and 

• Residential wood combustion and open burning. 

These efforts led to the selection of the emission reduction strategies presented in this SIP. 

11.3 Existing Commitments to Reduce Emissions 

40 CFR Section 51.308(d)(3)(v)(A) requires Connecticut to consider emission reductions 

from ongoing pollution control programs. In developing its long-term strategy, Connecticut 

considered air pollution programs being implemented between the 2002 baseline year and 

2018. The emission reduction programs described in Subsections 11.3.1, 11.3.2, and 11.3.3 

below represent commitments already made by Connecticut and other states to implement air 

pollution control measures for EGU point sources, non-EGU point sources, and area sources, 

respectively. These control measures are the very same measures that were included in the 

2018 emissions inventory and used in the modeling. While these control measures were not 

designed expressly for the purpose of improving visibility, the pollutants they control include 

those that contribute to visibility impairment in MANE-VU Class I Areas. 

MANE-VU’s 2018 beyond-on-the-way (BOTW) emissions inventory accounts for emission 

controls already in place as well as emission controls that are not yet finalized but are likely to 

achieve additional emission reductions by 2018. The BOTW inventory was developed based 

on the MANE-VU 2002 Version 3.0 inventory and the MANE-VU 2018 on-the-books/on-theway (OTB/OTW) inventory. Inventories used for other RPOs reflect anticipated emissions 

controls that will be in place by 2018. The inventory is termed BOTW because it includes 

control measures that were developed for ozone SIPs that were not yet on the books in some 

states. For some states, BOTW also included controls that were under consideration for 

regional haze SIPs that have not yet been adopted. More information may be found in the 

following documents: 
Connecticut Regional Haze Page 11-5 

State Implementation Plan November 2009 

• MACTEC Federal Programs, Inc., “Development of Emissions Projections for 2009, 

2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU 

Region,” Final Report, February 28, 2007, otherwise known as the Emission 

Projections Report (Attachment N); 

• Alpine Geophysics, LLC, “Documentation of 2018 Emissions from Electric 

Generating Units in the Eastern United States for MANE-VU’s Regional Haze 

Modeling, Final Report, August 16, 2009 (Attachment H); 

• NESCAUM, “MANE-VU Modeling for Reasonable Progress Goals: Model 

Performance Evaluation, Pollution Apportionment, and Control Measure Benefits,” 

February 7, 2008 (Attachment G); and 

• NESCAUM, “2018 Visibility Projections,” May 13, 2008 (Attachment Q). 

11.3.1 Controls on EGUs Expected by 2018 

The following EGU emission reduction programs were included in the modeling used to 

develop the reasonable progress goals. These programs represent the greatest opportunities 

for reducing SO2 emissions at Class I areas in the MANE-VU region and serve as the starting 

point for MANE-VU’s long-term strategy to mitigate regional haze. 

Clean Air Interstate Rule (CAIR): This major federal rule has been remanded to EPA to 

correct deficiencies. The original CAIR imposed permanent caps on sulfur dioxide (SO2) and 

nitrogen oxides (NOX) in the eastern United States by 2015. When fully effective, this 

program was expected to reduce SO2 emissions in the CAIR region by up to 70 percent. 

While the first phase of CAIR begins in 2009, it is unknown when EPA will issue a revised 

CAIR rule in response to the remand and what level of reductions will be required. To predict 

future emissions from EGUs after implementation of CAIR, MANE-VU used the Integrated 

Planning Model (IPM)17. Adjustments to the IPM output were made to provide a more 

accurate representation of anticipated controls at specific EGU sources as documented in the 

Alpine Geophysics report listed above. In making these adjustments, emission controls 

originating from the following state and regional programs were considered: 

Connecticut EGU Regulations: Connecticut adopted the following regulations governing 

EGU emissions: 

 

• Regulations of Connecticut State Agencies (RCSA), section 22a-174-19a, limiting the 

SO2 emission rate to 0.33 lb/MMBtu for fossil-fuel-fired EGUs 15 MW and greater 

that are also Title IV sources (effective, 2003). 

 

17 The IPM model runs also anticipated the implementation of EPA’s Clean Air Mercury Rule (CAMR), which was recently 

vacated by the courts. However, MANE-VU believes that the adjustments made to the predicted SO2 emissions from 

EGUs will have a larger effect on the air quality modeling analysis conducted for this SIP than will the vacatur of the 

CAMR rule. The emission adjustments were based on states’ comments on the actual levels of SO2 controls expected to be 

installed in response to state-specific regulations and EPA’s CAIR rule. MANE-VU believes these adjustments improve 

the reliability of both the emissions inventory and modeling results. 
Connecticut Regional Haze Page 11-6 

State Implementation Plan November 2009 

• RCSA, section 22a-174-22, limiting the non-ozone seasonal NOX emission rate to 0.15 

lb/MMBtu for fossil-fuel-fired EGUs 15 MW and greater that are also NOx Budget 

Program sources (effective, October 2003). 

• Connecticut General Statutes, section 22a-199, limiting the mercury (Hg) emission 

rate to 0.0000006 lb/MMBtu for all coal-fired EGUs or alternatively coal-fired EGUs 

can meet a 90% Hg emission reduction (effective, July 2008). 

Delaware EGU Regulations: Delaware adopted the following regulations governing EGU 

emissions: 

• Reg. 1144, Control of Stationary Generator Emissions, requiring emission controls for 

SO2, PM, VOC, and NOX state-wide, effective January 2006. 

• Reg. 1146, Electric Generating Unit (EGU) Multi-Pollutant Regulation, requiring SO2

and NOX emission controls state-wide, effective December 2007. SO2 reductions will 

be more than regulation specifies. 

• Reg. 1148, Control of Stationary Combustion Turbine Electric Generating Unit 

Emissions, requiring SO2, NOX, and PM2.5 emission controls state-wide, effective 

January 2007. 

Delaware estimates that these regulations will result in the following emission reductions for 

affected units: SO2 emissions of 32,630 tons in 2002 will decline to 8,137 tons in 2018 (a 75-

percent reduction); NOX emissions of 8,735tons in 2002 will decline to 3,740 tons in 2018 (a 

57-percent reduction). 

Also, Delaware anticipates the following reductions resulting from the consent decree with 

Valero Refinery Delaware City, DE (formerly Motiva, Valero Enterprises): SO2 emissions of 

29,747 tons in 2002 will decline to 608 tons in 2018 (a 98-percent reduction); NOX emissions 

in 1,022 in 2002 will decline to 102 tons in 2018 (a 90-percent reduction). 

Maine EGU Regulations: Chapter 145, NOX Control Program, limits the NOX emission rate 

to 0.22 lb/MMBtu for fossil-fuel-fired units greater than 25 MW built before 1995 with a heat 

input capacity between 250 and 750 MMBtu/hr, and also limits the NOX emission rate to 0.15 

lb/MMBtu for fossil-fuel-fired units greater than 25 MW built before 1995 with a heat input 

capacity greater than 750 MMBtu/hr (effective, 2007). 

Massachusetts EGU Regulations: Based on the Massachusetts Department of Environmental 

Protection’s 310 CMR 7.29, Emissions Standards for Power Plants, adopted in 2001, six of 

the largest fossil-fuel-fired power plants in Massachusetts must comply with emissions 

limitations for NOX, SO2, Hg, and CO2. These regulations will achieve an approximately 50-

percent reduction in NOX emissions and a 50- to 75-percent reduction in SO2 emissions. 

Depending on the compliance paths selected, the affected facilities will meet the output-based 

NOX and SO2 standards between 2004 and 2008. This regulation also limits the six 

grandfathered EGUs to a CO2 emission rate of 1,800 lb/MWh. 

New Hampshire EGU Regulations: New Hampshire adopted the following regulations 

governing EGU emissions: 
Connecticut Regional Haze Page 11-7 

State Implementation Plan November 2009 

• Chapter Env-A 2900, Multiple Pollutant Annual Budget Trading and Banking 

Program, capping NOX emissions at 3,644 tons per year, SO2 emissions at 7,289 tons 

per year, and CO2 emissions at 5,425,866 tons CO2 per year for all existing fossil-fuel 

fired steam units by December 31, 2006. 

• Chapter Env-A 3200, NOX Budget Trading Program, limiting ozone season NOX

emissions on all fossil-fuel-fired EGUs greater than 15 MW to 0.15 lb/MMBtu, 

effective November 2, 2007. 

New Jersey New Source Review Settlement Agreements: The New Jersey settlement 

agreement with PSEG required the following actions for specific EGUs: 

• Bergen Unit #2: Repower to combined cycle by December 31, 2002. 

• Hudson Unit #2: Install dry FGD or approved alternative technology by Dec. 31, 

2006, to control SO2 emissions and operate the control technology at all times the unit 

operates to limit SO2 emissions to 0.15 lb/MMBtu; install SCR or approved alternative 

technology by May 1, 2007, to control NOX emissions and operate the control 

technology year-round to limit NOX emissions to 0.1 lb/MMBtu; and install a 

baghouse or approved alternative technology by May 1, 2007, to control and limit PM 

emissions to 0.015 lb PM/MMBtu. 

• Mercer Unit #1: Install dry FGD or approved alternative technology by Dec. 31, 

2010, to control SO2 emissions and operate the control technology at all times the unit 

operates to limit SO2 emissions to 0.15 lb/MMBtu; and install SCR or approved 

alternative technology by 2005 to control NOX emissions and operate the control 

technology during ozone season only in 2005 and year-round by May 1, 2006, to limit 

NOX emissions to 0.13 lb/MMBtu. 

• Mercer Unit #2: Install dry FGD or approved alternative technology by Dec. 31, 

2012, to control SO2 emissions and operate the control technology at all times the unit 

operates to limit SO2 emissions to 0.15 lb/MMBtu; and install SCR or approved 

alternative technology by 2004 to control NOX emissions and operate the control 

technology during ozone season only in 2004 and year-round by May 1, 2006, to limit 

NOX emissions to 0.13 lb/MMBtu. 

The New Jersey settlement also requires that units operating an FGD use coal having a 

monthly average sulfur content no greater than 2 percent.

New York EGU Regulations: New York adopted the following regulations governing EGU 

emissions: 

• Title 6 NYCRR Parts 237, Acid Deposition Reduction NOX Budget Trading Program, 

limits NOX emissions on all fossil-fuel-fired EGUs greater than 25 MW to a nonozone season cap of 39,908 tons in 2007. 

• Title 6 NYCRR Parts 238, Acid Deposition Reduction SO2 Budget Trading Program, 

limits SO2 emissions from all fossil-fuel-fired EGUs greater than 25 MW to an annual 

cap of 197,046 tons per year starting in 2007 and an annual cap of 131,364 tons per 

year starting in 2008. 

North Carolina Clean Smokestacks Act: Enacted in 2002, this legislation requires that coal-
Connecticut Regional Haze Page 11-8 

State Implementation Plan November 2009 

fired EGUs achieve a 77-percent cut in NOX emissions by 2009 and a 73-percent cut in sulfur 

dioxide SO2 emissions by 2013. This act also established annual caps on both SO2 and NOX

emissions for the two primary utility companies in North Carolina, Duke Energy and Progress 

Energy. These reductions must be made in North Carolina, and allowances are not saleable. 

Consent Agreements in the VISTAS region: The effects of the following consent agreements 

in the VISTAS states were reflected in the emissions inventories used for those states: 

• Santee Cooper: A 2004 consent agreement calls for Santee Cooper in South Carolina to 

install and commence operation of continuous emission control equipment for 

PM/SO2/NOX emissions; comply with system-wide annual PM/SO2/NOX emissions 

limits; agree not to buy, sell, or trade SO2/NOX allowances allocated to Santee Cooper 

System as a result of this agreement; and to comply with emission unit limits of this 

agreement. 

• TECO: Under a settlement agreement, by 2008, Tampa Electric in the state of Florida 

will install permanent emission control equipment to meet stringent pollution limits; 

implement a series of interim pollution reduction measures to reduce emissions while 

the permanent controls are designed and installed; and retire pollution emission 

allowances that Tampa Electric or others could use, or sell to others, to emit additional 

NOX, SO2, and PM.

• VEPCO: Virginia Electric and Power Co. agreed to spend $1.2 billion by 2013 to 

eliminate 237,000 tons of SO2 and NOX emissions each year from eight coal-fired 

electricity generating plants in Virginia and West Virginia. 

• Gulf Power 7: A 2002 agreement calls for Gulf Power to upgrade its operation to cut 

NOX emission rates by 61 percent at its Crist 7 generating plant by 2007 with major 

reductions beginning in early 2005. The Crist plant is a significant source of NOX

emissions in the Pensacola, Florida, area. 

11.3.2 Controls on Non-EGU Point Sources Expected by 2018 

For non-EGU sources within MANE-VU, Connecticut relied on MANE-VU’s Version 3.0 

Emission Inventory for 2002. MACTEC conducted an analysis of various control measures 

as documented in the Emission Projections Report (Attachment N). Control factors were 

applied to the 2018 MANE-VU inventory for non-EGUs to represent the following national, 

regional, or state control measures: 

• NOX SIP Call Phase I (NOX Budget Trading Program) (except ME, NH, VT); 

• NOX SIP Call Phase II (except ME, NH, VT); 

• NOX RACT in 1-hour Ozone SIPs (already included in the 2002 inventory); 

• NOX OTC 2001 Model Rule for ICI Boilers; 

• 2-, 4-, 7-, and 10-year MACT Standards; 

• Combustion Turbine and RICE MACT (NOX co-benefits were not included and 

assumed to be small);
Connecticut Regional Haze Page 11-9 

State Implementation Plan November 2009 

• Industrial Boiler/Process Heater MACT18; and 

• Refinery Enforcement Initiative (Fluid catalytic cracking units and fluid coking units, 

process heaters and boilers, flare gas recovery, leak detection and repair, and benzene 

(wastewater)). 

In addition, states provided control measure information about specific non-EGU sources or 

regulatory programs in their states. MANE-VU used the state-specific data to the extent it 

was available. For example, several states developed additional control measures in the 

course of their planning efforts to reduce ozone within the Ozone Transport Region (OTR). 

These control measures were included by MANE-VU in the inventories used for regional 

haze modeling. (The affected states may or may not have committed to adopting these 

measures in their ozone SIPs.) For specific states, the ozone-reduction strategies included in 

the modeling would reduce NOX emissions from the following non-EGU point sources: 

• Asphalt production plants in Connecticut, New Jersey, New York, and the District of 

Columbia; 

• Cement kilns in Maine, Maryland, New York, and Pennsylvania; and 

• Glass and fiberglass furnaces in Maryland, Massachusetts, New Jersey, New York, 

and Pennsylvania. 

For other regions, MANE-VU used emission inventory data developed by the RPOs for those 

regions, including VISTAS’s Base G2, MRPO’s Base K, and CenRAP’s emissions inventory. 

Non-EGU source controls incorporated into the modeling include those required under the 

following consent agreements as reflected in the VISTAS inventory: 

• Dupont: A 2007 agreement calls for E. I. Dupont Nemours & Co.’s James River plant 

to install dual absorption pollution control equipment by September 1, 2009, resulting 

in SO2 emission reductions of approximately 1,000 tons annually. The James River 

plant is a non-EGU located in the state of Virginia. 

• Stone Container: A 2004 agreement calls for the West Point Paper Mill in Virginia 

owned by Smurfit/Stone Container to control SO2 emissions from its #8 Power Boiler 

by using a wet scrubber. This control device should result in reductions of over 3,500 

tons of SO2 in 2018. 

11.3.3 Controls on Area Sources Expected by 2018 

For area sources within MANE-VU, Connecticut relied on MANE-VU’s Version 3.0 

Emissions Inventory for the 2002 base year. In general, MANE-VU developed the 2018 

inventory for area sources by applying growth and control factors to the 2002 Version 3.0 

inventory. Area source control factors were developed and incorporated in the modeling for 

the following national or regional control measures: 

 

18 The inventory was prepared before the MACT for Industrial Boilers and Process Heaters was vacated. Control efficiency 

was assumed to be 4 percent for SO2 and 40 percent for PM. The overall effects of including these reductions in the 

inventory are estimated to be minimal. 
Connecticut Regional Haze Page 11-10 

State Implementation Plan November 2009 

• The Ozone Transport Commission’s VOC Model Rules (for consumer products, 

architectural and industrial maintenance coatings, portable fuel containers, mobile 

equipment repair and refinishing, and solvent cleaning); 

• Residential woodstove NSPS; and 

• State-specific control strategies implemented since 2002. 

The following additional control measures were included in the 2018 analysis to reduce NOX

and VOC emissions for the following area source categories for some (identified) states: 

• NOX control measures for combustion of coal; natural gas; and #2, #4, and #6 fuel oils 

(CT, NJ, and NY only); 

• VOC control measures for adhesives and sealants (all MANE-VU states except New 

Jersey19 and VT); 

• VOC control measures for emulsified and cutback asphalt paving (all MANE-VU states 

except ME and VT); 

• VOC control measures for consumer products (all MANE-VU states except VT); and 

• VOC control measures for portable fuel containers (all MANE-VU states except VT). 

As noted above, inventory data for other regions were obtained from those regions’ RPOs. 

Some of the area-source control measures listed above may have been developed by states for 

the primary purpose of reducing ozone within the Ozone Transport Region (OTR) – see 

Subsection 11.3.2 for information on other measures included in states’ ozone SIPs. 

11.3.4 Controls on Mobile Sources Expected by 2018 

For the on-road mobile source emission inventory, Connecticut relied on MANE-VU’s 

Version 3.0 emission inventory, which included the following post-2002 emission control 

measures:

• Use of reformulated gasoline in the four New Hampshire southern counties classified 

as ozone nonattainment areas: Rockingham, Strafford, Hillsborough, and Merrimack; 

• An enhanced safety inspection program in New Hampshire, including an antitampering inspection for motor vehicles less than 20 years old; 

• On-board diagnostics testing for 1996 and newer vehicles in New Hampshire in lieu of 

the anti-tampering inspection; 

• Federal On-Board Refueling Vapor Recovery (ORVR) Rule; 

• Federal Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Requirements; 

and 

• Federal Heavy-Duty Diesel Engine Emission Standards for Trucks and Buses

 

19 New Jersey’s emission reductions from control measures for adhesives and sealants apply only to area sources. No reductions 

for point sources (SCC 4-02-0007-xx) were included to avoid inventory double-counting. 
Connecticut Regional Haze Page 11-11 

State Implementation Plan November 2009 

Similar programs in other MANE-VU states were included in the on-road mobile source 

emission inventory, where applicable. The last four items listed above are federal programs, 

briefly described here: 

On-Board Refueling Vapor Recovery (ORVR) Rule: The 1990 Clean Air Act (CAA) 

Amendments contain provisions that require passenger cars to capture refueling emissions. In 

1994, EPA published the ORVR Rule establishing standards for refueling emissions controls 

for passenger cars and light trucks. The onboard controls were required to be phased in for all 

new car production by 2000 and for all light trucks by 2006. The rule established a refueling 

emission standard of 0.20 grams per gallon of dispensed fuel, which was expected to yield a 

95 percent reduction of VOC emissions over uncontrolled levels. The CAA authorizes EPA 

to allow state and local agencies to phase out Stage II programs, even in the worst 

nonattainment areas, once EPA has determined that onboard systems are in widespread use. 

Tier 2 Motor Vehicle Emissions Standards: Tier 2 is a fleet-averaging program modeled 

after the California LEV II standards. Manufacturers can produce vehicles with emissions 

ranging from relatively dirty to zero, but the mix of vehicles a manufacturer sells each year 

must have average NOX emissions below a specified value. The Tier 2 regulations also 

require reduced gasoline sulfur levels. The reduction in sulfur levels contributes directly to 

cleaner air and has additional beneficial effects on vehicle emission control systems. The Tier 

2 standards became effective in the 2005 model year and are included in the assumptions used 

for calculating mobile source emissions inventories used for 2018. 

Heavy-Duty Diesel Engine Emission Standards for Trucks and Buses: EPA set a PM 

emissions standard of 0.01 grams per brake-horsepower-hour (g/bhp-hr) for new heavy-duty 

diesel engines in trucks and buses, to take full effect in the 2007 model year. This rule also 

includes standards for NOX and non-methane hydrocarbons (NMHC) of 0.20 g/bhp-hr and 

0.14 g/bhp-hr, respectively. These NOX and NMHC standards will be phased in together 

between 2007 and 2010. Sulfur in diesel fuel must be lowered to enable modern pollutioncontrol technology to be effective on the trucks and buses that use this fuel. EPA will require a 

97-percent reduction in the sulfur content of highway diesel fuel from its current level of 500 

parts per million (low-sulfur diesel) to 15 parts per million (ultra-low sulfur diesel).

11.3.5 Controls on Non-Road Sources Expected by 2018 

For non-road emission sources, Connecticut used Version 3.0 of the MANE-VU 2002 

Emissions Inventory. Because the NONROAD Model used to develop the non-road source 

emissions did not include aircraft, commercial marine vessels, and locomotives, MANE-VU’s 

contractor, MACTEC, developed the inventory for these sources. Non-road mobile source 

emissions for the 2018 emission inventory were calculated with EPA’s NONROAD2005 

emissions model as incorporated into the NMIM2005 (National Mobile Inventory Model) 

database. The NONROAD model accounts for emissions benefits associated with federal 

non-road emission control requirements such as the following: 

• “Control of Air Pollution: Determination of Significance for Nonroad Sources and 

Emissions Standards for New Nonroad Compression Ignition Engines at or above 37 

Kilowatts,” 59 FR 31306, June 17, 1994.
Connecticut Regional Haze Page 11-12 

State Implementation Plan November 2009 

• “Control of Emissions of Air Pollution from Nonroad Diesel Engines,” 63 FR 56967, 

October 23, 1998. 

• “Control of Emissions from Nonroad Large Spark-Ignition Engines and Recreational 

Engines (Marine and Land-Based),” Final Rule, 67 FR 68241, November 8, 2002. 

• “Control of Emissions of Air Pollution from Nonroad Diesel Engines and Fuel,” Final 

Rule, 69 FR 38958, June 29, 2004. 

As noted above, inventory data for other regions were obtained from those regions’ RPOs. 

11.4 Additional Reasonable Measures 

As required under 40 CFR 51.308(d)(1)(i)(A), Connecticut and the other MANE-VU states 

applied four-factor analysis to potential control measures for the purpose of establishing 

reasonable progress goals (see Subsection 10.2 for detailed description). Reasonable 

measures include those that the affected states have already committed themselves to 

implementing, as described in Subsection 11.3, above. In addition, the MANE-VU states 

have identified other control measures that were found to be reasonable and were included in 

the modeling that was used to set reasonable progress goals. (These additional measures 

surpass the “beyond-on-the-way” emission controls and inventories.) All of the control 

measures – those embodied in the states’ commitments to existing or planned programs and 

the additional reasonable control measures described below – comprise the long-term strategy 

for improving visibility at MANE-VU Class I Areas. 

Specifically, the MANE-VU long-term strategy includes the following additional measures to 

reduce pollutants that cause regional haze. 

• Timely implementation of BART requirements. 

• 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: 

− #2 distillate oil to 0.05 percent (500 ppm) sulfur, by weight, by no later than 2012; 

− #4 residual oil to 0.25 percent sulfur, by weight, by no later than 2012; 

− #6 residual oil to 0.3-0.5 percent sulfur, by weight, by no later than 2012; 

− Further reduction of the sulfur content of distillate oil to 15 ppm by 2016. 

• A low-sulfur fuel oil strategy in the outer-zone states (the remainder of the MANE-VU 

region) to reduce the sulfur content of: 

− #2 distillate oil to 0.05 percent (500 ppm) sulfur, by weight, by no later than 2014; 

− #4 residual oil to 0.25-0.5 percent sulfur, by weight, by no later than 2018; 

− #6 residual oil to 0.5 percent sulfur or less, by weight, by no later than 2018; 

− Further reduction of the sulfur content of distillate oil to 15 ppm by 2018, 

contingent on supply and availability. 

• A 90-percent or greater reduction in SO2 emissions from each of the EGUs identified 

by MANE-VU as reasonably anticipated to cause or contribute to impairment of 
Connecticut Regional Haze Page 11-13 

State Implementation Plan November 2009 

visibility in each mandatory Class I area in the MANE-VU region. (This requirement 

affects 167 point sources, or stacks, at EGU facilities in the eastern United States.) If 

it is infeasible to achieve this level of SO2 reductions from specific EGUs, equivalent 

alternative measures will be pursued in the affected states. 

• Continued evaluation of other control measures, including energy efficiency, 

alternative clean fuels, 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. 

This suite of additional control measures are those that the MANE-VU states have agreed to 

pursue for the purpose of mitigating regional haze. The corollary is that the MANE-VU Class 

I states (Maine, New Hampshire, Vermont, and New Jersey) are asking states outside the 

MANE-VU region that contribute to visibility impairment inside the region to pursue similar 

measures. The control measures that non-MANE-VU states choose to pursue may be directed 

toward the same emission source sectors identified by MANE-VU for its own emission 

reductions, or they may be equivalent measures targeting other source sectors. Under MANEVU’s long-term strategy, states will be allowed up to ten years to pursue adoption and 

implementation of proposed control measures. While some measures that states pursue may 

not represent enforceable commitments immediately, they may become enforceable in the 

future as new laws are passed, rules are written, and facility permits are issued. 

11.4.1 BART 

Implementation of the BART provisions of the Regional Haze Rule (40 CFR 51.308(e)) is 

one of the reasonable strategies included in this SIP. For EGUs, EPA determined that CAIR 

would fulfill the BART requirement for this sector. Connecticut’s approach demonstrates 

BART equivalency and is described in Section 9.0 of this SIP. 

To assess the benefits of implementing BART controls for MANE-VU’s non-EGU sectors, 

NESCAUM included in the final 2018 CMAQ modeling analysis anticipated emission 

reductions for the region’s BART-eligible facilities, as described previously in Subsection 

10.2.2 of this SIP. It is anticipated that twelve units at eight BART-eligible sources in 

MANE-VU would be controlled as a result of BART requirements alone (see Table 10.3). 

Note that additional emission reductions will occur at many other BART-eligible facilities 

within MANE-VU as a result of controls achieved by other programs that serve as BART but 

are not specifically identified as such (e.g., RACT control measures). While not specifically 

identified as being attributable to BART, these additional emission reductions were fully 

accounted for in the 2018 CMAQ modeling. 

Further visibility benefits are likely to result from installation of new emission controls at 

BART-eligible facilities located in neighboring RPOs. However, the MANE-VU modeling 

did not account for BART controls in other RPOs and, consequently, did not include visibility 

improvements at MANE-VU Class I Areas that would be likely to accrue from such measures. 
Connecticut Regional Haze Page 11-14 

State Implementation Plan November 2009 

11.4.2 Low-Sulfur Oil Strategy 

The important assumption underlying MANE-VU’s low-sulfur fuel oil strategy is that refiners 

can, by 2018, produce sufficient quantities of home heating and other fuel oils with lower 

sulfur content than current fuel supplies at only a small increase in price to the end user. The 

expected reductions in sulfur content range from 50 percent for the heavier grades (#4 and #6 

residual) to a minimum of 75 percent and maximum of 99.25 percent for #2 fuel oil (also 

known as home heating oil, distillate, or diesel fuel). As much as three-fourths of the total 

sulfur reductions achieved by this strategy will come from using low-sulfur #2 distillate for 

space heating in the residential and commercial sectors. The costs of these emissions 

reductions are estimated at $550 to $750 per ton, as documented in the MANE-VU 

Reasonable Progress Report. While the costs of the low-sulfur fuel oil strategy remain 

somewhat uncertain, they appear to be reasonable when measured against the costs of 

controlling other sectors. 

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

reasonable to pursue over the next ten years. CTDEP will review the details of this strategy in 

five years, coincident with Connecticut’s first regional haze SIP progress report. Section 16a21a of the Connecticut General Statutes limits fuel sulfur content of heating distillate oil and 

off-road diesel oil to 500 ppm as of the date on which the last of the States New York, 

Massachusetts and Rhode Island limit the sulfur content of such fuels. Therefore, 

implementation of this strategy in Connecticut is dependent upon adjacent states’ 

implementation. CTDEP continues to participate in consultations with other MANE-VU 

states to develop a low sulfur heating strategy consistent with the MANE-VU “Ask”. 

11.4.3 Targeted EGU Strategy 

MANE-VU has identified emissions from the top 167 EGU emission points that contribute 

the most to visibility impairment at MANE-VU Class I Areas (see Figure 10.2). Controlling 

emissions from these contributing facilities is crucial to mitigating haze pollution in 

wilderness areas and national parks of the Northeast states. 

MANE-VU’s agreed regional approach for the EGU source sector is to pursue a 90 percent 

control level on SO2 emissions from the 167 identified stacks by 2018. MANE-VU has 

concluded that pursuing this level of sulfur reduction is both reasonable and cost-effective. 

Even though current wet scrubber technology can achieve sulfur reductions greater than 95 

percent, an overall 90-percent sulfur reduction level would include the effects of lower 

average reduction rates from dry scrubbing technology, consistent with historical experience. 

The costs of SO2 emission reductions will vary by unit. MANE-VU’s Reasonable Progress 

Report (Attachment Y) summarizes the available control methods and costs, which range 

from $170 to $5,700 per ton (2006 dollars), depending on site-specific factors such as size of 

unit, combustion technology used, and type of fuel burned. Connecticut is not home to any of 

the top 167 EGU emission points that contribute the most to visibility impairment at MANEVU Class I Areas. 

As of 2003, EGUs in Connecticut reduced their SO2 emissions by 72 percent since 1999. 
Connecticut Regional Haze Page 11-15 

State Implementation Plan November 2009 

 These benefits to regional visibility occurred as a consequence of Connecticut’s Control of 

Sulfur Dioxide Emissions from Power Plants and Other Large Stationary Sources of Air 

Pollution regulation, which was established by law in RCSA section 22a-174-19a. Under this 

regulation, Acid Rain Program EGUs 15 MW and greater are required to limit fuel sulfur 

content combusted to equal to or less than 0.3% sulfur, or to meet an average emission rate of 

equal to or less than 0.33 lbs SO2/MMBtu for each calendar quarter for an affected unit, or to 

meet an average emission rate of equal to or less than 0.3 lbs SO2/MMBtu for each calendar 

quarter if the owner or operator averages the emissions from two or more affected units at a 

premises. CTDEP will continue to evaluate other control measures for EGUs and will 

provide an update on its evaluation in Connecticut’s first five-year regional haze SIP progress 

report. 

Several other states within and outside the MANE-VU region have implemented state-specific 

EGU emission reduction programs that will help MANE-VU meet visibility improvement 

goals. Many of the state programs that will contribute to meeting the targeted EGU strategy 

are identified in Subsection 11.3.1. Listed below are other state programs not previously 

identified that will also contribute to meeting this strategy. These other programs may yield 

additional benefits by controlling emissions at certain EGUs not listed among the top 167 

EGU stacks. The listed programs represent existing commitments by the states and, as such, 

were included in MANE-VU’s most recent modeling. 

Maryland Healthy Air Act: Maryland adopted the following requirements governing EGU 

emissions: 

• For NOX: 

− Phase I (2009) sets unit-specific annual caps totaling 20,216 tons and ozoneseason caps totaling 8,900 tons. 

− Phase II (2012) sets unit-specific annual caps totaling 16,667 tons and ozoneseason caps totaling 7,337 tons. 

• For SO2: 

− Phase I (2010) sets unit-specific annual caps totaling 48,818 tons. 

− Phase II (2013) sets unit-specific annual caps totaling 37,235 tons. 

• For mercury: 

− Phase I (2010) requires a 12-month-rolling-average minimum removal 

efficiency of 80 percent. 

− Phase II (2013) requires a 12-month-rolling-average minimum removal 

efficiency of 90 percent. 

The specific EGUs included are: Brandon Shores (Units 1 and 2), C.P.Crane (Units 1 and 2), 

Chalk Point (Units 1, and 2), Dickerson (Units 1, 2, and 3), H.A. Wagner (Units 2 and 3) 

Morgantown (Units 1 and 2), and R. Paul Smith (Units 3 and 4). No out-of-state trading of 

emission allowances, no inter-company trading of allowances, and no banking of allowances 

from year to year were included in the analyses. 
Connecticut Regional Haze Page 11-16 

State Implementation Plan November 2009 

New Jersey Mercury MACT Rule: Under this rule all coal-fired EGUs in New Jersey will 

have a mercury removal efficiency of 90 percent. (Some SO2 reductions may occur as a cobenefit of mercury emission controls.) 

Consent Agreements in the VISTAS region: The following consent agreements in the 

VISTAS states were reflected in the emissions inventories used for those states: 

• East Kentucky Power Cooperative: A July 2, 2007, consent agreement between EPA 

and East Kentucky Power Cooperative (EKPC) requires the utility to reduce its SO2

emissions by 54,000 tons per year and its NOX emissions by 8,000 tons per year, by 

installing and operating selective catalytic reduction (SCR) technology; low-NOX

burners, and PM and mercury continuous emissions monitors at the utility’s Spurlock, 

Dale, and Cooper Plants. According to the EPA, total emissions from the plants will 

decrease between 50 and 75 percent from 2005 levels. As with all federal consent 

decrees, EKPC is precluded from using reductions required under other programs, 

such as CAIR, to meet the reduction requirements of the consent decree. EKPC is 

expected to spend $654 million to install pollution controls. 

• American Electric Power: Under this agreement, American Electric Power (AEP) will 

spend $4.6 billion dollars for emission controls at sixteen plants located in Indiana, 

Kentucky, Ohio, Virginia, and West Virginia. These control measures will eliminate 

72,000 tons of NOX emissions each year by 2016 and 174,000 tons of SO2 emissions 

each year by 2018 from the affected facilities.

11.5 Source Retirement and Replacement Schedules 

40 CFR Section 51.308(d)(3)(v)(D) of the Regional Haze Rule requires Connecticut to 

consider source retirement and replacement schedules in developing its long-term strategy. 

Source retirement and replacement were considered in developing the 2018 emissions 

inventory described previously in Subsection 10.3, Reasonable Progress Goals for Class I 

Areas in the State. While the output of the IPM model predicts that a certain number of older 

power plants will be replaced by newer units to meet future electric growth and state-specific 

NOX and SO2 caps, Connecticut did not directly rely on the closure of any particular plant in 

establishing the 2018 inventory upon which the reasonable progress goals were set. 

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

large EGUs in Connecticut, including five of the six BART-eligible EGUs (Middletown 

Power 3 & 4, Montville Power 6, Norwalk Power 2 and PSEG Power Connecticut New 

Haven Harbor 1) will retire by 2018. Table 11.1 shows two non BART-eligible EGUs in 

Connecticut that have retired since 2002. 

Table 11.1 Retired EGUs 

Unit Capacity (MW) Retirement Date 

Devon 7 109 11/28/07 

Devon 8 109 11/28/07 
Connecticut Regional Haze Page 11-17 

State Implementation Plan November 2009 

11.6 Measures to Mitigate the Impacts of Construction Activities

40 CFR 51.308(d)(3)(v)(B) of the Regional Haze Rule requires Connecticut to consider 

measures to mitigate the impacts of construction activities on regional haze. MANE-VU’s 

consideration of control measures for construction activities is documented in “Technical 

Support Document on Measures to Mitigate the Visibility Impacts of Construction Activities 

in the MANE-VU Region,” Draft, October 20, 2006,” (Attachment DD). 

The construction industry is already subject to requirements for controlling pollutants that 

contribute to visibility impairment. For example, EPA’s off-road engine standards and low 

sulfur fuel requirements result in reductions of PM and precursor emissions (SO2 and NOx) 

from construction vehicles. 

At the state level, Connecticut’s RCSA section 22a-174-18, “Control of particulate matter and 

visible emissions”, addresses the control of airborne particulate matter and fugitive particulate 

matter in subsections (c) and (d). These regulations, which include dust control measures and 

visible emissions from diesel powered mobile sources, apply to road building and 

construction activities. Regulations are available online at 

http://www.dep.state.ct.us/air2/regs/mainregs.htm. 

Two additional emissions control programs related to construction activities are currently 

underway in Connecticut. First, the Connecticut Clean Air Construction Initiative is a 10-year 

pilot project designed to reduce idling and operational emissions from construction equipment 

used to complete the I-95 New Haven Harbor Crossing Improvement Project also called the Q 

Bridge Project. Retrofits and idling restrictions for this project are required as part of contract 

specifications with the Connecticut Department of Transportation (CTDOT). Diesel retrofits 

and idling restrictions for construction vehicles were also written into a special act called the 

Connecticut Clean Diesel Plan by the Connecticut Department of Environmental Protection 

(CTDEP). The CTDEP hopes to work with CTDOT to expand this program to all state road 

construction projects. Currently, 150 diesel powered construction machines have been 

retrofitted with oxidation catalysts and by the projects’ completion 200 machines will be 

retrofitted. 

The CTDOT has implemented diesel vehicle emission controls that Contractors and Subcontractors are obligated to follow. Any non-road construction equipment with engine 

horsepower (HP) rating of 60 HP and above that are assigned to a contract for a period in 

excess of 30 consecutive calendar days must be retrofitted with Emission Control Devices 

and/or use Clean Fuels in order to reduce diesel emissions. Contractors must submit a 

certified list of non-road diesel powered construction equipment that will be retrofitted with 

emission control devices and/or use Clean Fuel and include the addition or deletion of nonroad diesel equipment. The list has three parts and a monthly report must also be submitted by 

the contractor updating the above stated information. If these rules are not followed the 

contractor will be issued a Non-Compliance and given 24 hours to bring the equipment into 

compliance or have it removed from the project. If the contractor still does not comply further 

and more extreme actions will be taken. For further information on this project contact the 

CTDOT, regarding the I-95 New Haven Harbor Crossing Corridor Improvement Program.
Connecticut Regional Haze Page 11-18 

State Implementation Plan November 2009 

Second, a PM10 limited maintenance plan for the City of New Haven was approved by EPA. 

The plan includes some contingency measures that apply to New Haven under a state order. 

The measures focus on street paving and sweeping. 

MANE-VU’s Contribution Assessment (Attachment B) found that, from a regional haze 

perspective, crustal material generally does not play a major role. On the 20 percent bestvisibility days during the 2000-2004 baseline period, crustal material accounted for 6 to 11 

percent of particle-related light extinction at MANE-VU Class I Areas. On the 20 percent 

worst-visibility days, however, the ratio was reduced to 2 to 3 percent. Furthermore, the 

crustal fraction is largely made up of pollutants of natural origin (e.g., soil or sea salt) that are 

not targeted under the Regional Haze Rule. Nevertheless, the crustal fraction at any given 

location can be heavily influenced by the proximity of construction activities; and 

construction activities occurring in the immediate vicinity of MANE-VU Class I Areas could 

have a noticeable effect on visibility. 

Connecticut has adopted an indirect source permitting program to minimize particulate matter 

emissions from highway construction activities (RCSA section 22a-174-100 – not part of 

Connecticut’s SIP). The need for additional control measures for construction activities and 

their possible implementation will be evaluated in the first five-year regional haze SIP 

progress report. 

11.7 Agricultural and Forestry Smoke Management 

40 CFR 51.308(d)(3)(v)(E) requires Connecticut to consider smoke management techniques 

related to agricultural and forestry management in developing the long-term strategy. 

MANE-VU’s analysis of smoke management in the context of regional haze is documented in 

“Technical Support Document on Agricultural and Forestry Smoke Management in the 

MANE-VU Region, September 1, 2006,” (Attachment V). 

As that report notes, fires used for resource benefits are of far less significance to the total 

inventory of fine-particle pollutant emissions than other sources of wood smoke in the region. 

The largest wood smoke source categories, with respect to PM2.5 emissions, are residential 

wood combustion (73 percent); open burning (15 percent); and industrial, commercial, and 

institutional wood combustion (9 percent) (see Figure 2 in Subsection 4.1 of Attachment V). 

Unwanted fires involving buildings and wild lands make up only a minor fraction of wood 

burning emissions and cannot be reasonably addressed in a SIP. Fires that are covered under 

smoke management plans, including agricultural and prescribed forest burning, constitute less 

than one percent of total wood smoke emissions in MANE-VU (see Figure 2 in Subsection 

4.1 of Attachment V). 

Moreover, smoke emissions from all sources represent only a minor fraction of fine-particle 

mass that is the cause of regional haze. MANE-VU’s Contribution Assessment (Attachment 

B) found that elemental carbon, the main ingredient of smoke, contributed only 3 to 4 percent 

of fine-particle mass on days of worst and best visibility. Additionally, elemental carbon 

absorbs light more readily than it scatters light. It is therefore reasonable to conclude that 

smoke emissions from controlled agricultural and forestry burning contribute, on average, 

only a small fraction of one percent of total light extinction on days of both good and poor
Connecticut Regional Haze Page 11-19 

State Implementation Plan November 2009 

visibility. CTDEP has no information to indicate that this situation would change 

significantly over the next decade. 

Connecticut currently regulates outdoor word burning through a statute at CGS 22a-174(f) 

and a regulation at RCSA 22a-174-17. The open burning requirements limit the locations and 

times when open burning can take place. These requirements were originally adopted to 

protect public health but also act to reduce smoke and regional haze. Although CTDEP does 

not have a formal smoke management program, as a smoke management policy, CTDEP’s 

Division of Forestry can only initiate prescribed burns when such activity has less significant 

impacts on air quality (see Attachment FF). 

CTDEP’s Bureau of Air Management currently obtains wildfire and prescribed burning data, 

including number of acres burned, when the wildfire or prescribed burn occurred and the 

location of the wildfire or prescribed burn, from CTDEP’s Forestry Division. The wildfire 

and prescribed burning data will be included in CTDEP’s periodic inventory every three 

years. CTDEP will track smoke emissions from wildfires and prescribed fires and will assess 

if emissions from such activities are increasing in the first five-year regional haze SIP 

progress report and required SIP revision due in 2018. 

11.8 Estimated Effects of Long-Term Strategy on Visibility 

40 CFR 51.308(d)(3)(v)(G) requires Connecticut to consider, in developing its long-term 

strategy, the anticipated net effect on visibility due to projected changes in point, area, and 

mobile source emissions over the period addressed by the long-term strategy. NESCAUM 

conducted modeling to evaluate the expected improvements to visibility at affected Class I 

areas by 2018 as a consequence of implementing MANE-VU’s long-term strategy. Those 

visibility improvements will result, in part, from the efforts identified in this SIP to reduce 

emissions that originate in Connecticut. 

All Class I states affected by emissions originating in Connecticut have (or will have) 

established reasonable progress goals for 2018 for each of their Class I areas. The 

control measures included in this SIP represent the reasonable efforts of Connecticut, in 

conjunction with the efforts of other MANE-VU states, toward achieving the reasonable 

progress goals established by the affected states. 

Based on the most recent MANE-VU modeling, the proposed control measures will reduce 

sulfate levels at affected Class I areas by about one-third on the worst visibility days and by 

6 to 31 percent on the best visibility days by 2018. Nitrate and elemental carbon levels will 

also show substantial reductions across all areas for both best and worst days, while smaller 

reductions in organic carbon levels will occur. Small increases are predicted for the fine soil 

component of regional haze. There is a possibility that the predicted increases in this 

component are not real but, rather, related to structural differences in the data sets used in the 

modeling for the baseline and future years. (Specifically, the fire emissions inventory used in 

VISTAS for the base year relied on an earlier version of fire emissions data than the one used 

for the 2018 inventory.) No changes are predicted for sea salt because the model does not 

track this component. 
Connecticut Regional Haze Page 11-20 

State Implementation Plan November 2009 

The 2000-2004 visibility readings at affected Class I areas provide the baseline against which 

future visibility readings will be measured to assess progress deriving from implementation of 

Connecticut’s regional haze SIP and those of the other MANE-VU states. To determine 

baseline visibility for affected Class I areas, the 2000-2004 IMPROVE monitoring data was 

used to calculate the average deciview values for the 20 percent best visibility days and the 20 

percent worst visibility days over that period. Thus, the 20 percent best day and 20 percent 

worst day values represent average visibility conditions for the top and bottom quintiles. 

To create the series of visibility graphs which follow, 2018 visibility estimates were made in 

accordance with EPA modeling guidance. First, 2002 daily average baseline concentrations 

were multiplied by their corresponding relative reduction factors to obtain 2018 projected 

concentrations for each day. The 2018 projected concentrations were then used to derive 

daily visibility in deciviews. As a final step, the deciview values for the 20 percent of days 

having best visibility were averaged, and the process repeated for the 20 percent of days 

having worst visibility. The resulting averages represent the projected upper and lower 

quintiles of visibility in 2018. 

The following is provided to assist with interpretation of the line graphs in Figures 11.1 

through 11.5. Note that lower deciview values indicate better visibility. 

• The irregular blue line (~) represents the 20 percent best visibility average value as 

determined from monitoring data for each year of the period 2001-2005. 

• The irregular red line (~) represents the 20 percent worst visibility average value as 

determined from monitoring data for each year of the period 2001-2005. 

• The straight orange line (⎯) represents the 20 percent best visibility average value as 

determined from monitoring data for the 5-year period of 2000-2004. (This line 

represents the 20 percent best visibility baseline condition.) 

• The straight blue line (⎯) represents the 20 percent worst visibility average value as 

determined from monitoring data for the 5-year period of 2000-2004. (This line 

represents the 20 percent worst visibility baseline condition.) 

• The straight broken line (⋅⋅⋅⋅) is a continuation of the 20 percent best visibility baseline, 

representing the 20 percent best visibility condition as it would be with no further 

degradation or improvement. 

• The straight green line (⎯) represents the 20 percent worst visibility values that 

establish the uniform rate of progress for the period 2004-2064. (This line is 

sometimes referred to as the uniform progress line, or “glide slope.” It was created by 

linear interpolation between the 20 percent worst visibility baseline value in 2004 and 

the 20 percent worst visibility value under natural conditions in 2064. If visibility 

improvements match this rate of progress, actual visibility will return to natural 

conditions in 2064.) 

• The light-green dash (−) shown at 2064 represents the theoretical 20 percent best 

visibility value under natural conditions (i.e., no anthropogenic emissions). 

• The purple star (1⁄4) represents the 20 percent best visibility value in 2018 after 

implementation of MANE-VU’s long-term strategy, as predicted by the CMAQ model. 

(This value is a reasonable progress goal.) 
Connecticut Regional Haze Page 11-21 

State Implementation Plan November 2009 

• The blue star (1⁄4) represents the 20 percent worst visibility value in 2018 after 

implementation of MANE-VU’s long-term strategy, as predicted by the CMAQ model. 

(This value is a reasonable progress goal.) 

Figures 11.1 through 11.5 are line graphs showing anticipated visibility improvements for the 

MANE-VU Class I Areas. All locations are projected to meet or exceed their uniform-rateof-progress goals for 2018. In addition, all areas are expected to see improvements in bestday visibility relative to baseline values. 
Connecticut Regional Haze Page 11-22 

State Implementation Plan November 2009 

Figure 11.1: Expected Visibility Improvement at Great Gulf Wilderness 

Based on Most Recent Projections 20

Figure 11.2: Expected Visibility Improvement at Acadia National Park 

Based on Most Recent Projections 

 

20 The visibility improvement estimate for Great Gulf Wilderness also serves as an estimate for Presidential Range - Dry 

River Wilderness. 
Connecticut Regional Haze Page 11-23 

State Implementation Plan November 2009 

Figure 11.3: Expected Visibility Improvement at Brigantine National Wildlife Refuge 

Based on Most Recent Projections 

Figure 11.4: Expected Visibility Improvement at Lye Brook Wilderness 

Based on Most Recent Projections 
Connecticut Regional Haze Page 11-24 

State Implementation Plan November 2009 

Figure 11.5: Expected Visibility Improvement at Moosehorn National Wildlife Refuge 

Based on Most Recent Projections 21

11.9 Connecticut’s Share of Emission Reductions 

40 CFR 51.308(d)(3)(ii) of the Regional Haze Rule requires Connecticut to demonstrate that 

its implementation plan includes all measures necessary to obtain its share of emission 

reductions needed to meet the reasonable progress goals. The modeling analyses referenced 

in Subsection 11.8, above, demonstrate that the MANE-VU long-term strategy is sufficient to 

meet these visibility goals. 

The basis for the long-term strategy is a statement adopted by MANE-VU on June 20, 2007 

(see Subsection 3.2.2, The MANE-VU “Ask”). The MANE-VU “Ask” provides that each 

state will have up to 10 years to pursue adoption and implementation of reasonable control 

measures for NOX and SO2 emission reductions. Connecticut’s regional haze SIP is wholly 

consistent with this long-term strategy. To further meet its obligation beyond those controls 

already adopted, CTDEP has agreed to pursue the following measures, consistent with the 

provisions of the MANE-VU “Ask”: 

• Participation in a regional low-sulfur fuel oil strategy that will result in SO2 emission 

reductions from residential heating units across the state; and 

• Continued evaluation of other possible control measures for haze-causing emissions. 

Implementation of the long-term strategy will produce significant reductions in Connecticut’s 

emissions inventory by the end of the first planning period, 2018. Changes to the emissions 

inventory will also occur as a result of population growth; changes in land use and 

 

21 The visibility improvement estimate for Moosehorn Wilderness also serves as an estimate for Roosevelt/Campobello 

International Park.
Connecticut Regional Haze Page 11-25 

State Implementation Plan November 2009 

transportation; development of industrial, energy, and natural resources; and other air pollution 

control measures not directly related to regional haze. However, it is the expected reductions 

in SO2 emissions that will have the greatest effect on visibility improvement at MANE-VU 

Class I Areas; and those reductions will be largely due to implementation of the control 

measures developed for this SIP. (As a precursor to sulfate, SO2 emissions are responsible for 

most of the fine-particle mass on the haziest days at MANE-VU Class I Areas. See Section 

8.0, Understanding the Sources of Haze-Causing Pollutants.) 

As referred to in Section 11.2, the “beyond on the way” scenario described in Attachment G 

(defined by CAIR with other “on the books” measures and the limitation of fuel sulfur content 

to 500 ppm for all No. 2 “distillate” fuel oil sold in the MANE-VU region) is sufficient to 

achieve visibility improvement beyond the so-called “uniform rate of progress” defined by 

uniform visibility improvement between now and 2064, the planning horizon for the regional 

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

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

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

Current and projected SO2 emissions for the various source categories in Connecticut and, for 

comparison, all of MANE-VU are summarized in Tables 11.2 and 11.3. These emissions 

represent the majority of all haze-causing pollutants originating within the state and region. 

Further information on Connecticut’s emissions inventory, including other pollutants that 

contribute to visibility impairment, is available in Section 6.0, Emissions Inventory. 

Table 11.2: SO2 Emissions from Point, Area, and Mobile Sources 

in Connecticut (tpy)22 

Source Category Baseline 

2002 

Projected 

2018 

% Reduction 

2002-2018 

Area 12,418 534 95.6 

Non-EGU Point 2,438 2,068 15.1 

EGU Point 13,550 6,697 50.6 

On-Road Mobile 1,667 366 78 

Non-Road Mobile 2,087 815 60.9 

TOTAL 32,160 10,480 67.4 

 

22 It should be noted that due to Connecticut’s early SO2 emission reduction strategy, SO2 emissions from EGUs and large 

point sources were reduced from 35,625 tons per year in 2001 to 13,055 tons per year in 2002 (see Attachment X).
Connecticut Regional Haze Page 11-26 

State Implementation Plan November 2009 

Table 11.3: SO2 Emissions from Point, Area, and Mobile Sources 

in all of MANE-VU (tpy) 

Source Category Baseline 

2002 

Projected 

2018 

% Reduction 

2002-2018 

Area 286,921 129,656 54.8 

Non-EGU Point 264,377 211,320 65.4 

EGU Point 1,643,257 386,584 77.6 

On-Road Mobile 40,090 8,757 78.2 

Non-Road Mobile 57,257 8,643 84.9 

TOTAL 2,291,902 744,960 67.5 

Note: Emission estimates for all MANE-VU states are archived at ftp.marama.org (User Name: mane-vu; 

Password: exchange). 

The projected overall reduction of 67.4 percent for SO2 emissions originating in Connecticut 

is comparable to the projected reduction of 67.5 percent in the MANE-VU region. In 

addition, SO2 emissions from EGUs and large point sources in Connecticut decreased by 63% 

from 2001 to 2002 as a result of Connecticut’s early SO2 emission reduction strategy. This 

comparison indicates that Connecticut will meet its share of anticipated SO2 emission 

reductions within the region by 2018. 

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

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

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

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

issues, caused by outdoor wood burning furnaces (OWBFs) through the adoption of minimum 

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

to gather and evaluate information concerning OWBF emissions and to learn from the success 

of surrounding states with more stringent regulatory programs for OWBFs. Adoption of 

performance standards for new OWBFs would be most effectively pursued by EPA since the 

sales market includes the entire northern United States. 

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

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

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

emissions standards. An analysis provided by Cambridge Systemics for NESCAUM finds 

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

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

what the federal Tier 2 program is expected to achieve. Reduced formation of secondary 

organic aerosol is likely another benefit of the California LEV II program. 

 

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

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

certain operating practices, including a requirement to burn only clean wood. 
Connecticut Regional Haze Page 11-27 

State Implementation Plan November 2009 

11.10 Emission Limitations and Compliance Schedules 

40 CFR 51.308(d)(3)(v)(C) requires Connecticut to establish emission limitations and 

compliance schedules to meet reasonable progress goals. Emission limitations and 

compliance schedules are already in place for the Connecticut programs outlined in 

Subsection 11.3 of this section. There are two additional reasonable control measures 

described in Subsection 11.4; these additional measures include: 

1. Additional low-sulfur fuel oil requirements, and 

2. Continued evaluation of other control measures for coal burning facilities by 

2018 and NSPS for wood combustion. 

In terms of a state-wide limitation of #4 residual oil to 0.25-0.5% by weight and of #6 residual 

oil to no greater than 0.5% sulfur by weight, CTDEP commits to pursue adoption of a 

regulation by 2012 with an implementation date of no later than 2014. Regarding reduction 

of distillate fuel sulfur content to 15 ppm by 2018, CTDEP commits to pursue adoption of 

legislation that will implement this measure by no later than 2018. CTDEP will continue to 

pursue these measures, consistent with the provisions of the MANE-VU “Ask”, and will 

provide a status update in the first five-year regional haze SIP progress report. Connecticut 

intends to adopt all reasonable control measures as expeditiously as practicable, in a 

manner consistent with state law, so that they may be in place by the end of the ten-year 

planning period. 

11.11 Enforceability of Emission Limitations and Control Measures 

40 CFR 51.308(d)(3)(v)(F) requires Connecticut to ensure that emission limitations and 

control measures used to meet reasonable progress goals are enforceable. All control 

measures incorporated into law or codified in administrative rules will be enforceable. Any 

facility subject to state or federal permit requirements, including BART-eligible and Title V 

facilities, will be required to comply with the specific permit conditions that reference the 

applicable provisions of those laws and rules. 

In Connecticut, the authority to create rules, issue permits, and enforce laws related to 

regional haze are established in Connecticut General Statutes (CGS) Chapter 446c, Air 

Pollution Control. Under CGS sections 22a-171 and 22a-174, Duties of Commissioner of 

Environmental Protection and Powers of the Commissioner, respectively, the CTDEP 

Commissioner is authorized to enforce the state’s air laws, establish a permit program, accept 

and administer grants, and exercise all incidental powers necessary to carry out the statutory 

obligations. 

Sections of Connecticut law of particular relevance to the regional haze SIP are: 

• Connecticut General Statutes (CGS) section 22a-174(c) , which authorizes the 

issuance of permits; 

• CGS section 22a-174(g), which authorizes the Commissioner to collect fees to recover 

the costs of reviewing and acting upon permit applications and monitoring compliance 

with the terms and conditions of permits issued; and
Connecticut Regional Haze Page 11-28 

State Implementation Plan November 2009 

• CGS section 22a-177, which establishes the legal authority for enforcement of the 

RCSA (sections 22a-174-1 – 22a-174-200) and CGS section 22a-178, which 

authorizes CTDEP to issue orders to correct violations of any regulation, order or 

permit adopted or issued under Chapter 446c (Air Pollution Control). 

The Connecticut regulations provide for enforceable emission control measures and 

compliance schedules to meet the applicable requirements of the Clean Air Act and rules 

promulgated by EPA. The Connecticut regulations also define the permit program and fee 

structure for stationary sources, to ensure that national ambient air quality standards are 

achieved. Specifically: 

• RCSA section 22a-174-3a (formerly RCSA section 22a-174-3), Permits to Construct and 

Operate Stationary Sources (RCSA section 22a-174-3 originally effective 6/1/72, amended 

fifteen times or more and replaced by RCSA section 22a-174-3a on 3/15/02 and amended 

on 5-29-07), provides for the issuance of state permits to operate. RCSA subsection 

22a-174-3a(k) addresses the prevention of significant deterioration of air quality and 

visibility protection, in accordance with the requirements of 40 CFR 51.166 and 40 CFR 

52.21. 

• RCSA section 22a-174-33 Title V, provides for the issuance of Title V operating 

permits. 

• RCSA section 22a-174-26, Fees (originally effective 9/24/82, amended subsequently 

five times, most recently on 5-26-04), provides for the payment of fees to cover the 

reasonable costs of administering the permit program. 

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

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

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

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

SO2 emission limit for non-EGUs; 0.5%/0.3% fuel sulfur content or 0.55 

lb/MMBtu/0.33 lb/MMBtu quarterly SO2 emission limits for EGUs). CTDEP has 

submitted the emission limits of RCSA section 22a-174-19a to EPA on November 18, 

2008 in order to make such provisions federally enforceable. The approval request is 

pending. 

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

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

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

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

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

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

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

EPA for SIP approval on December 1, 2004. The approval request is pending. 
Connecticut Regional Haze Page 11-29 

State Implementation Plan November 2009 

Also, Section 16a-21a of the Connecticut General Statutes limits fuel sulfur content of heating 

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

New York, Massachusetts and Rhode Island limit the sulfur content of such fuels. CTDEP is 

submitting CGS section 16a-21a with this SIP in order to make the requirements federally 

enforceable (Attachment GG). 

Ultimately, Connecticut’s Regional Haze SIP is dependent on the implementation of 

enforceable emission limitations and control measures, both within the state and in other 

states identified as contributing to visibility impairment at Class I Areas. Because 

Connecticut has no jurisdiction over other states, the attainment of regional progress goals 

will, to a large extent, be predicated on the good-faith efforts of contributing upwind states to 

meet their fair share of emission reductions through implementation of their own enforceable 

control measures. While Connecticut can provide assurances regarding the implementation of 

in-state emission controls, the bulk of regional-haze-causing pollutants at Class I Areas will 

continue to come from non-Connecticut sources. 

11.12 Prevention of Significant Deterioration 

RCSA section 22a-174-3a(k) spells out the Prevention of Significant Deterioration (PSD) 

requirements of Permits to Construct and Operate Stationary Sources. PSD is applicable to all 

major sources (or existing sources making a major modification), triggering significance 

thresholds, located in an area that is in attainment with the National Ambient Air Quality 

Standards or unclassified. One of the intentions of the PSD program is to protect air quality 

in national parks, wilderness areas, and other areas of special natural, scenic, or historic value. 

The PSD permitting process requires a technical air quality analysis and additional analyses to 

assess the potential impacts on soils, vegetation and visibility. 

Recommended procedures for evaluating the impacts of a proposed PSD source on air quality 

and visibility are provided in CTDEP’s “Ambient Impact Analysis Guidelines”, 1989. Since 

1989, there have been regulatory changes and developments that leave some information in 

the document outdated, so CTDEP recommends on its website that sources contact the 

Attainment Planning Stationary Source group for additional information. In this manner, new 

major sources and existing sources making major modifications will be constructed and 

operated in a manner that will not degrade air quality or visibility. The PSD permitting 

program, as set forth under RCSA section 22a-174-3a(k), is an integral part of Connecticut’s 

long-term strategy for meeting its regional haze goals. 
Connecticut Regional Haze Page 11-30 

State Implementation Plan November 2009 

Attachment A through GG are available on the CT DEP website at: 

http://www.ct.gov/dep/cwp/view.asp?a=2684&Q=432658&depNav_GID=1619