# INTER-RPO

CONSULTATION

BRIEFING BOOK

## Inter-RPO Consultation Briefing Book

Table of Contents

Tab 1 – Introduction

Tab 2 – Consultation Overview

Tab 3 – MANE-VU Class 1 States’ Resolution and MANE-VU Statements

Tab 4 – Uniform Rate of Progress

Tab 5 – Pollution Apportionment

Tab 6 – BART

Tab 7 – Technical Support for Reasonable Progress Goals and Long Term Strategies

 Tab 7A – Overview of Control Options and Reasonable Progress Report

 Tab 7B – Approach to Control Measures and EGU Stacks Analysis

 Tab 7C – Summary of MANE-VU’s CAIR+ Report

Tab 8 – Summary of Work

# Introduction

### I. Background The States of Maine, New Hampshire, Vermont, and New Jersey have Class I areas in the Mid-Atlantic/Northeast Visibil ity Union (MANE-VU) region. In preparation for setting reasonable progress goals for their Class I areas, the MANE-VU Class I States are seeking input from the States with emissi on sources that affect visibility in MANEVU Class I areas and from Federal Land Ma nagers and EPA. The MANE-VU Class I areas are also seeking input from these othe r States and agencies concerning strategies that should be adopted to achieve reasona ble progress in improving visibility in the MANE-VU Class I areas.
Together with the MANE-VU staff at OTC, NESCAUM, and MARAMA, the MANE-VU Class I States have prepared this briefing book to support the process of consultation with States outside the MANE -VU region and to support consultation with Federal Land Managers. This briefing book is intended to facilitate discussions on an interstate conference call and interstate meetings to be scheduled in July and August 2007. This section presents the consultation requirement and reviews the contents of the briefing book. As detailed below, the c onsultation process is required by the EPA’s Regional Haze Rules (40 CFR 51.300 – 51.309).
As explained in the preamble for the Regional Haze Rules, published in the Federal Register on July 1, 1999 (64 FR 35714) “[t]he EPA expects that much of the consultation, apportionment demonstrations , and technical documentation will be facilitated and developed by regional planni ng organizations.” (See 64 FR 35735). The goals of instituting consulta tion procedures are mainly:

1. To help develop a common technical ba sis and apportionment for long-term strategies that could be approved by indi vidual State participants and translated into regional haze SIPs for submission to EPA; 2. To demonstrate that States are working together to develop acceptable approaches for addressing regional visibi lity problems to which they jointly contribute; and 3. To provide information on areas of ag reement and disagreement among States that the Administrator will take into account in the review of a State’s implementation plan to determine whet her the State’s goal for visibility improvement provides for reasonable progress towards natural visibility conditions.
For the purposes of this Briefing Book, the term “consultation” refers solely to the consultation requirements of the Regional Haze Ru les, and is not intended to refer to or address the Tribal government/Federal government consultation process.

### II. Consultation Requirements Specified in the Regional Haze Rules
The requirements for consultation in th e Regional Haze Rules are as follows:
A. Development of the Reasonable Progress Goal:
Section 51.308(d) of the Regional Haze Ru les specifies that “–[I]n developing each reasonable progress goal, the State must consult with those States which may reasonably be anticipated to cau se 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 reasonabl e progress, the State must describe in its submittal the actions taken to resolve the disagreement. In reviewing the State's implementation plan submittal, the [EPA] Administrator will take this information into account in determining whether the State's goal for visibility improvement provides for reasona ble progress towards natural visibility conditions.” [40 CFR §51.308(d)(1)(iv)]. B. Development of Long-term Strategy:
The Regional Haze Rules provides that – “[w] here the State has emissions that are reasonably anticipated to cont ribute to visibility impairme nt in any mandatory Class I Federal area located in anothe r State or States, the State must consult with the other State(s) in order to develop coordinated emission management strategies. The State must consult with any other State having emissi ons that are reasonably anticipated to contribute to visibility impairment in any mandatory Class I Federal area within the State.” [40 CFR § 51.308(d)(3)(i)].
C. State and Federal Land Manager Coordination:
According to Section 51.308(i)(2) of the Regional Haze Rules, “ “[t]he State must provide the Federal Land Manager [FLM] with an opportunity for consultation, in person and at least 60 days prior to holding any pub lic hearing on an implementation plan (or plan revision) for regional haze required by this [Subpart P]”. The purpose of the consultation in person is to allow the a ffected FLM to discuss: (1) The FLM’s “assessment of impairment of visibility in any mandatory Class I Federal area;” and (2) “Recommendations on the development of the reasonable progress goal and on the development and implementation of strategies to address visibility impairment.” [40 CFR §51.308(i)(2)].
The Rules also provides that – “[t]he plan (or plan revision) must provide procedures for continuing consultation betw een the State and Federal Land Manager on the implementation of the visibility protec tion program required by [Subpart P], including development and review of implementation pl an revisions and 5-y ear progress reports,

### and on the implementation of other programs having the potential to contribute to impairment of visibility in mandatory Cla ss I Federal areas.” [40 CFR §51.308(i)(4)].

D. Documentation of Consultation:
Documentation of the consultation process must be included in the Regional Haze SIP submittal. The preamble of the Regional Haze Rules States that “[t]he EPA is requiring States to document their analyses, including any consultations with other States in support of their conclusions....” (64 FR 35721) . Formal consultation, as required by the Regional Haze Rules in 40 CFR Part 51, Subpart P, may be built upon prior, documented informal consultations.
There is a reciprocal and equal obligation by all States to consult with each other. This obligation carries forward into the fu ture at each 10-year comprehensive State implementation plan (SIP) revision milest one. Although there is not an explicit consultation requirement in the regulations fo r developing the 5-year progress reports that all States must submit to EPA between the 10-year revisions, in acting on any deficiencies in the SIP for achieving reasona ble progress, the States must “collaborate” with other States through the regional pl anning process for the purpose of developing additional strategies to addr ess the plan’s deficiencies.

III. Overview of the MANE-VU Inter-RPO Consultation Briefing Book
The primary goal of this Briefing Book is to provide a user-friendly review of MANE-VU’s technical work and analyses inve stigating the nature of the visibility problem, the pollutants and sources contribu ting to the problem, and possible control measures and strategies to improve visibil ity. The book is organized into tabbed sections that will allow MANE-VU Class I States to walk our consul tation partners through these analytical pieces in a systematic manner fr om beginning to end, as well as provide a quick reference for locating information res ponding to specific issues or questions.
Tab 2, “Consultation Overview,” includes a brief explanation of the approach that MANE-VU applied in developing a single “cons ulting group” that encompasses all of the MANE-VU Class I areas. In this tab the reader will also find sample copies of the “intent to consult” letters sent by Maine, New Jersey, New Hampshire and Vermont to the States in the MANE-VU consulting group.
Tab 3, “MANE-VU Class I States’ Resolu tion and Statements,” includes four recently approved actions:

• 

### The first is a Resolution adopted by th e MANE-VU States with Class I areas outlining the set of principles they will follow in implementing the Regional Haze Rules.

• 

### The second is a Statement that lays out a course of action that MANE-VU, as a region, will pursue toward a ssuring reasonable progress.• 

### The third is a Statement that outlines the MANE-VU States’ initial ideas requesting a course of action by States outside of the MANE-VU region to help assure reasonable pr ogress in improving visibili ty at our Class I areas. The course of action described is intended as a starting point for our discussions, and will be examined in li ght of the technical work and findings provided by other States during the Technical Call and the in-person Consultation Meetings.

• 

### The fourth action is a request that MANE-VU is making of the U.S. Environmental Protection Agency to work with the eastern Regional Planning Organizations to develop a national proposal to achieve additional costeffective SO 2 

### reductions.
Tab 4, “Uniform Rate of Progress,” contai ns Power Point slides illustrating the glide path to natural conditions from 2004 to 2064 for each of the MANE-VU Class I areas, using both the EPA default calculati on method for natural conditions and the alternative provided via the new IMPROVE algorithm.
Tab 5, “Pollution Apportionment,” contains a Power Point slide presentation that shows the contribution of vari ous pollutants to visibility extinction on the 20% worst and 20% best days from 2000-2004 at all MANE -VU Class I areas. It also includes a projection of the contribution of these pollutants for 2018.
Tab 6, “BART,” is a section that summa rizes the approach that the MANE-VU States are taking in their BART analyses , including an estimate of the potential reductions from BART-eligible sources in the region and possible ranges of controls and costs for SO2 and NOx.
Tab 7, “Technical Support for Reas onable Progress Goals and Long Term Strategies,” comprises 3 subsections. The fi rst, Tab 7A, provides an overview of the potential sources and control options that MANE-VU examined and summarizes the work done by MANE-VU as part of its “Reas onable Progress Goals Pr oject” and report. The second section, Tab 7B, explains MANE -VU’s approach to developing a set of regional haze control measures for the 2018 milestone, and includes a detailed discussion of how MANE-VU identified the top EGU stack s whose emissions affect visibility at MANE-VU Class I areas. The information in both Tab 7A and Tab 7B supports the second and third actions that are included in Tab 3 of this briefing book. The third section, Tab 7C, contains a summary of MANE-VU’s CAIR+ Report documenting the analysis of the cost of additional SO 2 

### and NO x 

### controls at EGUs in the Eastern U.S., which supports the fourth action incl uded in Tab 3 of the briefing book.
Tab 8, “Summary of Work,” is a list of the references, including websites and other location information, for the techni cal reports and documents supporting MANEVU’s findings and proposed solutions for impr oving visibility at our mandatory Class I federal areas.

### MANE-VU is continuing to develop additional information, and further summaries may be provided for the call or meetings. We recogni ze the importance of modeling results to assess vi sibility impacts in 2018.

IV. Conclusion
The MANE-VU Class I States appreciate the time you are taking to review this material and to participate in the technical call and in-pers on consultation meeting. We look forward to working with you as we es tablish our reasonable progress goals and together adopt and promote long term strategi es that will improve vi sibility in all of our Class I areas.

# Consultation Overview

### MANE-VU Approach to the Development of “Consulting Groups”

On November 1, representatives from each RPO and th e FLMs began a dialogue aimed at identifying groups of Class I areas that might serv e to focus consultations for purposes of the regional haze rule. While it appears that cons ultations will be conducted state-tostate, the RPO representatives agreed that there ma y be a role for the RPO staff in identifying Class I areas with common visibility is sues where a joint consultation process might be more efficient. At this point, the focus of the RPO efforts is to help identify common Class I “consulting groups” and leave it to the states involved in any future joint consultation process to discuss details regarding t he nature and extent of state contributions to a common Class I group. Another role that the RPOs may play in the process is to assist with the scheduling of consult ations so as to ensure that RPOdeveloped technical products would be ready and ava ilable to facilitate state discussions.

The Class I states within the MANE-VU RPO have cons idered the question of how best to group common Class I areas from the perspective of forming consulting groups. After reviewing monitoring and modeling data related to t he sources of visibility impairment for each Class I site, they have proposed an approa ch that would create a single consulting group that encompasses all MANE-VU Class I sites. The “MANE-VU consulting group” would consist of the Acadia Natio nal Park, Maine; Brigantine Wilderness (within the Edwin B. Forsythe National W ildlife Refuge), New Jersey; Great Gulf Wilderness, New Hampshire; Lye Brook Wildernes s, Vermont; Moosehorn Wilderness (within the Moosehorn National Wildlife Refuge), Maine; Presidential Range – Dry River Wilderness, New Hampshire; and Roosevel t Campobello International Park, New Brunswick.
The Class I states of MANE-VU recognize some differ ences between the Brigantine Wilderness and the northern tier of Class I sites i n Vermont, New Hampshire and Maine. However, when viewed from the perspective of contri butions to sulfate pollution – which is still the dominant form of visibility impairment experienced on the twenty percent worst visibility days at all MANE-VU sites – the gr oup found more similarities than differences and felt that a single consulting group representing all MANE-VU sites offered the best opportunity to engage contributing states in a meaningful consultation process. MANE-VU, therefore, proposes the addition of the MA NE-VU consulting group to those already suggested by the Mid-West RPO in their Octo ber 19 memorandum. The revised “Table 1” on the next page reflects the proposed co mposition of the MANE-VU consulting group in a manner similar to that of the October 19 memo for three other proposed consulting groups. The MANE-VU Class I st ates are planning to contact those states listed in the proposed consulting group shor tly to initiate the consultation process.RPO State MI/MN AR/MO/KY VA/WV MANE-VU (BOWA, VOYA, ISRO, SEN) (UPBU, MINGO,

HG, MACA) (DOSO, SHEN, JRIV) (ACAD, MOOS,

GRGU, LYBR, BRIG) MANE-VU Connecticut x Delaware x Maine x Maryland x x Massachusetts x New Hampshire x New Jersey x New York x Pennsylvania x x Rhode Island x Vermont x

VISTAS Alabama Florida Georgia x Kentucky x x Mississippi North Carolina x South Carolina x Tennessee x x Virginia x x West Virginia x x

MRPO Illinois x x x Indiana ? x x Michigan x x Ohio x x Wisconsin x

CENRAP Arkansas x Iowa x Kansas Louisiana Minnesota x Missouri ? x Nebraska Oklahoma Texas

WRAP N. Dakota x S. Dakota Other Western

States

Canada Manitoba New Brunswick x Ontario x x Quebec x Other Provinces

### February 26, 2007

Carl Johnson, Acting Exec. Dep. Commissioner 625 Broadway, 14th Floor Albany, NY 12233-1010
Dear Deputy Commissioner Johnson:
I am writing to request your state participate in the development of Maine’s regional haze programs under Section 169A of the Clean Air Act. Visibility impairment, or regional haze, is caused by fine particle air pollution from many s ources located over a wide region, and is an issue of great importance to both the future of our natio n’s wild places, and to the health of millions throughout the United States. In Maine, and most of the northeast, regional haze is due primarily to emissions of sulfur oxides (SO X 

### ), organic carbon, and nitrogen oxides (NO X 

### ). Regional haze has reduced visibility in the East by as much as 75% from natural conditions, and the same pollutants that are responsible for visibility degr adation also cause a variety of serious health environmental impacts such as cardio-pulmonary disease, and contribute to the acidification of our waters. The national visibility goal, as set forth in Section 169A of the Clean Air Act (CAA), requires ‘‘the prevention of any future, and the remedying of any existing, impairment of visibility in Class I areas which impairment results from man made air pollution.’’ The 156 Class I areas across the country include many well-known nationa l parks and wilderness areas, such as the Grand Canyon National Park in Arizona and Shen andoah National Park in Virginia. Maine is fortunate to be home to three Class I areas: 1) Acadia National Park; 2) Moosehorn National Wildlife Refuge Wilderness Area; and 3) Roosev elt Campobello International Park. States with Class I areas are required to maintain and improve visibility in these areas to eventually achieve natural background conditions by the year 2064.
The federal regional haze rules implementing Sec tion 169A of the CAA require all states, to prepare State Implementation Plans (SIPs) demonstrating that reasonable progress is being made toward meeting the 2064 visibility goals. The fi rst regional haze SIP is due in December 2007, and for Class I states such as Maine, must include reasonable progress goals for 2018 that have been developed in consultation with any othe r state having emissions that are reasonably anticipated to contribute to impairment in any of the State’s Class I areas. 1 

### Future regulations to control air pollutant emissions affecting visibility must be evaluated and included in our regional haze SIPs before setting this first reasonable pr ogress goal. Although future regional haze plans may need to address emissions from a very broad geographic area, for the purposes of this first SIP, we plan to focus our regional haze consulta tion and planning efforts on a number of eastern states. Appendix 1 provides a listing of these states along with technical justification for their inclusion in our first consultation process.

1 

### 40 CFR 51.308 (d) (1) (iv 

### )

### In an effort to better utilize technical resources a nd foster inter-state and inter-agency cooperation in regional haze planning, EPA established a nd is funding Regional Planning Organizations (RPOs). Maine is a member of the Mid-Atlantic Northeast Visibility Union (MANE-VU), which is coordinating plans to reduce regional haze in the Northeast and Mid-Atlantic states. 2 

### During 2007, MANE-VU will be scheduling consultation meetings with the express intent of establishing reasonable progress goals for the Class I areas in the northeastern states. MANE-VU may also be working with other RPOs to which your State belongs (i.e.; the Mid-West RPO or VISTAS).
I am inviting your state to participate in our c onsultation process, and to send a representative to future meetings scheduled through our resp ective Regional Planning Organization. These meetings will provide a forum for discussing th e policy and technical foundations behind the establishment of the first reasonable progress goals for the Class I areas of the northeastern United States, and will greatly facilitate the deve lopment of a coordinated program to address regional haze that will also significant public h ealth benefits in the form of reduced fine particulate (and precursor) emissions. Please send the name, address and telephone number of the appropriate agency contact person to Jeff Cr awford, Maine Department of Environmental Protection, 17 State House Station, Augusta, Maine 04333.
Thank you for considering this request and we look forward to working with you and your staff on this important initiative..

Sincerely,

David P. Littell Commissioner

C:\ James Brooks, ME DEP Jeffrey Crawford, ME DEP Arthur Marin, NESCAUM Susan Weirman, MARAMA Chris Recchia, OTC Sandra Silva, USFWS Tim Allen, USFWS Bruce Polkowsky, USDA, FS Randy Moore, USDA, FS Anne Acheson, USDA, FS Anne Mebane, UDAA, FS Chris Shaver, NPS

2 MANE-VU’s members includ e Connecticut, Delaware, the District of Columbia, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, the Penobscot Nation, the St. Regis Mohawk Tribe, th e U.S. Environmental Protection Agency, the U.S. National Park Service (NPS), the U.S. Fish and Wildlife Service (FWS), and the U.S. Forest Service (USFS).

### Appendix 1
States to be Consulted During the Es tablishment of Maine’s Class I Area 2018 Reasonable Progress Goals

State Technical Justification for Inclusion 3

### MANEVU Member REMSAD Q/D Calpuff NWS Calpuff MM5 % Time Upwind

Connecticut X

Delaware X District of Columbia X

Georgia X Illinois X X X Indiana Kentucky X X X X Maryland X Massachusetts X Michigan X X X X X New Hampshire X
New Jersey X New York X North Carolina X X Ohio X X X X X Pennsylvania X Rhode Island X

Tennessee X Vermont X Virginia X West Virginia X X X X X

3 From the report entitled “Contributions to Regional Haze in the Northeast and Mid-Atlantic United States”, prepared by NESCAUM for the Mid-Atlantic / Northeast Visibility Union (MANE-VU), August 2006.

## The State of New Hampshire 

# NHDES D epartment o f

Environmental Services

Thomas S. Burac k Commissioner

P.O. Box 95, 29 Hazen Drive, Concord, New Hampshire 03302-0095 Telephone: (603) 271-13 70 Fax: (603) 271-1381 TD D Access Relay NH 1-800-735-2964 

### April 4, 2007 Commissioner/Secretary Address City, State, Zip
Dear Commissioner/Secretary,
As you are aware, New Hampshire is home to tw o Class I areas as designated under Section 169A of the U.S. federal Clean Air Act. The Gr eat Gulf and the Presidential Range – Dry River Class I areas are located on the beautiful slopes of Mt. Washington, the highest point in the Northeastern United States. While this area is renowned for having some of the most challenging weather in the world, it also is know n for providing very impressive vistas, that is, when visibility is not impaired by air pollution. Fortunately for those who visit this region and for those who live and work there, the Regiona l Haze rule requires th at these areas and 154 others nationwide gradually impr ove visibility, with a goal of achieving natural conditions by 2064. While this ultimate goal is decades away, we begin today by taking reasonable actions and by partnering in consultation with states and Cana dian provinces, as needed, to begin planning to take the first steps toward meeti ng this goal. I write today becaus e we have identified your state or province as one that needs to be part of our collective solution to regional haze in New Hampshire.
According to the Clean Air Act, all U.S. states must submit State Implementation Plans (SIPs) by December 2007 for regional haze, regardless of wh ether they are home to a Class I area. Under the Act’s section 169A (including regulations at 40 CFR 51.300), the regional haze SIP must demonstrate that reasonable progress will be made at nearby Class I areas at 10-year intervals, beginning in 2018. The regulati ons of 40 CFR 51.308(d)(1)(iv) spec ify that states with Class I areas should develop reasonable progress goals for their Class I areas and associated measures to meet those goals, in consultation with any jurisdic tion that may reasonably cau se or contribute to visibility impairment in those areas. The Fede ral Land Managers for the Class I area are also required to be consulted in this process.
While it is believed by the scientific community th at every U.S. state contributes in some way to air pollution in The Great Gulf and the Presiden tial Range – Dry River Cl ass I areas, we have limited our requests for consultations to only thos e states and Canadian providences that our analyses indicate have the potential for c ontributions over certain thresholds for PM 2.5 

### and/or sulfate to regional haze in our Class I areas. Bey ond this, we are asking all states within our own Regional Planning Organization, th e Mid-Atlantic Northeast – Vi sibility Union (MANE-VU) to consult with us. Because we have asked you to jo in us in consultation does not necessarily imply that we will be asking for ai r pollution contro l beyond measures you may have already identified as necessary for your own state for ozone and PM 2.5 

### ambient air standard attainment. By joining us, you can help us shape our regional haze pr ogress goals for 2018 and help play a part in determining the best way to meet those goals for the New Hampshire Class I areas.

### New Hampshire Request for Regional Haze Consultation

We, or a representative from MANE-VU, will be contacting you soon to arrange a consultation meeting. Thank you for your anticipated particip ation in this consulta tion and we look forward to working with you and your staff. Should you have any questions, please contact Jeff Underhill of my staff at 603-271-1370 (o r email: junderhill@des.state.nh.us).

Sincerely Yours,

Thomas S. Burack Commissioner

Cc: Robert Scott, NHDES Air Resources Division Jeffrey Underhill, NHDES Air Resources Division Anna Garcia, OTC Arthur Marin, NESCAUM Susan Weirman, MARAMAAIR POLLUTION CONTROL DIVISION Building 3 South 103 South Main Street Waterbury, VT 05671-0402

TEL 802-241-3840 FAX 802-241-2590 

### July 17, 2007
Gina McCarthy, Commissioner Connecticut Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127
Dear Commissioner McCarthy:
This letter has two purposes. Its first purpose is to present a brief summary of results of analyses which the State of Vermont , in conjunction with the Regional Planning Or ganization (RPO) MANE-VU, has conducted to fulfill requirements for the protection of visibility in federally managed areas of the United States known as Class I areas (Section 169A of the Clean Air Act). The analyses indicate that sources of visibility impairing air pollutants in the State of Connecticut, though not contributing at a level currently believed to be significant, will require our consultation with you on strategies a ddressing regional haze in the Class I Lye Brook Wilderness area located in Vermont. Its second purpose is to invite you and/or representatives from the department/agency resp onsible in your state for regulatory air matters, to participate in a consultation process to determine an appropriate mitigation strategy for Lye Brook Wilderness. The consultation process will develop a recommendation for the most cost-effective strategy, agreeable to all jurisdictions involved, for implementation of long-term measures and controls which demonstrate that reasonable progress goals for the Class I area, to be established in Vermont’s State Implementation Plan (SIP), will be achieved.
Background:
Environmental Protection Agency (EPA) final regional haze rules promulgated on July 1, 1999 require every state, whether containing a Class I area or not, to develop a SIP d escribing that state’s control commitments (if any) to a long-term strategy for achieving reasonable progress goals (RPGs) in all Class I areas by 2018. 2018 is the end of the first 10 year period in a series of periodic SIP submittals that are required by the rules. The first SIPs under the regional haze rules (40 CFR 51.300) must be submitted to EPA by December 2007. Individual state plans that are developed need to be consistent with each other for them to be effective in achieving the RPGs. The regulations at 40 CFR 51.308 (d) (1) (iv) require a documented consulta tion process between all states involved in any multi-state strategy aimed at achieving the RPGs. This consultation reco rd is one element required in the SIP of any state such as Vermont which contains one or more Class I areas. Th is letter serves to initiate the formal consultation process between our two states regarding the strategies to be incor porated in our state SIPs for submittal in December 2007.
Because the development of an effective strategy for mitig ation of regional haze will be regional in nature, several other states have also been invited to participate in this consultative process to develop a SIP strategy that demonstrates the RPGs for visibility w ill be met in Lye Brook Wilderness Area by 2018. Vermont is a member of

### the Regional Planning Organization MANE-VU which is co mprised of the New England States and New York, New Jersey, Pennsylvania, Delaware, Ma ryland, and the District of Columbia. All other MANE-VU member states are being invited to consult with Vermont on our SIP strategy. In addition, a total of eleven other states outside of MANE-VU have been identified as having a level of im pact on regional haze in the Lye Brook Wilderness area which is considered “significant” for this first round of regional haze SIPs with a 2018 target for RPGs. The attached Table 1 identifies all of the states with which Verm ont believes it must consult during this planning period.
Table 1 summarizes the specific analytical results for each state which lead us to believe sources of haze-causing air pollutants in your state contribute significantly to th e regional haze experienced at Vermont’s Class I area. Over the past three years MANE-VU has conducted a number of studies and used several accepted scientific methodologies to identify the sources of impacts on visibility at all of the Class I areas in the northeast. These have been collected into a technical doc ument entitled “Contributions to Regi onal Haze in the Northeast and MidAtlantic United States” dated August 2006 ( http://manevu.org ). This information will be available along with other technical study results during our consultative process. All MANE-VU states have determined that they will participate in each of the consultation processes for each of the MANE-VU Class I areas. In that context, if your state is a member of MANE-VU, staff from your state w ill already be aware of the consultation that has been ongoing internally through committees and workgroups involved in M ANE-VU RPO planning efforts.
If your state is not a member of MANE-VU, you are also invited and encouraged to send a representative to future consultation meetings which will be scheduled through contacts between our respective RPOs (MANE-VU, VISTAS, MRPO). These meetings will be held over a pe riod of months in the near future. At the meetings, establishment of the 2018 RPGs for each of the Class I areas in the northeastern U.S. will be discussed and strategies intended to achieve the RPGs will be proposed and defined. Please send us the name, address and contact phone number and/or email address of the appropriate person within your organization to contact when details of the first consultation meeting have been finalized.
The Vermont contact for this consultation process is Paul Wishinski, Air Quality Planning Chief for the Vermont Air Pollution Control Division, Phone: 802-241-3862 Fax: 802-241-2590 email: Pa ul.Wishinski@state.vt.us. Please contact him if you have any questions about the regional haze planning consultation process that we are formally proposing with this letter.

Sincerely,

Justin Johnson, Deputy Commissioner Department of Environmental Conservation Vermont Agency of Natural Resources

### TABLE 1
States to be Consulted on Establishing Vermon t’s Class I Area 2018 Reasonable Progress Goals and Strategies for Achieving Them

State Name Primary Haze-Causing Significant Impact (1) 

### and/or Other Reason for Inclusion

Connecticut MANE-VU member Delaware MANE-VU member District of Columbia MANE-VU member Georgia Sources impact > 2% Sulfate Contribution Illinois Sources impact > 2% Sulfate Contribution Indiana Sources impact > 2% Sulfate Contribution Kentucky Sources impact > 2% Sulfate Contribution Maine MANE-VU member Maryland Sources impact > 2% Sulfate Contribution Massachusetts Sources impact > 2% Sulfate Contribution Michigan Sources impact > 2% Sulfate Contribution New Hampshire MANE-VU member New Jersey MANE-VU member New York Sources impact > 2% Sulfate Contribution North Carolina Sources impact > 2% Sulfate Contribution Ohio Sources impact > 2% Sulfate Contribution Pennsylvania Sources impact > 2% Sulfate Contribution Rhode Island MANE-VU member Tennessee Sources impact > 2% Sulfate Contribution Virginia Sources impact > 2% Sulfate Contribution West Virginia Sources impact > 2% Sulfate Contribution Wisconsin Sources impact > 2% Sulfate Contribution

(1) 

### From the report entitled “Contri butions to Regional Haze in the Northeast and Mid-Atlantic United States”, prepared by NESCAUM for the Mid-Atlantic / Northeast Vi sibility Union (MANE-VU), August 2006. The primary criteria Vermont used to identify a state as having a significant impact on Vermont’s Class I area was the modeled base-year 2002 state-wi de sulfur oxide emission impacts on the ambient sulfate levels predicted at receptor s in the Class I area. Any state wi th a modeled annual average sulfate ion impact greater than 2% of all modeled sulfate ion impacts was considered to have “significant impacts” for purposes of consultation on long-term strategies and reasonable progress goals.

# MANE-VU Class I States’ Resolution and MANE-VU Statements

# Uniform Rate of Progress

## Contributions to PM 2.5 

## Mass at 7 Sites 20% Worst Visibility Days (2000-2004)

# # # #

# #

#

Dolly Sods Shenandoah Brigantine Lye Brook Great Gulf Acadia Moosehorn

0 5 10 15 20 Soil Sea Salt OC EC Nitrate SulfateMass (ug/m3)

# # # #

# #

# 

## Contributions to PM 2.5 

## 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 1Extinction (Mm-1)

Dolly Sods Shenandoah Brigantine Lye Brook Great Gulf Acadia Moosehorn

### Shenandoah Glide Path to Natural Conditions 2004-2064

SHEN1

0 5 10 15 20 25 30 351990-19941992-19961994-19971996-20001999-20022000-2004200920142019202420292034203920442049205420592064Deciviews (dv)

Default 5-Year Average 20% Worst Alternative 5-Year Average 20% Worst Default Glide Path Alternative Glide Path Default Natural Conditions Alternative Natural Conditions



### Dolly Sods Glide Path to Natural Conditions 2004-2064

DOSO1

0 5 10 15 20 25 30 351994-19981996-20001998-20022000-2004200920142019202420292034203920442049205420592064Deciviews (dv)

Default 5-Year Average 20% Worst Alternative 5-Year Average 20% Worst Default Glide Path Alternative Glide Path Default Natural Conditons Alternative Natural Conditions

### Brigantine Glide Path to Natural Conditions 2004-2064

BRIG1

0 5 10 15 20 25 30 351993-19981996-20001998-20022000-2004200920142019202420292034203920442049205420592064

Default 5-Year Average 20% Worst Alternative 5-Year Average 20% Worst Default Glide Path Alternative Glide Path Default Natural Conditons Alternative Natural Conditions



### Lye Brook Glide Path to Natural Conditions 2004-2064

LYBR1

0 5 10 15 20 25 301993-19981996-20001998-20022000-2004200920142019202420292034203920442049205420592064Deciviews (dv)

Default 5-Year Average 20% Worst Alternative 5-Year Average 20% Worst Default Glide Path Alternative Glide Path Default Natural Conditions Alternative Natural Conditions

### Great Gulf Glide Path to Natural Conditions 2004-2064

GRGU1

0 5 10 15 20 25 302001200220032004200920142019202420292034203920442049205420592064Deciviews (dv)

Default 5-Year Average 20% Worst Alternative 5-Year Average 20% Worst Default Glide Path Alternative Glide Path Default Natural Conditions Alternative Natural Conditions



### Acadia Glide Path to Natural Conditions 2004-2064

ACAD1

0 5 10 15 20 25 301990-19941992-19961994-19981996-20001998-20022000-2004200920142019202420292034203920442049205420592064Deciviews (dv)

Default 5-Year Average 20% Worst Alternative 5-Year Average 20% Worst Default Glide Path Alternative Glide Path Default Natural Conditions Alternative Natural Conditons

### Moosehorn Glide Path to Natural Conditions 2004-2064

MOOS1

0 5 10 15 20 251995-19981996-20001998-20022000-2004200920142019202420292034203920442049205420592064Deciviews (dv)

Default 5-Year Average 20% Worst Alternative 5-Year Average 20% Worst Default Glide Path Alternative Glide Path Default Natural Conditions Alternative Natural Conditions

Acadia

Moosehorn Lye Brook Great Gulf Dolly Sods Brigantine

Shenandoah 

## 2000-2004 Worst 20% Days Mass Contribution (New Algorithm)

ammSO4f:VAL ammNO3f:VAL OMC1.8:VAL ECf:VAL SOILf:VAL CM_calculated:VAL SeaSalt:VALAcadia

Moosehorn Lye Brook Great Gulf Dolly Sods Brigantine

Shenandoah 

## 2000-2004 Worst 20% Days Extinction Contribution (New Algorithm)

ammSO4f_bext:VAL ammNO3f_bext:VAL OMCf_bext:VAL ECf_bext:VAL SOILf_bext:VAL CM_bext:VAL SeaSalt_bext:VAL

Acadia

Moosehorn Lye Brook Great Gulf Dolly Sods Brigantine

Shenandoah 

## 2000-2004 Best 20% Days Mass Contribution (New Algorithm)

ammSO4f:VAL ammNO3f:VAL OMC1.8:VAL ECf:VAL SOILf:VAL CM_calculated:VAL SeaSalt:VALAcadia

Moosehorn Lye Brook Great Gulf Dolly Sods Brigantine

Shenandoah 

## 2000-2004 Best 20% Days Extinction Contribution (New Algorithm)

ammSO4f_bext:VAL ammNO3f_bext:VAL OMCf_bext:VAL ECf_bext:VAL SOILf_bext:VAL CM_bext:VAL SeaSalt_bext:VAL



## Projected Mass Reductions 20 Percent Worst Sulfate Reductions

0 2 4 6 8 10 12 14 16

D

o l l y S

o d

s

S h

e n a n d

o a h

B r i g a n t i n e
L y e B

r o o k
G r e a t G

u l f A c a d i a M o o s e h

o r nMass (μg/m3) Baseline (2000-04) 2009 201818.0 19.0 20.0 21.0 22.0 23.0 24.0 25.0 26.0

2002 2004 2006 2008 2010 2012 2014 2016 2018 2020Deciview Acadia Acad BOTW_BaseB4 Great Gulf GrGu BOTW_BaseB4 Lye Brook LyeB BOTW_BaseB4 Moosehorn Moos BOTW_BaseB4 

## Relative mass reductions applied to visibility metric for New England sites

22.0 23.0 24.0 25.0 26.0 27.0 28.0 29.0 30.0

2002 2004 2006 2008 2010 2012 2014 2016 2018 2020Deciview Brigantine Dolly Sods Shenandoah Brig BOTW_BaseB4 Dolly BOTW_BaseB4 Shen BOTW_BaseB4 

## Relative mass reductions applied to visibility metric for Mid-Atlantic sites

# Pollution Apportionment

# 2002 Sulfate Attribution

Contribution Thresholds Determined Three Ways

• Method 1 : States/regions that contribute 0.1 ug/m3 sulfate or greater on 20% worst visibility days • Method 2 : States/regions that contribute at least 2% of total sulfate observed on 20% worst visibility days • Method 3 : Top ten contributing states on 20% worst visibility days0% 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 

# Shenandoah

20% Worst Days

IMPROVE mass 00-04 Threshold options 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 States

REMSAD 2002 Contribution to Sulfate # # #μg/m3

0 5 10 15 20 25

Shenandoah

Sulfate Nitrate EC OC Sea Salt Soil

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Dolly Sods CANADA CENRAP SE_BC W_BC N_BC RI VT ME DC CT NH MA MS DE NJ WI MI NY SC MD AL IL VA TN GA NC IN KY PA WV OH 

# Dolly Sods 20% Worst Days 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfate # #μg/m3

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%

Brigantine CANADA CENRAP SE_BC W_BC N_BC VT RI ME DC MS CT NH MA WI AL NY IL SC MI TN KY NJ IN DE GA WV VA NC MD OH PA 

# Brigantine 20% Worst Days 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfateμg/m3 #

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%

Lye Brook CANADA CENRAP SE_BC W_BC N_BC DC RI MS ME CT VT NH WI DE SC MA AL IL NJ TN GA MI KY VA IN NC MD WV NY OH PA 

# Lye Brook 20% Worst Days 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfateμg/m3

# #

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%

Acadia CANADA CENRAP SE_BC W_BC N_BC DC MS VT RI AL DE WI CT TN SC GA NJ VA IL KY MD MI NC NH IN WV ME NY PA OH MA 

# Acadia 20% Worst Days 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfateμg/m3

0 2 4 6 8 10 12 14

Acadia

Sulfate Nitrate EC OC Sea Salt Soil # # #

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Moosehorn CANADA CENRAP SE_BC W_BC N_BC MS DC VT RI AL CT WI DE TN SC NJ GA IL MI VA KY NH MD NC IN WV NY ME OH PA MA 

# Moosehorn

20% Worst Days 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 Threshold options REMSAD 2002 Contribution to Sulfateμg/m3

# #

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%

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 KY NH NC MI WV MA IN NY PA OH 

# Great Gulf 20% Worst Days

IMPROVE mass 01-04 Threshold options REMSAD 2002 Contribution to Sulfate 0.1 μg/m 3 Sulfate

2 % of Sulfate

Top 10 Statesμg/m3

# #

0 2 4 6 8 10 12 14

Great Gulf

Sulfate Nitrate EC OC Sea Salt Soil #



# 2002/2018 Sulfate Attribution0 5 10 15 20 25

Shenandoah

Sulfate Nitrate EC OC Sea Salt Soil 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

2002 2018 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 

# Shenandoah

20% Worst Days

IMPROVE mass 00-04 REMSAD Contribution to Sulfateμg/m3

0 5 10 15 20 25

Shenandoah

Sulfate Nitrate EC OC Sea Salt Soil CMAQ RRF-Based 2018 Mass

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%

2002 2018 CANADA CENRAP SE_BC W_BC N_BC RI VT ME DC CT NH MA MS DE NJ WI MI NY SC MD AL IL VA TN GA NC IN KY PA WV OH 

# Dolly Sods 20% Worst Daysμg/m3

0 2 4 6 8 10 12 14 16 18 20

Dolly Sods

Sulfate Nitrate EC OC Sea Salt Soil
IMPROVE mass 00-04 REMSAD Contribution to Sulfate CMAQ RRF-Based 2018 Mass0 5 10 15 20 25

Brigantine

Sulfate Nitrate EC OC Sea Salt Soil 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

2002 2018 CANADA CENRAP SE_BC W_BC N_BC VT RI ME DC MS CT NH MA WI AL NY IL SC MI TN KY NJ IN DE GA WV VA NC MD OH PA 

# Brigantine 20% Worst Days

IMPROVE mass 00-04 REMSAD Contribution to Sulfateμg/m3

0 5 10 15 20 25

Brigantine

Sulfate Nitrate EC OC Sea Salt Soil CMAQ RRF-Based 2018 Mass

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%

2002 2018 CANADA CENRAP SE_BC W_BC N_BC DC RI MS ME CT VT NH WI DE SC MA AL IL NJ TN GA MI KY VA IN NC MD WV NY OH PA 

# Lye Brook 20% Worst Daysμg/m3

0 2 4 6 8 10 12 14 16

Lye Brook

Sulfate Nitrate EC OC Sea Salt Soil

IMPROVE mass 00-04 REMSAD Contribution to Sulfate CMAQ RRF-Based 2018 Mass0 2 4 6 8 10 12 14

Acadia

Sulfate Nitrate EC OC Sea Salt Soil 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

2002 2018 CANADA CENRAP SE_BC W_BC N_BC DC MS VT RI AL DE WI CT TN SC GA NJ VA IL KY MD MI NC NH IN WV ME NY PA OH MA 

# Acadia 20% Worst Daysμg/m3

0 2 4 6 8 10 12 14

Acadia

Sulfate Nitrate EC OC Sea Salt Soil
IMPROVE mass 00-04 REMSAD Contribution to Sulfate CMAQ RRF-Based 2018 Mass

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%

2002 2018 CANADA CENRAP SE_BC W_BC N_BC MS DC VT RI AL CT WI DE TN SC NJ GA IL MI VA KY NH MD NC IN WV NY ME OH PA MA 

# Moosehorn

20% Worst Daysμg/m3

0 2 4 6 8 10 12

Moosehorn

Sulfate Nitrate EC OC Sea Salt Soil

IMPROVE mass 00-04 REMSAD Contribution to Sulfate CMAQ RRF-Based 2018 Mass0 2 4 6 8 10 12 14

Great Gulf

Sulfate Nitrate EC OC Sea Salt Soil 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

2002 2018 CANADA CENRAP SE_BC W_BC N_BC DC MS VT RI ME CT DE AL NJ WI SC TN VA IL MD GA KY NH NC MI WV MA IN NY PA OH 

# Great Gulf 20% Worst Daysμg/m3

0 2 4 6 8 10 12 14

Great Gulf

Sulfate Nitrate EC OC Sea Salt Soil

IMPROVE mass 00-04 REMSAD Contribution to Sulfate CMAQ RRF-Based 2018 Mass



# States Contributing to >2% Sulfate REMSAD 2002 vs. 2018

#



### 2002 2018 Acadia

# 

### Great Gulf

2002 2018 # #

# States Contributing to >2% Sulfate REMSAD 2002 vs. 2018

2002 2018 Moosehorn

Lye Brook

2002 2018 #

# #

#



# States Contributing to >2% Sulfate REMSAD 2002 vs. 2018

2002 2018 Shenandoah

Brigantine

2002 2018 #

# #

#

# States Contributing to >2% Sulfate REMSAD 2002 vs. 2018

2002 2018 Dolly Sods

# #



### 2002 2018 Any MV Site
#

# #

# # #

# #

# #

# BART

### MANE-VU Approach to BART
BART-Eligible Source Identification

• MANE-VU developed preliminary list of BART-eligible EGUs based on review of Clean Air Markets Division databases ( A Basis for Control of BART-Eligible Sources ; http://www.nescaum.org/documents/a-bas is-for-control-of-bart-eligiblesources/ ).

• MANE-VU developed preliminary list of BART-eligible non-EGUs based on review of state permit files ( Development of a list of BART-eligible sources in the MANE-VU region ; http://www.nescaum.org/documents/memo6-bart.pdf/ ).

• States reviewed preliminary lists and have developed their own final list of BART eligible sources
‘Subject’ to BART

• MANE-VU developed a preliminary demons tration that broad regions of the Eastern U.S. were likely to cont ribute to Baseline Regional Haze ( A Basis for Control of BART-Eligible Sources ; http://www.nescaum.org/documents/a-basisfor-control-of-bart-eligible-sources/ ).

• MANE-VU refined and finalized an assessm ent of contributing sources to sulfate in the Eastern U.S. in their contribution assessment report ( Contributions to Regional Haze in the Northeas t and Mid-Atlantic United States ; http://www.nescaum.org/documents/cont ributions-to-regional-haze-in-thenortheast-and-mid-atla ntic--united-states/ )

• In 2004, the MANE-VU Board adopted the approach proposed by EPA that allowed states to find all MANE-VU BART -eligible sources “subject” to BART supported by findings in the preceding two reports that emissions from all MANE-VU states contribute some degree of visibility impairment in Class I areas. (No exemption modeling was conducted)

BART Determinations

• MANE-VU conducted a control technology a ssessment for four primary source categories that were most common in our region. This report focused on available control options and costs for EGUs, Industr ial Boilers, Paper and Pulp facilities and Cement Plants. (Assessment of Control Technology Options for BARTEligible Sources ; http://www.nescaum.org/documents/bart-controlassessment.pdf/ ).

• MANE-VU coordinated and surveyed a wo rking group of state staff focused on BART issues. Out of this survey process, MANE-VU identified potential BART control options for several BART eligible sources across the region. This information was synthesized to develop a regional “first-order” five-factor analysis to guide states as they devel op their own five-factor analysis for BARTeligible sources in their state. ( Five Factor Analysis of BART-Eligible Sources ; http://www.nescaum.org/documents/bart-memo-02-09-07.pdf/ ). This report provides a suggested approach for consider ing each of the five statutory BART factors including the degree of visibil ity improvement that may result from installation of controls. For this factor it was suggested that a weight be given

### such that no additional controls would be warranted for any source that has a current annual average contribution to visi bility impairment at any Class I area of less than 0.1 delta deciview during 2002.

• Primary findings from this analysis are shown in the figure below and three attached tables. The analysis suggests th at the majority of BART-eligible sources either do not warrant additional controls base d on cost or visibility considerations or are being controlled already under othe r programs (e.g. CAIR) and that these controls will serve as BART.

Figure 1: Potential Reductions from BART-Eligible Sources in the MANE-VU Region

Note: “No Expected BART-Based Controls” implies that the eligible units at that source either do not warrant additional controls based on cost or visibility considerations or are being controlled already under other programs (e.g. CAIR) and that these controls will serve as BART.

### Table 1. Possible range of SO 2 

### controls and costs based on survey of state staff

Type of Source Number of Sources Control Strategies Number of Emission Units Control Strategy May Apply Total 2002 SO 2 Emissions Total Estimated Decrease in SO 2 (tons/yr) Estimated Cost ($/Ton SO2) Notes SO2 Scrubber 1 24000 9600 400-8000 Mid Range (1) Chemical Manufacturer 3 Currently Controlled 2 80 NA 0 Glass Fiber 6 Currently Controlled 6 17 0 0 Coal Cleaning 1 No Known Further Controls 1 68 0 0

Dry Scrubber 4 58000 52600 200-500 Mid Range, assume 90% scrubber efficiency EGU/Coal 5 0.33 lb/MMBtu 1 4000 1200 NA

0.3% fuel sulfur limit 3 1400 340 0 Switch to 0.3% has already occurred

for 3 boilers. 0.56 lb/MMBtu 1 85 NA NA 2.0 % Fuel Sulfur Limit 1 600 300 NA 1.5% Fuel Sulfur Limit 1 5200 1300 NA 0.33 lb/MMBtu 1 4000 3100 NA

3.0 lb/MWh 5 31000 NA NA 1.1-1.2 lb/MMBtu 2 480 NA NA EGU/Oil (Resid and Dist) 17 Currently Controlled 3 1200 0 0 Incinerator 2 Currently Controlled 2 84 0 0 No Further Controls Warranted 5 2200 0 0

Metal Production 7 Increased efficiency of the facility's wet scrubber 2 3000 300 Limited Cost Low Range FGD (SO 2 Scrubber) 3 13000 11000 400-8000 Mid Range (1) 1.8% Fuel Oil 2 6050 3000 NA 2.0% Fuel Oil 1 2800 1400 NA
No Known further controls 3 10000 0 0 Paper and Pulp 30 Currently Controlled 21 4000 0 0 Fuel switching: CE of SOx 10% 3 2300 230 NA
No Further Controls Warranted 5 3700 0 0
No Known Further Controls 7 300 0 0 Portland Cement 25 SO 2 Scrubber 10 26000 19000 400-8000 Mid Range (1) Refinery RACT 9 5400 NA 0 SO2 Scrubber 3 NA NA 400-8000 Mid Range (1)

Refinery 37 No Known Further Controls 25 NA NA 0 (1) Cost estimate from NESCAUM, 2005 for Industrial Boilers NA- No information currently available.

### Table2. Possible range of NO X 

### controls and costs based on survey of state staff

Type of Source Number of Sources Control Strategies Number of Emission Units Control Strategy May Apply Total 2002 NO x Emissions Total Estimated Decrease in NO x (tons/yr) Estimated Cost ($/Ton NO x ) Notes SCR 1 4900 3400 1300-10000 (2) Chemical Manufacturer 3 Currently Controlled 2 5000 0 0

Glass Fiber 6 Currently Controlled 6 180 0 0
Coal Cleaning 1 Low NOx burners, CE of 15% 1 160 25 1-2 Million (capital cost) Low Range Currently Controlled 2 2900 820 0 SCR and 1.5

lb/MWh 2 9800 NA 1000-1500 Mid Range (1)

EGU/Coal 5 NOx Budget & 1.5 #/MWh 1 2300 NA NA Currently Controlled 6 3200 0 0 No Known Controls 3 390 0 0 NOx Budget 3 700 NA NA NOx Budget and

1.5 lb/MWh 4 5300 NA NA EGU/Oil 17 SNCR, 1.5 lb/MWh 1 2400 NA 500-700 Mid Range (1)

Incinerator 1 Currently Controlled 2 720 0 NA

2 Currently Controlled 2 0 0 0 Metal Production 5 No Further Controls Warranted 5 110 0 0

SCR or SNCR 2 710 430 1300-10000 Mid to High Range (2) No Known Further Controls 13 4500 0 0 Paper and Pulp 30 Currently Controlled 15 4600 0 0 Low NOx burners 3 2800 430 200-3000 Mid Range Low NO x Burners and Mid Kiln Firing,

40% Reduction 2 8500 3400 1200-10000 Mid Range (2) SCR, 65% Red. 1 740 480 1300-10000 (2) No Known Further Controls 9 2000 0 0 Currently Controlled 1 1700 0 0 Portland Cement 25 SNCR 9 7100 2900 900-1200 Mid Range Refinery RACT 9 2300 NA NA No Known Further Controls 25 0 0 0

SCR 2 460 40 1300-10000 (2) Refinery 37 SNCR 1 1000 560 1300-10000 (2) (1) Cost estimate from NESCAUM, 2005, EGU controls (2) Cost estimate from NESCAUM 2005, Industrial Boiler controls NA- No information currently available.

### Table 3. Possible range of PM 10 

### controls and costs based on survey of state staff

Type of Source Number of Sources Control Strategies Number of Emission Units Control Strategy May Apply Total 2002 PM 10 Emissions Total Estimated Decrease in PM 10 (tons/yr) Estimated Cost ($/Ton PM 10 ) Notes Chemical Manufacturer 3 Currently Controlled 3 200 0 0
Coal Cleaning 1 No Known Further Controls 1 46 0 0 Currently Controlled ESP 7 2000 0 0 PM co-benefit

reductions expected due to

FGD-25-50%

reduction 2 1500 370 0 EGU/Coal 10 Baghouse 1 1500 NA $50 M Capital Cost

EGU/Natural Gas 2 Controls information included with oil/coal boilers 2 13 NA NA

Currently Controlled 13 410 42 0

EGU/Oil 18 No Known Further Controls 5 50 0 0

Incinerator 2 Currently Controlled Fabric Filter 2 0 0 0

Glass Fiber 6 Currently Controlled 6 190 0 0

Metal Production 7 Currently Controlled 7 41 0 0 Upgrade from ESP to baghouse, CE of 4% estimate 2 180 7 $15 M Capital Cost No Known Further Controls 7 280 0 0 Currently Controlled (ESP, Venturi Scrubbers, Demister, or MultiCyclones) 9 690 0 0 Paper and Pulp 30 Current Controls 7 670 0 NA Upgrade on current

ESP, CE of 5% 3 210 11 Limited Cost No Known Further Controls 15 300 0 0 Currently Controlled 6 370 0 0

Portland Cement 25 Baghouse or electric precipitator 1 4 NA NA
No Known Further Controls 28 NA 0 0 Refinery 37 Refinery RACT 9 270 NA NA NA- No information currently available.

# Technical Support for Reasonable Progress Goals and Long-Term Strategies

### Technical Support for MANE-VU Statements-Control Option AssessmentFocus on SO 2



### • MANE-VU has conducted a contribution asse ssment and developed a conceptual model that indicates that the dominant cont ributor to visibility impairment at all sites during all seasons is particulate sulfate form ed from emissions of SO 2 

### . While other pollutants, including organic car bon, need to be addressed in order to achieve the national visibility goals, our technical assessments suggest that an early emphasis on SO 2 

### will yield the greatest near-term benefit. See Figure 1

. • Source region for SO 2 

### emissions is generally south and west (upwind) of MANEVU Class I areas on worst visibility days.

• Wood combustion near Class I areas cont ributes to organic carbon. This component of fine particle pollution also contributes to visibility impairment and is observed at MANE-VU sites. Figure 1: Contribution of Sulfur to Visibility Impairment in the Eastern U.S. on 20% Worst Days

# # # #

# #

#



### Soil Sea Salt OC EC Nitrate Sulfate 0 20 40 60 80 100 120 140 160 180

1 1 1 1 1Extinction (Mm-1)



### Dolly Sods Shenandoah Brigantine Lye Brook Great Gulf Acadia Moosehorn

# # # #

# #

#



### Soil Sea Salt OC EC Nitrate Sulfate 0 20 40 60 80 100 120 140 160 180

1 1 1 1 1Extinction (Mm-1)

0 20 40 60 80 100 120 140 160 180

1 1 1 1 1Extinction (Mm-1)



### Dolly Sods Shenandoah Brigantine Lye Brook Great Gulf Acadia Moosehorn

### Inventory Analysis

• By 2018, implementation of CAIR is pr ojected to reduce 1.3 million tons of MANE-VU SO 2 

### emissions annually. Relative to our current 2002 total of 1.6 million tons per year in the power sect or, this represents a very significant reduction of over 80% of power sector emissions in the MANE-VU region.

• By contrast, non-EGU SO 2 

### emissions are projected to be reduced by federal programs (primarily through on-road and non -road fuel standards) in the MANEVU region by only 24,000 tons. This would bring our current SO 2 

### emissions of 667,000 tons per year down to appr oximately 643,000 tons per year.

• Significant opportunities remain to furt her reduce the projected remaining 312,000 tons of annual EGU SO 2 

### emissions as well as the 643,000 tons of annual non-EGU SO 2 

### emissions. See Figure 2

.

EGUs

• MANE-VU remains interested in CAIR+ for SO 2 

### as a means of achieving PM 2.5 

### NAAQS compliance and furthering regional haze progress in a reasonable (costeffective) way.

• The MANE-VU four-factor analysis has identified several large EGUs (both within and outside MANE-VU) with significant impact on MANE-VU Class I visibility during 2002. Control options fo r these sources are being considered.

Non-EGU SO 2



### • The 643,000 tons in non-EGU SO 2 

### emissions can be broken down into the following categories: Industrial Boiler s (156,000 tons), Other oil combustion sources (206,000 tons), Other non-oil point sources (includes many BART emissions reduction candidates; 106,000 tons), Other area sources (100,000 tons), and other mobile sources (74,000 tons). See Figure 3

.

Figure 2: Potential Reduction Oppo rtunities in the MANE-VU Region

667,000 Tons 1,628,000 Tons

Electric Generation Units Non-EGU 643,000 Tons 24,000 Tons

312,000 Tons 1,316,000

Tons

2018 EGU CAIR reductions Fed Fuel measure reductions 2018 Non-EGU CAIR will eliminate these emissions! Federal fuel measures will eliminate these

643,000 Tons 24,000 Tons

312,000 Tons 1,316,000

Tons

2018 EGU CAIR reductions Fed Fuel measure reductions 2018 Non-EGU CAIR will eliminate these emissions! Federal fuel measures will eliminate these



### 2002 Emissions 2018 Emissions

### • Coal burning industrial boilers have non- FGD control options including Hydrate Boiler Injection, and Lime Slurry Duct Injection. These methods have been shown to achieve between 20 and 60 per cent and 35 to 90+ pe rcent control at reasonable costs in the range of $500 to $1000 per ton of SO 2 

### removed. A conservative assumption of 50% control could achieve a 40,500 ton reduction.

• Limits on the fuel-sulfur content of oil-bu rning industrial boiler s could also yield reductions on the order of 50% from th is category by requiring the use of 0.5 percent S residual oil. Such a stra tegy might yield a 19,000 ton reduction.

• Low-sulfur fuel requirements would offe r significant additional reduction from non-EGU, non-industrial boiler sources. Requiring 500 and/or 15 ppm distillate (relative to current 2000+ ppm baseline) could result in between 140,000 and 167,000 tons of SO 2 

### reduction annually.

• The use of 0.5 percent (5000 ppm) residual o il (relative to curren t residual oil that has sulfur content of 1 per cent or higher) could result in ~19,000 tons reduction.

• Preliminary findings from our BART an alysis suggest additional emissions reduction potential in the 35,000 ton range from several MANE-VU BARTeligible sources.

• The combined emission reduction of all thes e measures would result in nearly a 40 percent reduction in SO 2 

### emissions from the non-EGU sources in MANE-VU relative to projected 2018 levels. See Figure 4

. • The MANE-VU four-factor analysis has identified several la rge non-EGUs (both within and outside MANE-VU) with significant impact on MANE-VU Class I visibility during 2002. Control options fo r these sources are being considered.

Figure 3: 2018 Projected Non-EGU SO 2 

### Emissions in the MANE-VU Region

0 100000 200000 300000 400000 500000 600000 700000

Coal Oil Other Distillate Residual

Industrial Boilers= 156,000 Tons Non EGU, Non Ind. Oil Combustion= 206,000 Tons Other Point Source Emissions = 106,000 Tons (includes many BART Sources) Other Area Source Emissions = 100,000 Tons Mobile Source Emissions = 74,000 Tons

### Long-term Emissions Manage ment Options for MANE-VU MANE-VU is considering (1) a CAIR+ EGU program for SO 2 

### , (2) measures to reduce non-EGU emissions in MANE-VU by up to 40 percent or 250,000 tons of SO 2 

### , and (3) programs to reduce wood combustion -related emissions in MANE-VU. Figure 4: 2018 Potential Non-EGU SO 2 

### Emission Reductions in the MANE-VU Region

0 100000 200000 300000 400000 500000 600000 700000



### Coal Oil Other Distillate Residual

Industrial Boilers Fuels Other Point Sources Other Area Sources Mobile

Other Area Sources Mobile

Coal Oil Other Residual Distillate Post-BART Point



### 2018 Projection 2018 Potential

## MANE-VU Reasonable Pr ogress Project Summary

PURPOSE
The Clean Air Act requires states to consider the following four factors to determine which emission control measures are needed to make reasonable progress in improving visibility: 1) costs of compliance, 2) time necessary for compliance, 3) energy and non-air quality environmental impacts of compliance, and 4) remaining useful life of any ex isting source subject to such requirements. The plan must include reasonable measures and identify the visibility improvement that will result from those measures (i.e., the reasonable progress goal).
EPA issued draft guidance for implementing the reas onable progress requirement (dated 11/28/2005). The guidance recommends the following process for de veloping reasonable progr ess goals: 1) identify pollutants and associated source cate gories affecting visibility in Clas s I areas, 2) list possible control measures for these pollutants and source categories, 3) apply the four statutory factors to each control measure for each source category, and 4) assess th e visibility improvement resulting from various combinations of strategies and sele ct the Reasonable Progress Goals.
MANE-VU has developed information about the pollu tants and sources affec ting visibility and has developed a list of possible control measures for c onsideration. In order to assist MANE-VU in applying the four statutory fact ors, in January 2007, MARAMA signed a contract with MACTEC Federal Programs Inc., to prepare a technical su pport document. The report MACTEC is preparing under this project summarizes MANE -VU’s assessment of pollutants and associated source categories affecting visibility in Class I ar eas in and near MANE-VU, lists pos sible control measures for those pollutants and source categories, and develops the requisite four factor analysis. NESCAUM will assist MANE-VU by conducting air qua lity and visibility modeling to address the fourth step of the process described in EPA’s guidance.

POLLUTANTS AND SOURCE CATEGOR IES AFFECTING VISIBILITY
What Pollutants Affect Visibility? The MANE-VU Contribution Assessment (NESCAUM 2006) and the MANE-VU Conceptual Model for Fine Particles and Regional Haze Air Quality Problems (NESCAUM 2006) identify sulfate as the largest contributor to visibility impairment in Mi d-Atlantic and Northeastern Class I areas. Organic carbon is typically the second-la rgest contributor to regional haze in the MANE-VU region.
What are the Major Source Categories of these Pollutants? The largest source category of su lfur dioxide in the region is el ectric generating units (EGUs). Additional SO 2 

### source categories analyzed include oil-fired installations at residential, commercial, institutional, or industrial facilities; industrial, co mmercial, and institutional (ICI) boilers; and cement and lime kilns.

### According to Appendix B of the MANE- VU Contribution Assessment (NESCAUM 2006), woodsmoke also contributes to visibility impairment, with contributions typically higher in rural areas than urban areas, winter peaks in northern areas from residential wood burni ng, and occasional large summer impacts at all sites fr om wildfires. The MANE-VU Technical Support Document on Agricultural and Forestry Smoke Management in the MANE-VU Region concluded that fire from land management activities was not a major contributor to regional haze in MANE-VU Class I areas, and that the majority of emissions from fire s were from residential wood combustion.
Based on available information, the MANE- VU Reasonable Progress Workgroup selected the following source categories for analysis:

• 

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

• 

### Point and area source industrial, commercial and institutional boilers;

• 

### Cement kilns;

• 

### Lime kilns;

• 

### The use of heating oil; and

• 

### Residential wood combustion and open burning.

WHERE DO THESE POLLU TANTS ORIGINATE?
Specific EGUs are Important Roughly 70% of the 2.3 million tons of SO 2 

### emission in the 2002 MANE-VU emissions inventory (2002 MANE-VU Emission Inventory Version 3) we re from EGUs, making them the largest SO 2 

### source category in terms of visibility impairing emissions. Figure 1 shows the locations of 34 EGU stacks that have impacts on at least one Class I area in MANE-VU or Shenandoah (a nearby Class I area). Many of these EGUs are in MANE -VU but some are outside of the region.

Figure 1: Key EGUs affecting Class I area(s) (Moosehorn, Acadia, Great Gulf, Lye Brook, or Shenandoah) Note: There are 34 EGUs represente d by the circles, but these are lo cated at 26 distinct facilities

Class I Areas Top 15 EGUs affecting Shenandoah only (4 stacks at 3 facilities) Top 15 EGUs affecting any MANE-VU Class I area (30 stacks at 23 facilities)

### Wood Smoke is More Local in Origin Figure 2 is from Appendix B of the MANE- VU Contribution Assessment (NESCAUM 2006) and represents the results of source appo rtionment and trajectory analyses. It illustrates that the impacts of woodsmoke on MANE-VU Class I areas are more like ly due to emissions from within MANE-VU and Canada. The green highlighted se ction of the map shows the woods moke source region for several MANE-VU Class I areas represented by the green stars. (Brigantine was not analyzed for this map.)

Figure 2: Woodsmoke Source Regional Aggregations

Defining the Area of Influence In order to identify states where emissions are most likely to influence visibi lity in MANE-VU Class I areas, analyses such as represente d in Figure 1 and 2 above as well as other analyses documented in the MANE-VU Contribution Assessment were considered.
The MANE-VU States concluded that it was appropriate to include in the area of influence all of the states participating in MANE-VU pl us other states that modeling show ed contributed at least 2% of the sulfate ion at MANE-VU Class I areas in 2002.
Figure 3 shows for Acadia, Brigantine, Lye Brook, a nd Great Gulf the modeled percent of sulfate ion impact from specific states. The stat e with the largest individual sulfat e impact at that Class I area is shown at the bottom of the bar and the list to the right . The size of the bar sli ce is proportional to the modeled impact (using the REMSAD m odel). The percentages at the left of the bar refer to the percent of SO 4 

### impact within the modeling domain. Each of the states at and below the arrow contributes more than 2% of modeled sulfate ion to that Class I area.

### POTENTIAL CONTROL MEASURES AND FOUR FACTOR ANALYSIS

In consultation with the MANE-VU Reasonable Progress Workgroup, MACTEC has developed a report that identifies potential control measures and assesses costs, time needed for compliance, energy and non-air quality impacts, and the remaining usef ul life of affected sources. Table 1 presents a summary of the four factor analysis for the source categories analyzed; more detailed information is available in the draft final report document, which may be found on MARAMA’s website at http://www.marama.org/visibility/RPG/index.html Figure 3: States Contributing to Sulfate in MANE-VU in 2002

0 % 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

A c a d ia CA NA DA CENRA P SE_BC W _BC N_BC D C M S V T R I A L D E W I C T T N G A S C N J V A IL K Y M D M I N C N H IN W V M E N Y P A O H M A Acadia

0 % 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Lye Brook CA NA DA CENRA P SE_BC W_BC N_BC D C R I M S M E C T V T N H W I D E S C A L N J IL M A T N G A M I K Y V A IN N C M D W V N Y O H PA Lye Brook 0 % 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

B r ig a n tin e CA NA DA CENRA P S E_B C W _BC N_BC V T R I M E D C M S C T N H M A W I N Y A L IL S C M I K Y T N IN N J D E G A W V M D V A N C O H P A Brigantine

0 % 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

G r e a t G u lf CA NA DA CENRA P SE_BC W_BC N_BC D C M S V T R I M E C T D E A L N J W I S C T N V A IL M D G A N H K Y N C M I W V IN M A N Y PA O H Great Gulf Source: NESCAUM, MANE-VU Cont ribution Assessment 2006

### Table 1: Summary of Results fr om the Four Factor Analysis

Source Category Primary Regional

Haze Pollutant Average Cost in 2006 dollars

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

Electric Generating Units SO 2 IPM* v.2.1.9 predicts $775-$1,690

$170-$5,700 based on available literature 2-3 years following SIP submittal Fuel supply issues, potential permitting issues, reduction in electricity production capacity, wastewater issues 50 years or more

Industrial, Commercial, Institutional Boilers SO 2 $130-$11,000 based on available literature 2-3 years following SIP submittal Fuel supply issues, potential permitting issues, control device energy requirements, wastewater issues 10-30 years

Cement and Lime Kilns SO 2 $1,900-$73,000 based on available literature 2-3 years following SIP submittal Control device energy requirements, wastewater issues 10-30 years

Heating Oil SO 2 $550-$750 based on available literature. There is a high uncertainty associated with this cost estimate. Currently feasible. Capacity issues may influence timeframe for implementation of new fuel standards Increases in furnace/boiler efficiency, Decreased furnace/boiler maintenance requirements 18-25 years

Residential Wood Combustion PM $0-$10,000 based on available literature Several years - dependent on mechanism for emission reduction Reduce greenhouse gas emissions, increase efficiency of combustion device 10-15 years

* EPA’s Integrated Planning Model 

### MANE-VU invited all interested parties to submit comments on the draft report by May 4 th 

### to Angela Crenshaw at MARAMA ( acrenshaw@marama.org ). Additional comments will be considered if time permits.

THE MANE-VU REASONABLE PROGRESS WORKGROUP This project is guided by MANE-VU’s Reasona ble Progress Workgroup, which reviewed draft documents and reports to MANE-VU’s Techni cal Support Committee. The Workgroup met via conference call several times per month, with twelve calls in total. Regular participants include the MANE-VU states and tribes, VISTAS, LADCO, NESCAUM, OTC, the Environmental Protection Agency, the National Park Service, and the Forest Service. Workgroup minutes, and all related project documents are available on the MARAMA website: http://www.marama.org/visibility/RPG/index.html

CONTACT INFORMATION Angela Crenshaw, MARAMA, acrenshaw@marama.org , 410-467-0170 Susan Wierman, MARAMA, swierman@marama.org , 410-467-0170 Art Werner, MACTEC, aswerner@mactec.com , 919-941-0333

MARAMA , 711 W. 40 th 

### Street Suite 312 Baltimore MD 21211

### MANE-VU’s Approach to Developing Regional Haze Control Measures for the 2018 Milestone

MANE-VU’s approach towards deciding which c ontrol measures to pursue for regional haze is based on technical analyses documented in the following reports:

• 

### Contributions to Regional Haze in the Nort heast and Mid-Atlantic United States (called the Contri bution Assessment),

• 

### Comparison of CAIR and CAIR Plus Propos al using the Integrated Planning Model (called the CAIR+ Report), and

• 

### Assessment of Reasonable Progress for Re gional Haze in MANE-VU Class I Areas (callsed the Reasonable Progress Report).

Pollutants of Concern
Finalized in August 2006, the Contribution A ssessment 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 region. Sulfate alone accounts for anywhere from one-hal f to two-thirds of total fine particle mass on the 20 percent haziest days at M ANE-VU Class I sites.” Organic carbon was shown to be the second largest contributor to haze. As a result of the dominant role of sulfate in the formation of regional haze in the Northeast and Mid-Atlantic region, the report states that “[T]hese findings suggest that an eff ective emissions management approach would rely heavily on broad-based regional SO 2 

### control efforts in the eastern United States.”
Contributing Sources

The Contribution Assessment reviewed vari ous modeling techniques, air quality data analysis, and emissions inventory analysis to identify source categories and states that contribute to visibility impairment in MANE- VU Class I areas. With respect to sulfate, emissions from within MANE-VU in 2002 were responsible for about 25-30 percent of the sulfate at MANE-VU Class I areas. Sour ces in the MRPO and VISTAS regions were responsible for about 15-25 percent each. Po int sources dominated the inventory of SO 2 

### emissions. Biomass combustion was also iden tified by source apportionment analysis as a local source contributing to visibility impairment.
Identifying Potential Strategies
The process by which MANE-VU arrived at a set of proposed regional haze control measures to pursue for the 2018 milestone st arted in late 2005. OTC selected a contracting firm to assist with the analysis of ozone and regional haze control measure options. OTC provided the contractor with a “master list’ of so me 900 potential control measures, based on experience and previous state implementation plan work. With the help of an internal OTC control measure wor kgroup, the contractor identified reasonably

### available regional haze control measures for MANE-VU’s further consideration. MANE-VU then developed an interim list of control measures, which for regional haze included: beyond-CAIR sulfate reductions from EGUs, low-sulfur heating oil (residential and commercial), ICI boilers (both coal and oil-fired), lime and cement kilns, residential wood combustion, and outdoor burning (including outdoor wood boilers).
The next step in the regional haze control meas ure selection process was to further refine the interim list. The beyond-CAIR EGU strate gy continued to stay on the list since EGU sulfate emissions have, by far, the largest im pact on visibility in the MANE-VU Class I areas. Likewise, a low-sulfur oil strategy gained traction after a NESCAUM-initiated conference with refiners and fuel-oil supplie rs concluded that such a strategy could realistically be implemented in the 2014 timeframe. Thus th e low-sulfur heating oil and the oil-fired ICI boiler sector control meas ures merged into an overall low-sulfur oil strategy for #2, #4, and #6 residual oils for both the residential and commercial heating and oil-fired ICI boiler source sectors.
During MANE-VU’s internal consultation meeting in March 2007, member states reviewed the interim list of control measures to make further refinements. States determined, for example, that there may be too few coal-fired ICI boilers in the MANEVU states for that to be considered as a “reg ional” strategy, but coul d be a sector pursued by individual states. They also determined th at lime and cement kiln s, of which there are few in the MANE-VU region, would likely be handled via their BART determination process. Residential wood burning and outdoor wood boilers remain on the list for those states where localized visibility impacts ma y be of concern even though emissions from these sources are primarily organic carbon and di rect particulate mater. Finally, outdoor wood burning was determined to also be better left as a sector to be examined further by individual states, due to issues of enfo rceability and penetrat ion of existing state regulations.
The CAIR+ Report documents the analys is of the cost of additional SO 2 

### and NO x 

### controls at EGUs in the Eastern U.S. The Reasonabl e Progress Report documents the assessment of control measures for EGUs and the othe r source categories selected for analysis.
Determining What Is Reasonable
MANE-VU is guided by two primary principles in which regional control measures to pursue in reducing sulfate levels: 1) that the measures are “reasonable,” and 2) that the measures are in place by 2018, the first m ilestone date in the Congressional goal of achieving natural visibility conditions by 2064. Reasonable progress towards meeting the 2064 goal is defined in section 169A of the Clean Air Act, and includes the mandatory consideration of four factors: 1) the cost of compliance, 2) the time necessary for compliance, 3) the energy and nonair quality environmental impacts of compliance, and 4) the remaining useful life of any exis ting source subject to such requirements.
Guided by these principles, MANE-VU has a rrived at a suite of suggested control measures that the MANE-VU states will pursue as a region. The corollary is that the

### MANE-VU Class I states (Mai ne, New Hampshire, Vermont, and New Jersey) will ask states outside of MANE-VU that contribute to visibility impairment to pursue similar strategies for reducing sulfate emissions fr om source sectors, or equivalent sulfate reductions if not from the source sectors that MANE-VU has identified for its own sulfate reductions. The guiding principle in MANE- VU’s approach to consulting with states outside of MANE-VU is that we cannot ask fo r more equivalent reductions than we are willing to pursue ourselves.
The regional strategies to reduce SO 2 

### emissions that MANE-VU has identified as reasonable within and outside MANE-VU by 2018 are: 1) Best Available Retrofit Technology (BART) sulfate reductions from sp ecific source sectors defined in the Clean air Act; and 2) a low-sulfur oil strategy for all sectors (commercial, industrial, and residential); and 3) an EGU strategy that ta rgets a 90% sulfate reduction from each of the key stacks impacting any MANE-VU Class I area (comprising a total of 167 EGU stacks), or a reduction equivalent to that amount within each State. Individual states may also pursue additional strategies.
The strategies for reducing SO 2 

### emissions that MANE-VU has identified as potentially reasonable for states outside of the MANE- VU region to pursue by 2018 are: 1) Best Available Retrofit Technology (B ART) sulfate reductions fr om specific source sectors defined in the Clean air Act); 2) an EGU st rategy that targets a 90% sulfate reduction from each of the key stacks impacting any M ANE-VU Class I area (comprising a total of 167 EGU stacks), or a reduction eq uivalent to that amount with in each State; and 3) the application of reasonable controls on non-E GU sources resulting in a 28% reduction in non-EGU SO 2 

### emissions, relative to on-the-books, on-the-way 2018 projections used in regional haze planning, by 2018, which is comparable to the projected reductions MANE-VU will achieve through its low sulfur oil strategy.
MANE-VU has considered potential SO 2 

### reductions available fr om the coal-fired ICI sector, and has concluded that states outside of MANE-VU ma y find this to be a viable source sector for SO 2 

### reductions comparable to those obt ained from oil-fired ICI boilers within MANE-VU. As noted above, additiona l reductions from this category within the MANE-VU region will be considered on a state- specific basis. MANE-VU states believe all contributing states should continue to seek viable and enforceable means to lower sulfur dioxide and nitrogen oxide emissi ons from all coal-bur ning facilities by 2018, relative to 2002. Finally, M ANE-VU is considering how to best deal with residential wood combustion and outdoor wood boilers. Although neither have significant SO 2 

### emissions, both of these source categories em it volatile and semi-volatile organic carbon and direct particulate matter that also impact visibility. Regarding these and other source sectors, the contributing states should conti nue to evaluate additional control measures, including energy efficiency and alternative clean fuels, to determine if they are reasonable for implementation in the short or long term, including, but not limited to, new source performance standards for wood combustion.

### Low-Sulfur Oil Strategy
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% less sulf ur for the heavier grades (#4 and #6 residual), and a minimum of 75% and maximum of 99.25% 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 end user. As much as 75% of the total sulfur reductions achieved by this strategy will come from us ing the low-sulfur #2 distillate for space heating in the residential and commercial sectors. While costs for these emissions reductions are somewhat uncertain, they are quite reasonable in comparison to costs of controlling other sectors as documented in th e Reasonable Progres Report, estimated at $550 to $750 per ton.
MANE-VU is cognizant of the fact that th e use of #2 distillate for residential, commercial, and industrial heating and process applications is primar ily a Northeast state phenomenon. The MANE-VU Class I states w ould then ask other states outside of MANE-VU to pursue equivalent reasonable su lfur reductions from their industrial, commercial, and institutional facilities.
Some MANE-VU states are proceeding with rulemakings to impose low-sulfur oil regulations much sooner than 2018 in order to aid their PM 2.5 

### attainment efforts. However, all of the MANE-VU states agree that a low-sulfur oil strategy is both reasonable and achievable by 2018.
EGU Strategy
MANE-VU has recently identified emissions from 167 stacks at EGU facilities as having visibility impacts in MANE-VU Class I areas that make controlling emissions from those stacks crucial to improving visibility at M ANE-VU Class I areaas. Unfortunately, when the Clean Air Interstate Rule (CAIR) is implemented (starting in 2010 for Phase I and 2015 for Phase II), there is no guarantee that sulfate emissions will be reduced at all of these units as generators have the legal opt ion to forgo sulfur controls in favor of allowance purchases. MANE-VU’s approach fo r this source sector is to pursue a 90% control level on SO 2 

### emissions from these stacks by 2018. MANE-VU has concluded that pursuing at least this level of sulfur reduction is both reasonable and cost-effective. Even though current wet scrubber technology can achieve sulfur reductions greater than 95%, historically a 90% sulfur reduction level includes lower average reductions from dry scrubbing technology. The cost for SO 2 

### emissions reductions will vary by unit, and the Reasonable Progress report summarizes the various control methods and costs available, ranging from $170 to $5,700 per ton.

BART
Imposition of BART on BART-eligible facilities and units in the MANE-VU states is up to each state in its BART-determination pro cess. MANE-VU is expecting significant sulfur reductions from this mandated control me asure. Since this is a very sector and

### source-specific process, MANE-VU does not anticipate that the level of BART reductions achieved in one region will necessa rily be the same as the level of BART reductions achieved in another region.

### Notes on List of Top Electric Generating Emissions Points Contributing to Visibility Impairment in MANE-VU

A list of top stacks impacting MANE VU Class I areas was generated by MARAMA on June 12, 2007. The following appr oach was taken to develop that table.
As part of the MANE VU Contribut ion Assessment, CALPUFF modeling was performed to identify the top 100 stacks that impact three of the MANE VU Class I areas. These three areas are Acadia , Brigantine and Lye Brook. Details of the modeling are provided in Appendix D of the Contributi on Assessment. The 100 top stacks for each Class I area are documented in Tables 10 a nd 20 from Appendix D “Dispersion Model Techniques” of the Contribution Assessment.
The modeling was performed by two indepe ndent modeling centers using two sets of meteorological data—the MM5 and th e NWS observation-based meteorology. Because of the differences in meteorological in put data, there are some differences in the results from the two modeling centers. The MM5 modeling identified some stacks as being in the top 100 impacting a MANE-VU Cl ass I area that were not identified by the VTDEC modeling, and vice versa. For purposes of the table, a ll stacks on either list were included.

MARAMA combined the lists of the top 100 EGU stacks in Tables 10 and 20 from Appendix D of the Contribution Assessm ent. Because there were 100 stacks for each of the three Class I areas and there were two tables for each Class I area (one for MM5 meteorology and second table for (VTDEC) meteorology) there were 600 stacks in the initial file. There were many duplications of identical stacks, either because they impacted more than one Class I area or because they were identified by both modeling centers. MARAMA eliminated the duplications. MARAMA also eliminated the stacks that were outside the consultation area pr eviously identified. The consultation area includes states contributing at least 2% of the sulfate monitored at MANE-VU Class I areas in 2002. This resulted in 167 uni que stacks impacting one or more MANE VU Class I areas.
The Appendix D tables did not identify the units or facilities that were modeled, only providing a CEMS Identification number . MARAMA used information contained in IPM input files to identify the plant na me and type where the stack was located.
The modeling used 2002 emissions data from EPA’s records of Continuous Emission Monitoring System (CEMS) data re ported by the power companies. This hourly data represents actual emissions from the stack on which the CEMS is placed. A power plant may have several stacks. Each stack may vent emissions from one or more units at the plant.

### Although the modeling was done on an hourly basis, the emissions data reported in the table represents the a ggregate of all the hours in 2002 from a given stack. Each of the modeling centers summed hourly CEMS data over the year to get a total annual emission rate in units in tons per year (T PY). This summing exercise was performed independently as part of the two modeling effo rts. Because of round-off error, the annual emission numbers generated by the two mode ling efforts shown in the Contribution Assessment are slightly different. For this table, the two annual emission rates were averaged to provide a single a nnual emission rate for each stack.
Finally, MARAMA developed a composite ranking from the two modeling center results for the three Class I areas to get a single overall ranking for each stack. The impact of each stack on the three Class I ar eas using two different meteorological sets resulted in up to six impact rankings from 1 to 100, with the lowest rank being the greatest impact. These rankings were averaged to provide an average stack rank. The stacks were sorted from lowest to highest average rank and then an integer ranking ranging from 1 to 167 was assigned to each stack.
There are several differences between this list and lists distributed previously. In previous discussions, MARAMA had prepared a list of all units at each of the facilities identified as having one of the top 100 stacks by the VTDEC modeling. That list included units which may or may not be vented to the stacks that were identified in the top 100 stacks for each of the Class I areas. The previous list also included sources outside the MANE-VU consultation area, and it did not reflect sources on the list generated by the modeling center that used MM5 meteorological data.
For this list, MARAMA did not list units. As noted above, only stacks listed in the tables from the Contribution Assessment have been listed. This resulted in a list of 167 stacks, including 24 that were not prev iously included because they were only identified by the MM5 modeling, not the VT DEC modeling. The use of stacks rather than units or facilities was chosen as more consistent with the re sults of the modeling presented in the Contribution Assessment.TOP ELECTRIC GENERATING EMISSION POINTS CONTRIBUTING TO VISIBILITY IMPAIRMENT IN MANE-VU - MODELED BY BOTH VTDEC AND MM5

R o w n u m b e r C E M S U n i t O R I S I D A c a d i a M M 5 A c a d i a V T D E C B r i g M M 5 B r i g V T D E C L y e M M 5 L y e V T D E C M M 5 2 0 0 2 S 0 2 T P Y V T D E C 2 0 0 2 S O 2 T P Y P l a n t N a m e P l a n t T y p e S t a t e N a m e S t a t e C o d e1 D005935 593 90 54 2,138 2,136 1 EDGE MOOR O/G Steam Delaware 102 D005941 594 95 3,742 2 INDIAN RIVER Coal Steam Delaware 103 D005942 594 74 3,760 2 INDIAN RIVER Coal Steam Delaware 104 D005943 594 84 44 4,686 4,682 2 INDIAN RIVER Coal Steam Delaware 105 D005944 594 69 21 7,390 7,384 2 INDIAN RIVER Coal Steam Delaware 106 D007031LR 703 79 86 75 38,520 38,486 3 BOWEN Coal Steam Georgia 137 D007032LR 703 72 89 61 68 37,289 37,256 3 BOWEN Coal Steam Georgia 138 D007033LR 703 71 99 74 64 63 94 43,067 43,029 3 BOWEN Coal Steam Georgia 139 D007034LR 703 69 95 86 58 60 89 41,010 40,974 3 BOWEN Coal Steam Georgia 1310 D00709C02 709 84 75 89 71 47,591 47,549 4 HARLLEE BRANCH Coal Steam Georgia 1311 D00861C01 861 28 96 65 46 62 42,355 42,318 5 COFFEEN Coal Steam Illinois 1712 D010011 1001 53 28,876 28,851 6 CAYUGA Coal Steam Indiana 1813 D010012 1001 95 46 68 26,016 25,992 6 CAYUGA Coal Steam Indiana 1814 D00983C01 983 52 19,922 7 CLIFTY CREEK Coal Steam Indiana 1815 D00983C02 983 54 18,131 7 CLIFTY CREEK Coal Steam Indiana 1816 D0099070 990 55 100 70 37 29,801 29,774 8 ELMER W STOUT O/G Steam Indiana 1817 D06113C03 6113 30 48 14 43 22 41 71,182 71,119 9 GIBSON Coal Steam Indiana 1818 D06113C04 6113 44 70 97 83 73 83 27,848 27,823 9 GIBSON Coal Steam Indiana 1819 D01008C01 1008 73 100 47 24,109 24,087 10 R GALLAGHER Coal Steam Indiana 1820 D01008C02 1008 98 55 23,849 23,828 10 R GALLAGHER Coal Steam Indiana 1821 D06166C02 6166 62 44 30 81 33 57 51,708 51,663 11 ROCKPORT Coal Steam Indiana 1822 D00988C03 988 77 15,946 12 TANNERS CREEK Coal Steam Indiana 1823 D00988U4 988 14 29 52 34 7 19 45,062 45,022 12 TANNERS CREEK Coal Steam Indiana 1824 D01010C05 1010 43 32 12 28 31 17 60,747 60,693 13 WABASH RIVER Coal Steam Indiana 1825 D067054 6705 34 60 34 44 73 40,118 40,082 14 WARRICK Coal Steam Indiana 1826 D06705C02 6705 92 75 96 27,895 14 WARRICK Coal Steam Indiana 1827 D01353C02 1353 38 30 15 26 85 29 41,545 41,508 15 BIG SANDY Coal Steam Kentucky 2128 D01384CS1 1384 22 58 21,837 21,817 16 COOPER Coal Steam Kentucky 2129 D01355C03 1355 21 51 99 68 52 38,104 38,070 17 E W BROWN Coal Steam Kentucky 2130 D060182 6018 83 39 12,083 18 EAST BEND Coal Steam Kentucky 2131 D01356C02 1356 93 71 88 50 59 25,646 25,623 19 GHENT Coal Steam Kentucky 2132 D060411 6041 61 18,375 20 H L SPURLOCK Coal Steam Kentucky 2133 D060412 6041 53 91 98 20,491 20,473 20 H L SPURLOCK Coal Steam Kentucky 2134 D013644 1364 81 7,185 21 MILL CREEK Coal Steam Kentucky 2135 D013782 1378 87 20,245 22 PARADISE Coal Steam Kentucky 21Notes:Plants in Red are added as a result of MM5 met modeling.List does not include sources in states that do not contribute 2% of visibility impact to MANE VU Class I areas.MM5 by ERM for Maryland70Printed : 7/17/2007 12:34 PMR o w n u m b e r C E M S U n i t O R I S I D A c a d i a M M 5 A c a d i a V T D E C B r i g M M 5 B r i g V T D E C L y e M M 5 L y e V T D E C M M 5 2 0 0 2 S 0 2 T P Y V T D E C 2 0 0 2 S O 2 T P Y P l a n t N a m e P l a n t T y p e S t a t e N a m e S t a t e C o d e36 D013783 1378 76 100 11 84 55 42 46,701 46,660 22 PARADISE Coal Steam Kentucky 2137 D015074 1507 78 1,170 23 WILLIAM F WYMAN O/G Steam Maine 2338 D006021 602 90 38 100 20,014 19,996 24 BRANDON SHORES Coal Steam Maryland 2439 D006022 602 99 29 99 19,280 19,263 24 BRANDON SHORES Coal Steam Maryland 2440 D015521 1552 63 17,782 17,767 25 C P CRANE Coal Steam Maryland 2441 D015522 1552 68 14,274 14,262 25 C P CRANE Coal Steam Maryland 2442 D01571CE2 1571 42 47 1 4 20 28 48,566 48,522 26 CHALK POINT Coal Steam Maryland 2443 D01572C23 1572 73 79 47 45 69 32 32,188 32,159 27 DICKERSON Coal Steam Maryland 2444 D015543 1554 77 10,084 10,075 28 HERBERT A WAGNER O/G Steam Maryland 2445 D015731 1573 67 50 16 12 56 38 36,823 36,790 29 MORGANTOWN Coal Steam Maryland 2446 D015732 1573 59 53 10 13 51 39 30,788 30,761 29 MORGANTOWN Coal Steam Maryland 2447 D016191 1619 37 80 9,252 9,244 30 BRAYTON POINT Coal Steam Massachusetts 2548 D016192 1619 35 66 8,889 8,881 30 BRAYTON POINT Coal Steam Massachusetts 2549 D016193 1619 4 14 65 56 79 19,325 19,308 30 BRAYTON POINT Coal Steam Massachusetts 2550 D015991 1599 5 36 65 13,014 13,002 31 CANAL O/G Steam Massachusetts 2551 D015992 1599 7 27 74 8,980 8,971 31 CANAL O/G Steam Massachusetts 2552 D016061 1606 48 5,249 32 MOUNT TOM Coal Steam Massachusetts 2553 D016261 1626 85 3,430 33 SALEM HARBOR Coal Steam Massachusetts 2554 D016263 1626 91 78 4,971 4,966 33 SALEM HARBOR Coal Steam Massachusetts 2555 D016264 1626 32 25 2,880 2,878 33 SALEM HARBOR O/G Steam Massachusetts 2556 D016138 1613 94 4,376 34 SOMERSET Coal Steam Massachusetts 2557 D01702C09 1702 96 4,565 35 DAN E KARN Coal Steam Michigan 2658 D01733C12 1733 49 24 80 80 45 22 46,081 46,040 36 MONROE Coal Steam Michigan 2659 D01733C34 1733 27 26 76 26 27 39,362 39,327 36 MONROE Coal Steam Michigan 2660 D017437 1743 91 15,805 37 ST CLAIR Coal Steam Michigan 2661 D017459A 1745 76 61 18,341 18,324 38 TRENTON CHANNEL Coal Steam Michigan 2662 D023641 2364 2 57 9,356 9,348 39 MERRIMACK Coal Steam New Hampshire 3363 D023642 2364 1 17 99 28 87 19,453 19,435 39 MERRIMACK Coal Steam New Hampshire 3364 D080021 8002 45 74 5,033 5,028 40 NEWINGTON O/G Steam New Hampshire 3365 D023781 2378 81 2 15 9,747 9,738 41 B L ENGLAND Coal Steam New Jersey 3466 D024032 2403 63 97 25 50 40 44 18,785 18,768 42 HUDSON O/G Steam New Jersey 3467 D024081 2408 95 8,076 43 MERCER Coal Steam New Jersey 3468 D024082 2408 60 5,675 43 MERCER Coal Steam New Jersey 3469 D02549C01 2549 64 41 42 72 25,343 25,320 44 C R HUNTLEY Coal Steam New York 3670 D02549C02 2549 99 12,317 44 C R HUNTLEY Coal Steam New York 3671 D024804 2480 71 7,720 45 DANSKAMMER O/G Steam New York 36Notes:Plants in Red are added as a result of MM5 met modeling.List does not include sources in states that do not contribute 2% of visibility impact to MANE VU Class I areas.MM5 by ERM for Maryland71Printed : 7/17/2007 12:34 PMR o w n u m b e r C E M S U n i t O R I S I D A c a d i a M M 5 A c a d i a V T D E C B r i g M M 5 B r i g V T D E C L y e M M 5 L y e V T D E C M M 5 2 0 0 2 S 0 2 T P Y V T D E C 2 0 0 2 S O 2 T P Y P l a n t N a m e P l a n t T y p e S t a t e N a m e S t a t e C o d e72 D02554C03 2554 33 51 62 27 51 30,151 30,125 46 DUNKIRK Coal Steam New York 3673 D02526C03 2526 78 14,929 47 WESTOVER Coal Steam New York 3674 D025276 2527 80 12,650 48 GREENIDGE Coal Steam New York 3675 D025163 2516 96 7,359 49 NORTHPORT O/G Steam New York 3676 D025945 2594 76 1,747 50 OSWEGO O/G Steam New York 3677 D02642CS2 2642 91 14,086 51 ROCHESTER 7 Coal Steam New York 3678 D080061 8006 93 3,817 52 ROSETON O/G Steam New York 3679 D080062 8006 88 2,840 52 ROSETON O/G Steam New York 3680 D080421 8042 13 12 18 5 10 34 57,820 57,769 53 BELEWS CREEK Coal Steam North Carolina 3781 D080422 8042 23 15 32 10 15 49 45,296 45,256 53 BELEWS CREEK Coal Steam North Carolina 3782 D027215 2721 98 45 87 39 97 85 19,145 19,128 54 CLIFFSIDE Coal Steam North Carolina 3783 D027133 2713 61 14,460 55 L V SUTTON Coal Steam North Carolina 3784 D027093 2709 97 9,390 56 LEE Coal Steam North Carolina 3785 D027273 2727 100 40 48 75 84 26,329 26,305 57 MARSHALL Coal Steam North Carolina 3786 D027274 2727 89 39 83 51 66 82 27,308 27,284 57 MARSHALL Coal Steam North Carolina 3787 D06250C05 6250 60 59 35 37 27,395 27,371 58 MAYO Coal Steam North Carolina 3788 D027121 2712 59 12,031 12,020 59 ROXBORO Coal Steam North Carolina 3789 D027122 2712 82 41 54 23 94 29,337 29,310 59 ROXBORO Coal Steam North Carolina 3790 D02712C03 2712 56 37 57 24 21 78 30,776 30,749 59 ROXBORO Coal Steam North Carolina 3791 D02712C04 2712 88 72 47 47 22,962 22,941 59 ROXBORO Coal Steam North Carolina 3792 D0283612 2836 55 20 48 89 29 35 41,432 41,395 60 AVON LAKE Coal Steam Ohio 3993 D028281 2828 29 9 31 30 24 8 37,307 37,274 61 CARDINAL Coal Steam Ohio 3994 D028282 2828 56 20,598 20,580 61 CARDINAL Coal Steam Ohio 3995 D028283 2828 80 15,372 61 CARDINAL Coal Steam Ohio 3996 D028404 284031622387,801 87,724 62 CONESVILLE Coal Steam Ohio 3997 D02840C02 2840 84 73 81 63 22,791 22,771 62 CONESVILLE Coal Steam Ohio 3998 D028375 2837 86 56 35 70 35,970 35,938 63 EASTLAKE Coal Steam Ohio 3999 D081021 8102 23 71 59 95 18,207 18,191 64 GEN J M GAVIN Coal Steam Ohio 39100 D081022 8102 78 12,333 12,322 64 GEN J M GAVIN Coal Steam Ohio 39101 D028501 2850 36 67 39 53 45 30,798 30,771 65 J M STUART Coal Steam Ohio 39102 D028502 2850 24 65 40 49 98 46 28,698 28,673 65 J M STUART Coal Steam Ohio 39103 D028503 2850 26 72 62 27,968 27,944 65 J M STUART Coal Steam Ohio 39104 D028504 2850 20 77 45 52 88 54 27,343 27,319 65 J M STUART Coal Steam Ohio 39105 D060312 6031 67 77 90 19,517 19,500 66 KILLEN STATION Coal Steam Ohio 39106 D02876C01 2876 40 7 3 9 30 10 72,593 72,529 67 KYGER CREEK Coal Steam Ohio 39107 D028327 2832 65 28 59 22 48 20 46,991 46,950 68 MIAMI FORT Coal Steam Ohio 39Notes:Plants in Red are added as a result of MM5 met modeling.List does not include sources in states that do not contribute 2% of visibility impact to MANE VU Class I areas.MM5 by ERM for Maryland72Printed : 7/17/2007 12:34 PMR o w n u m b e r C E M S U n i t O R I S I D A c a d i a M M 5 A c a d i a V T D E C B r i g M M 5 B r i g V T D E C L y e M M 5 L y e V T D E C M M 5 2 0 0 2 S 0 2 T P Y V T D E C 2 0 0 2 S O 2 T P Y P l a n t N a m e P l a n t T y p e S t a t e N a m e S t a t e C o d e108 D02832C06 2832 60 43 64 23,694 23,673 68 MIAMI FORT Coal Steam Ohio 39109 D028725 2872 74 92 78 90 36 30,079 30,052 69 MUSKINGUM RIVER Coal Steam Ohio 39110 D02872C04 2872 6 19 13 6 19 15 83,134 83,060 69 MUSKINGUM RIVER Coal Steam Ohio 39111 D02864C01 2864 70 56 61 63 49 24 35,193 35,162 70 R E BURGER Coal Steam Ohio 39112 D07253C01 7253 89 58 57 33 30,977 30,949 71 RICHARD GORSUCH Ohio39113 D028665 2866 82 53 19,796 19,779 72 W H SAMMIS Coal Steam Ohio 39114 D028667 2866 57 16 42 41 41 16 33,601 33,572 72 W H SAMMIS Coal Steam Ohio 39115 D02866C01 2866 97 54 93 96 92 30 24,649 24,627 72 W H SAMMIS Coal Steam Ohio 39116 D02866C02 2866 69 92 50 26,022 25,999 72 W H SAMMIS Coal Steam Ohio 39117 D02866M6A 2866 85 58 19,564 19,546 72 W H SAMMIS Coal Steam Ohio 39118 D060191 6019 93 72 60 21,496 73 W H ZIMMER Coal Steam Ohio 39119 D028306 2830 46 38 70 40 12 69 30,466 30,439 74 WALTER C BECKJORD Coal Steam Ohio 39120 D031782 3178 77 63 81 16,484 16,469 75 ARMSTRONG Coal Steam Pennsylvania 42121 D031403 3140 31 34 9 46 18 18 38,801 38,767 76 BRUNNER ISLAND Coal Steam Pennsylvania 42122 D03140C12 3140 52 46 49 69 25 23 29,736 29,709 76 BRUNNER ISLAND Coal Steam Pennsylvania 42123 D082261 8226 25 21 33 42 36 9 40,268 40,232 77 CHESWICK Coal Steam Pennsylvania 42124 D03179C01 3179 16 10585479,635 79,565 78 HATFIELD'S FERRY Coal Steam Pennsylvania 42125 D031221 3122 11 6 26 38 17 14 45,754 45,714 79 HOMER CITY Coal Steam Pennsylvania 42126 D031222 3122 9 4 37 92 13 11 55,216 55,167 79 HOMER CITY Coal Steam Pennsylvania 42127 D031361 3136 8 2 4 14 6 1 87,434 87,357 80 KEYSTONE Coal Steam Pennsylvania 42128 D031362 3136 18 3 8 19 8 2 62,847 62,791 80 KEYSTONE Coal Steam Pennsylvania 42129 D03148C12 3148 71 84 17,214 81 MARTINS CREEK Coal Steam Pennsylvania 42130 D031491 3149 19 8 35 7 1 6 60,242 60,188 82 MONTOUR Coal Steam Pennsylvania 42131 D031492 3149 15 5 21 20 3 5 50,276 50,232 82 MONTOUR Coal Steam Pennsylvania 42132 D031131 3113 82 9,674 83 PORTLAND Coal Steam Pennsylvania 42133 D031132 3113 36 93 14,294 83 PORTLAND Coal Steam Pennsylvania 42134 D03131CS1 3131 54 31 79 32 65 22,344 22,324 84 SHAWVILLE Coal Steam Pennsylvania 42135 D033193 3319 100 11,045 85 JEFFERIES O/G Steam South Carolina 45136 D033194 3319 90 87 11,838 85 JEFFERIES O/G Steam South Carolina 45137 D03297WT1 3297 68 61 17,671 86 WATEREE Coal Steam South Carolina 45138 D03297WT2 3297 83 73 17,199 86 WATEREE Coal Steam South Carolina 45139 D03298WL1 3298 35 94 37 25,170 25,148 87 WILLIAMS Coal Steam South Carolina 45140 D062491 6249 58 82 17,920 88 WINYAH Coal Steam South Carolina 45141 D03403C34 3403 85 20,314 89 GALLATIN Coal Steam Tennessee 47142 D03405C34 3405 39 19,368 90 JOHN SEVIER Coal Steam Tennessee 47143 D03406C10 3406 10 11 27 33 4 43 104,523 104,431 91 JOHNSONVILLE Coal Steam Tennessee 47Notes:Plants in Red are added as a result of MM5 met modeling.List does not include sources in states that do not contribute 2% of visibility impact to MANE VU Class I areas.MM5 by ERM for Maryland73Printed : 7/17/2007 12:34 PMR o w n u m b e r C E M S U n i t O R I S I D A c a d i a M M 5 A c a d i a V T D E C B r i g M M 5 B r i g V T D E C L y e M M 5 L y e V T D E C M M 5 2 0 0 2 S 0 2 T P Y V T D E C 2 0 0 2 S O 2 T P Y P l a n t N a m e P l a n t T y p e S t a t e N a m e S t a t e C o d e144 D03407C15 3407 64 87 66 67 76 37,308 37,274 92 KINGSTON Coal Steam Tennessee 47145 D03407C69 3407 48 98 91 82 91 38,645 38,611 92 KINGSTON Coal Steam Tennessee 47146 D038033 3803 55 9,493 93 CHESAPEAKE Coal Steam Virginia 51147 D038034 3803 94 16 10,806 93 CHESAPEAKE Coal Steam Virginia 51148 D037974 3797 90 9,293 94 CHESTERFIELD Coal Steam Virginia 51149 D037975 3797 88 44 27 86 19,620 19,602 94 CHESTERFIELD Coal Steam Virginia 51150 D037976 3797 66 18 7 3 34 66 40,570 40,534 94 CHESTERFIELD Coal Steam Virginia 51151 D03775C02 3775 47 16,674 95 CLINCH RIVER Coal Steam Virginia 51152 D038093 3809 52 64 29 10,477 10,468 96 YORKTOWN Coal Steam Virginia 51153 D03809CS0 3809 96 43 19 17 62 21,219 21,201 96 YORKTOWN Coal Steam Virginia 51154 D039423 3942 79 10,126 97 ALBRIGHT Coal Steam West Virginia 54155 D039431 3943 51 23 20 32 16 13 42,385 42,348 97 FORT MARTIN Coal Steam West Virginia 54156 D039432 3943 50 22 22 31 14 12 45,850 45,809 97 FORT MARTIN Coal Steam West Virginia 54157 D039353 3935 41 33 28 11 64 26 42,212 42,174 98 JOHN E AMOS Coal Steam West Virginia 54158 D03935C02 3935 17 42 43 1 11 21 63,066 63,010 98 JOHN E AMOS Coal Steam West Virginia 54159 D03947C03 3947 86 62 55 57 25 38,575 38,541 99 KAMMER Coal Steam West Virginia 54160 D03936C02 3936 98 15,480 15,467 100 KANAWHA RIVER Coal Steam West Virginia 54161 D03948C02 3948 58 13 17 36 9 7 55,405 55,356 101 MITCHELL Coal Steam West Virginia 54162 D062641 6264 75 49 50 18 77 40 42,757 42,719 102 MOUNTAINEER Coal Steam West Virginia 54163 D03954CS0 3954 68 24 25 23 67 20,130 20,112 103 MT STORM Coal Steam West Virginia 54164 D0393851 3938 79 97 12,948 12,936 104 PHILIP SPORN Coal Steam West Virginia 54165 D03938C04 3938 94 26,451 26,427 104 PHILIP SPORN Coal Steam West Virginia 54166 D060041 6004 66 83 31 21,581 21,562 105 PLEASANTS Coal Steam West Virginia 54167 D060042 6004 88 92 20,550 20,532 105 PLEASANTS Coal Steam West Virginia 54Notes:Plants in Red are added as a result of MM5 met modeling.List does not include sources in states that do not contribute 2% of visibility impact to MANE VU Class I areas.MM5 by ERM for Maryland74Printed : 7/17/2007 12:34 PM

### Mid-Atlantic/Northeast Visibility Union 444 N. Capitol Street, NW, Su ite 638, Washington, DC 20001 PROJECT RESULTS EVALUATION OF TIGHTER FEDERAL EMISSIONS CAPS FOR ELECTRIC GENERATING UNITS June 4, 2007 BACKGROUND

• 

### Purpose : This project evaluated an emission contro l strategy for Electric Generating Units (EGUs) that further reduced emissions beyo nd current federal requ irements throughout the eastern US via a tighter regional cap and trade program. Emissions reductions and costs were estimated in comparison to the federal program.

• 

### Why EGUs : Emissions from EGUs contribute to r egional haze in Class I areas throughout the eastern US. Therefore, states must evaluate st rategies for reducing em issions from EGUs as part of their efforts to achiev e reasonable progress in improving visibility at Class I areas.

• 

### Which Model : To predict future emissions from EG Us, the Mid-Atlantic/N ortheast Visibility Union (MANE-VU) and other Regi onal Planning Organizations ha ve followed the example of the US Environmental Protection Agency (EPA) in using the Integrat ed Planning Model (IPM ® 

### ), an integrated economic and emissions model. IPM projects energy supply based on various assumptions and develops a least-cost solu tion to generating needed electricity within specified emissions targets.

• 

### Strategy : EPA’s Clean Air Interstate Rule (CAI R) and Clean Air Mercury Rule (CAMR) will reduce SO 2 

### and NO x 

### emissions in the eastern US. This project evaluated an emission control strategy for EGUs that tightened CAIR throughout the eastern US. Emissions reductions and costs were estimated.

• 

### Model Runs : IPM runs are defined by numerous ec onomic and engineering assumptions.

o 

### EPA developed Base Case v.2.1.9 using IPM to evaluate the impacts of CAIR and the Clean Air Mercury Rule (CAMR). (R ecently, EPA updated their input data and developed Base Case v.3.0. Due to timi ng, all of the following runs used EPA Base Case v.2.1.9 with some updates and corrections.)

o 

### VISTAS CAIR Base Case. The Regional Planning Organizations collaborated with each other to update EPA Base Case v.2.1.9 us ing more current data about EGUs with more realistic fuel prices, creating an IP M run called VISTAS PC_1f. This VISTAS IPM implementation is the one that has been used in regional air quality modeling for ozone and haze state implementation plans.

o 

### MARAMA CAIR Base Case. MANE-VU, through MARAMA, contracted with ICF to prepare two new IPM runs. The MARAMA CAIR Base Case run was based on the VISTAS PC_1f run and underlying EPA Base Case v. 2.1.9, with some of the information

### Mid-Atlantic/Northeast Visibility Union 444 N. Capitol Street, NW, Su ite 638, Washington, DC 20001 updated, (e.g., fuel prices, control constraints, etc.) to better reflec t current information. The MARAMA CAIR Base Case run is also sometimes called MARAMA_5c.

o 

### MARAMA CAIR Plus Run. The MARAMA CAIR Plus run was also based on VISTAS PC_1f run and the underlying EPA Base Case v.2.1.9, but using lower NO x 

### emission caps and higher SO 2 

### retirement ratios. Consistent wi th the MARAMA CAIR Base Case Run, the CAIR Plus Run also updated some of the information used in the VISTAS run (e.g., fuel prices, control constraints, etc. ) to better reflect curr ent information. The MARAMA CAIR Plus run is also so metimes referred to as MARAMA_4c. ASSUMPTIONS

• 

### The assumptions for and results of the MA RAMA CAIR Base Case run and the MARAMA CAIR Plus run are summarized in the final draft ICF report titled “Comparison of CAIR and CAIR Plus Proposal using the Integr ated Planning Model (IPM), May 30 2007.

• 

### For purposes of this analysis, the CAIR region in cluded all states incl uded in any part of the EPA CAIR annual or seasonal program as well as all New England states. Figure 1 below from the final draft ICF report is a U.S. map with t he states affected by CAIR and CAIR Plus policies as implemented in the MARAMA CAIR and CAIR Plus IPM runs. Figure 1: States affected by CAIR and MARAMA CAIR Plus Policies

• Table 3 below from the final draft ICF report summarizes the NO x 

### budgets implemented in the MARAMA Base Case and MARAMA CAIR Plus IPM Policy runs. This shows the CAIR Plus Policy & CAIR Annual NOx

CAIR Plus Policy & CAIR Annual NOx and SO2 Policy & CAIR ozone season NOx Policy

CAIR Plus Policy & CAIR ozone season NOx Policy MN

RI

MO

A R

T X

L A WI

MI

IL IN OH

KY

TN

MS A L G A

FL SC

NC VA W V

P A NY ME

V T NH

MD DE NJ CT I A M A

DC

CAIR Plus Policy

### Mid-Atlantic/Northeast Visibility Union 444 N. Capitol Street, NW, Su ite 638, Washington, DC 20001 overall reduction in NO x 

### emissions to be achieved through t he implementation of CAIR Plus as compared to CAIR.

Table 3: NO x 

### Budgets in the CAIR/CAIR Plus Region (Thousand Tons) NO x Ozone Season Budget NO x Annual Budget Year MARAMA Base Case MARAMA CAIR Plus Policy Case MARAMA Base Case MARAMA CAIR Plus Policy Case

2009 568 623 1,722* 1,553* 2010 568 623 1,522 1,353 2012 568 415 1,522 902 2015 518 395 1,370 858 2018 485 382 1,268 829

*Includes NO x Compliance Supplement Pool of 199,997 tons included in 2009. Note: The 2015 budgets as modeled in IPM are the aver age of the budgets over the period 2013-2017. The actual ozone season NO x budgets proposed are 485 thousand tons in CAIR and 382 thousand tons in CAIR plus for 2015. The actual annual NO x budgets proposed are 1,268 thousand tons in CAIR and 829 thousand tons in CAIR plus for 2015.

• 

### As shown below in Table 4 from the final draft ICF report, the CA IR Plus run required a greater number of SO 2 

### allowances be retired for each ton of pollu tion discharged. This effect of this was to reduce the total amount of SO 2 

### emissions allowed within the CAIR Plus region.

Table 4: SO 2 

### Allowance Retirement Ratios in the CAIR/CAIR Plus Region SO 2 Allowance Retirement Ratio Year MARAMA Base Case MARAMA CAIR Plus Policy Case
2009 1.00 1.00 2010 2.00 2.50 2012 2.00 2.94 2015 2.52 3.32 2018 2.86 4.16 Note: The 2015 retirement ratios as modeled in IPM are the average of the retireme nt ratios over the period 2013-2017. The actual retirement ratios are 2.86 for CAIR and 3.57 for CAIR Plus for 2015. 

### RESULTS

• 

### Strengthening CAIR would achieve significant em ission reductions, increase the use of natural gas, decrease the use of coal, and drive the construction of new, cleaner plants.

• 

### The final draft ICF report projects t hat CAIR Plus would reduce national SO 2 

### emissions in 2018 from all fossil and non-fossil fuel-fired Electric Generating Units (EGUs) by 845,300 tons per year, from 4,785,600 to 3,940,300 tons per year, an 18% reduction.

o 

### SO 2 

### emissions in 2018 from all fossil and non- fossil fuel-fired EGUs are projected to decline by 31% in the MANE-VU region, 12 % in the Midwest, 29% in the Southeast, and 15% in the Central States. The CAIR Plus strategy would not apply in the West, so emissions there would grow by 5%. (See report, Table 8.)

### Mid-Atlantic/Northeast Visibility Union 444 N. Capitol Street, NW, Su ite 638, Washington, DC 20001 • 

### The report also projects that CA IR Plus would reduce national NO x 

### emissions in 2018 from all fossil and non-fossil fuel-fired Elec tric Generating Units (EGUs) by 480,500 tons per year, from 2,065,600 to 1,585,100 tons per year , a 23% national reduction (27% in MANE-VU) (Table 9).

• 

### The report projects that the annua lized incremental cost of t he CAIR Plus policy (over and above the cost of the CAIR pr ogram) would be $2.57 Billion (1999 $) in 2018 (Table 5). This includes the annualized capital costs of new cont rol equipment and new plants, fuel costs, and variable and fixed operation and maintenance cost s. This is a 2% increase (Table A5.8).

• 

### The report projects that the marginal cost of SO 2 

### emission reductions as manifested in the projected SO 2 

### allowance prices would increase from $1,106 (1999$/ton) in 2018 with CAIR to $1,392 (1999$/ton) with CAIR Plus, a 26% increase (Table 6).

• 

### The report estimates that with CA IR Plus, in the US an additional 17 gigawatts (GWs) of coal plant capacity would be controlled by SO 2 

### scrubbers and an additional 65 GW controlled by SCR (for NO x 

### ) as compared to the projected controls under CAIR (Table 7).

• 

### The costs and benefits listed above reflect that in comparison to the CAIR base case,

o 

### more new plants would be built under a CAIR Plus strategy, and more older plants would be retired; newer plants would have lower emissions (pp. 15-17);

o 

### the generation mix would change towards lowe r emission intensive fuel and plant types, including more IGCCs (pp. 16-17); and

o 

### natural gas-fired generation would increas e and generation from coal steam EGUs would decrease in all years except 2012. Increased installation of controls and an increase in coal generation occur in 2012, the first year when the SCR and SO 2 

### scrubber feasibility constraints were no longer applied in the CAIR Plus strategy. In years after 2012, the CAIR Plus SO 2 

### and NO x 

### policies continue to become more stringent resulting in an increase in nat ural gas-based generation. (See p. 15.) MORE INFORMATION

• 

### The final draft ICF report summarizing the result s of the MARAMA CAIR and CAIR Plus runs is available at www.manevu.org under Publications—Reports. It is also posted at www.marama.org under regional haze, projects, MANE-VU future year emissions inventories.

• 

### Information about the VISTAS CAIR Base Case run is summarized in an appendix to the report. More information is also posed at www.ladco.org under regional air quality planning, G. IPM Emissions Summaries.
TECHNICAL OVERSIGHT COMMITTEE Representatives from each MANE-VU stat e have participated in reviewing draft materials prepared under this project. Team members include: New Hampshire: Andy Bodnarik, Li z Nixon, Jeff Underhill New Jers ey: Chris Salmi, Ray Papalski Connecticut: David Wackter New York : Ron Stannard, Gopal Sistla, John Kent Delaware: David Fees, Mohammed Majeed Pennsylvania: Dean Van Orden, Wick Havens District of Columbia: Stan Tracey, Ram Tangirala Rhode Island: Karen Slattery Maine: Tom Downs OTC: Chris Recchia, Anna Garcia, Doug Austin Maryland: Tad Aburn, Diane Franks, Bri an Hug Massachusetts: Stephen Dennis MARAMA: Susan Wierman, Patrick Davis, Julie McDill Vermont: Paul Wishinski

CONTACT INFORMATION: Susan Wierman or Julie McDill, MARAMA ( swierman@marama.org or jmcdill@marama.org )

# Summary of Work

### Baseline, Natural Conditions, and Uniform Rate

1) Baseline and Natural B ackground Visibility Conditions - 12/2006 Considerations and Proposed Approach to the Calculation of Baseline and Natural Background Visibility Conditions at MANE-VU Class I Areas, 21 pages http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0 2) The Nature of the Fine Particle and Regional Haze Air 11/2006 Quality Problems in the MANE-VU Region: A Conceptual Description, 92 pages http://www.nescaum.org/topi cs/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0

### MANE-VU Emissions Inventory Data and Documentation - June 2007
I. 2002 Emissions Inventory

MANE-VU Contractor: Pechan – Randy Strait Documentation and Databa se files can be found at ftp.marama.org Subdirectory 2002 Version 3 Username: mane-vu Password: exchange

• Version 3 of the 2002 MANE-VU Inventory

• Summaries for biogenic, Area, Point, Non- Road, and Onroad sectors of Version 3 of 2002 MANE-VU Inventory.

• Technical Support Document (TSD)

Midwest RPO Contractor: Alpine – Greg Stella

• BaseK Emission Inventory conve rsion to SMOKE-ready format.
II. Non-EGU Future Year Emissions Inventory

MANE-VU Contractor: MACTEC – Ed Sabo Database files can be found at ftp.marama.org Username: future Password: emissions

Documentation can be found at www.marama.org/visibility/I nventory%20Summary/Futu reEmissionsInventory.htm



### • OTB/OTW 2009/12/18 MANE-VU Inventory
“On the books/On the Way” (OTB/OTW) Emissions inventories in both NIF and IDA format for Non-EGU, Point, Area, and Non-Road.

• BOTW 2009/12/18 MANE-VU Inventory
“Beyond On the Way” (BOTW) Emissions inventories in both NIF and IDA format for non EGU Point, Area, and Non-Road were developed based on the OTC control measures matrix. For regional haze purposes, except for SO2 controls, the BOTW controls are assumed in place by 2018.

### • Technical Support Document (TSD)

Midwest RPO Contractor: Alpine – Greg Stella

• BaseK 2009/12/18 OTB/OTW Growth and Control Factors Conversion to produce SMOKE-ready input files for all source categories.

III. EGU Future Year Emissions Inventory
IPM Modeling of EGU emissions for future years Contractor: ICF – Boddu Venk atesh & Alpine – Greg Stella Database files can be found at ftp.marama.org Subdirectory 2.1.9 EGUs Username: mane-vu Password: exchange

Documentation for this IPM run is not available

• VISTAS 2.1.9 IPM 2009/12/18 CAIR Inventory. (ICF – Boddu Venkatesh)
“ICF completed an IPM 2.1.9 modeling run based on the VISTAS PC_1f inventory. This run was headed by VISTAS, but has input from all RPOs. This is the IPM run MANE-VU is us ing for all of our base case CMAQ modeling.

• 2009/12/18 VISTAS 2.1.9 IPM output was c onverted into NIF and IDA format for CMAQ modeling by Alpine (Greg Stella)

• 2009 Non-Fossil EGU IDA Conversion of non-Fossil EGU data into an IDA format for CMAQ modeling. All MANE-VU states were asked to submit a list of their non-fossil EGU units in the 2009 i nventory. (Alpine – Greg Stella)
IV. MANE VU Inventories for Sensitivity Analysis

• MANE-VU Fuel Oil sulfur content se nsitivity Inventories. (Ongoing) Contractor: Alpine – Greg Stella No documents yet available for posting online.
Two 2018 sensitivity modeling inventories (S-1 and S-1) are being developed for use in REMSAD modeling. They will be based on the MANE-VU 2018 BOTW Emissions Inventory. The sulfur content of the #2/4/6 fuel oils will be restricted for all SCCs that use these fuels, except EGUs. EGUs are excluded because the sulfur in fuels burning in EGUs is subj ect to emissions trading. Therefore

### restrictions on the sulfur content of these fuels would free up allowances in the market that would be used elsewhere, re sulting in no net emissions decrease. The sulfur content for fuel oil is restricted as follows:
Sensitivity Inventory - 2018 S-1 Home heating and #2 Distillate Oil - 500 ppm S (0.05%) #4 Distillate/Residual Oil 2500 ppm S (0.25%) #6 Residual Oil 5000 ppm S (0.5%) (Except parts of CT & NY) #6 Residual Oil 3000 ppm S (0.3%) (For parts of CT & NY)
Sensitivity Inventory - 2018 S-2 Home heating and #2 Distillate Oil - 15 ppm S (0.0015%) #4 Distillate/Residual Oil 2500 ppm S (0.25%) #6 Residual Oil 5000 ppm S (0.5%) (Except parts of CT & NY) #6 Residual Oil 3000 ppm S (0.3%) (For parts of CT & NY)
Alpine is tasked with developing the Growth and Control packets that can be applied to the MANE-VU 20018 BOTW Inve ntory to develop the S-1 and S-2 inventories.

• MANE-VU Additional Limits on EGU NOx and SOx Sensitivity IPM Modeling Run Comparing CAIR with CAIR+ Contractor: ICF – Boddu Venkatesh Database files are not yet available.
Draft technical support documentation and fact sheets can be found at: www.marama.org/visibility/Inventory%20S ummary/FutureEmissionsInventory.ht

m

o 2.1.9 IPM 2009/12/18 MANE-VU Base Case EGU Inventory S.T.E.T.
This IPM run is known as the MANE-VU Base Case or MARAMA_5c. It was developed by MANE-VU based on the VISTAS 2.1.9 framework with updated natural gas prices and a few other adjustments to the input specifications. This Base Case was run to allow a comparison to the MANE-VU CAIR+ run described below. It has not been used for regional air quality modeling. State level results are available for this run. 2009/12/18 NIF and IDA files are available.

### o 2.1.9 IPM 2009/12/18 MANE-VU CAIR+ Inventory S.T.E.T.
This IPM run is known as the MANE-VU CAIR+ or MARAMA_4c. It was developed by MANE-VU based on the VISTAS 2.1.9 framework with updated natural gas prices and a few other adjustments to the input specifications. The results of this CAIR+ can be compared to the to the MANE-VU Base Case run described above. It has not been used for regional air quality modeling.

State level results are available for this run.

IV. Inter-RPO EI Warehouse System Contractor: ERG – Grace Kitzmiller/William Gerber Warehouse can be found at: http://app2.erg.com:8080/rpoapp/
MARAMA has uploaded the Version 3 2002 M ANE-VU Emissions Inventory. VISTAS has also uploaded data. Problems with the uploaded data and the warehouse system are currently being worked out.

V. Additional Data Contractor: EH Pechan OMNI

Documentation and Databa se files can be found at http://www.marama.org/visib ility/ResWoodCombustion/
MARAMA has provided two updates of the Nati onal Emissions Inventory for residential wood combustion. Some states have chosen to use some of these results in preparing their 2002 inventories. In gene ral, these updates are part of an ongoing process to refine information about this source category as it is a large sour ce of emissions with very uncertain emission estimates.

### BART

1) Five-Factor Analysis of BART -Eligible Sources: 2/2007 Survey of Options for Conducting BART Determinations http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0 2) BART Resource Guide, 34 pages 8/2006 http://www.nescaum.org/documents/bart-resource-guide 3) Assessment of Control Technology 3/2005 Options for BART-Eligible Sources, 102 pages http://www.nescaum.org/documents/bart-resource-guide 4) Development of a List of BART -Eligible Sources in the 5/2003 MANE-VU Region: Interim Report, 74 pages http://www.nescaum.org/documents/bart-resource-guide 5) A Basis for Control of BART-Eligible Sources, 168 pages 7/2001 http://www.nescaum.org/documents/bart-resource-guide

### Areas of Influence

1) Contributions to Regional Haze in the Northeast and 8/2006 Mid-Atlantic United St ates, 122 pages + Appendices A-D http://www.nescaum.org/documents/contribut ions-to-regional-haze- in-the-northeastand-mid-atlantic--united-states 2) Regional Aerosol Intensive Network (RAIN), 5/2006 Preliminary Data Analysis, 63 pages www.manevu.org/document.asp?FView+reports# 3) UMD Data Analysis Subcontrac t: Manuscripts on Data from 2/2006 the 2002 MANE-VU UMD Flightswww.nescaum.org/topics/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0 4) Upper Air Balloon Study – Millersville, PA, Winter 2004 2/2006www.nescaum.org/topics/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0 5) Source Apportionment Analysis of Air Quality Monitoring Data: 3/2005 Phase II, 102 pages http://www.marama.org/visibility/SA_phase2/index.html 6) Wintertime Tethered Balloon Measurements of Meteorological 1/2005 Variables and Aerosol Characteri zation in Support of MANE-VU, 17 pages http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0 7) Review of Speciation Trends Network and IMPROVE 3/2003 Chemically Speciated Data, Technical Memo #7, 71 pages http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50 8) REMSAD Platform Intercomparison Experiments, 2/2002 Technical Memo #5, 25 pages http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50

### 9) Trajectory Analysis of Potential Source Regions Affecting Class I 2/2002 Areas in the MANE-VU Regi on, Technical Memo #3, 32 pages http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50 10) REMSAD Modeling Exercises, T echnical Memo #2, 44 pages 2/2002 http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50 11) GIS Mapping of Regional Haze-R elated Data in the 2/2002 MANE-VU Region, Technical Memo #4, 41 pages http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50 12) Updated Visibility Statistic s for the MANE-VU Region, 2/2002 Technical Memo #1, 50 pages http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50 13) Source Apportionment Analysis of Air Quality Monitoring Data: 2/2002 Phase 1, 110 pages http://www.marama.org/visibility/SA_report/ 14) Meteorological Data Archive Feas ibility Assessment, 3 pages 1/2002 http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50 15) Determination of Fine Particle a nd Coarse Particle Concentrations 12/1999 in the Northeast United States, 1995, 85 pages http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50

### Reasonable Progress and Long Term Strategy

1) Reasonable Progress Goal Proj ect Summary, 5 pages 4/2007 http://www.marama.org/visibility/RPG/index.html#products 2) Assessing Reasonable Progress for Regional Haze in the Mid-Atlantic North Eastern Class I Areas Draft Final Report , 140 pages 4/2007 

### http://www.marama.org/visibility/RPG/index.html#products 3) Assessing Reasonable Progress for Regiona l Haze in the Mid-Atlantic North Eastern Class I Areas (Revised Draft Final Technical Memorandum #3), 129 pages 3/2007 http://www.marama.org/visibility/RPG/index.html#products 4) Methods for Evaluations Technica l Memorandum #2 Final, 5 pages 2/2007 http://www.marama.org/visibility/RPG/index.html#products 5) Control Scenarios Technical Memorandum #1 Final, 4 pages 2/2007 http://www.marama.org/visibility/RPG/index.html#products 6) Final Work Plan, 11 pages 1/2007 http://www.marama.org/visibility/RPG/index.html#products

### Communications and Outreach

1) MANE-VU Newsletter Fall 2006 http://www.manevu.org/document.asp?fview=Fact%20Sheets# 2) MANE-VU’s Comments on EPA / Bill Harnett Memorandum 8/2006 entitled “Process for Interstate Consultation on Regional Haze SIP Development,” 3 pages http://www.manevu.org/document.asp?fview=Correspondence# 3) MANE-VU’s Comments on Proposed IMPROVE Network 8/2006 Reduction Plan, 7 pages http://www.manevu.org/document.asp?fview=Correspondence# 4) Final Consultation Framework as approved by the MANE-VU Board 5/2006 on May 10, 2006, 6 pages http://www.manevu.org/document.asp?fview=Correspondence# 5) MANE-VU Newsletter Spring 2006 http://www.manevu.org/document.asp?fview=Fact%20Sheets# 6) MANE-VU’s Comments on EPA’s “Draft Guidance for Setting 1/2006 Reasonable Progress Goals Unde r the Regional Haze Program,” 9 pages http://www.manevu.org/document.asp?fview=Correspondence# 7) MANE-VU’s Comments on Proposed BART Trading Rule, 5 pages 9/2005 http://www.manevu.org/document.asp?fview=Correspondence# 8) MANE-VU Newsletter Fall 2005 http://www.manevu.org/document.asp?fview=Fact%20Sheets# 9) MANE-VU Newsletter Spring 2005 http://www.manevu.org/document.asp?fview=Fact%20Sheets# 10) Regional Haze – A Resource Guide for Journalists, 33 pages 5/2005 http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0 11) Regional Haze Reduces Visibility (Tri-fold brochure) 3/2005 http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0

### 12) Haze Communication Using CAMNET and IMPROVE Archives: 1/2005 Case Study at Acadia National Park, 13 pages http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0 13) About Regional Haze: Fact Sheet, 2 pages 1/2005 http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0 14) The Health Effects of Regional Haze: Fact Sheet, 2 pages 1/2005 http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0 15) About MANE-VU: Fact Sheet, 2 pages 1/2005 http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0 16) MANE-VU’s Comments on Proposed BART Rule, 27 pages 7/2004 http://www.manevu.org/document.asp?fview=Correspondence# 17) Scoping Study on Regional Haze, Initial Communications 12/2002 and Outreach Framework, 52 pages http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50

### Miscellaneous

1) TSD on Measures to Mitigate the Visibil ity Impacts of 10/2006 Construction Activities in the MANE-VU Region, 13 pages http://www.marama.org/visibility/SIP%5FPlanning/ 2) TSD on Agricultural and Forestry Smoke Management 9/2006 in the MANE-VU Region, 18 pages http://www.marama.org/visibility/SIP%5FPlanning/ 3) EPA Checklist for Regional Haze SIPs Submitted Under 8/2006 40 CFR 51.308, 14 pages http://www.marama.org/visibility/SIP%5FPlanning/ 4) 2006 Interim Report, 21 pages 5/2006 http://www.manevu.org/document.asp?Fview=Reports# 5) Draft Regional Haze SIP/TIP Template, 42 pages 1/2005 http://www.manevu.org/document.asp?Fview=Reports 6) MANE-VU Technical Work Plan, 20 pages 3/2003 http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50 7) Regional Haze and Visibility in the Northeast and Mid-Atlantic 1/2001 States, 265 pages http://www.nescaum.org/topics/r egional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50