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 Visibility 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 emission sources that affect visibility in MANEVU Class I areas and from Federal Land Managers and EPA. The MANE-VU Class I 

areas are also seeking input from these other States and agencies concerning strategies 

that should be adopted to achieve reasonable 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 consultation 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 planning organizations.” (See 64 FR 35735). The 

goals of instituting consultation procedures are mainly: 

1. To help develop a common technical basis and apportionment for long-term 

strategies that could be approved by individual 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 visibility problems to which they jointly contribute; and 

3. To provide information on areas of agreement and disagreement among States 

that the Administrator will take into account in the review of a State’s 

implementation plan to determine whether 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 Rules, and is not intended to refer to or 

address the Tribal government/Federal government consultation process. 

1
II. Consultation Requirements Specified in the Regional Haze Rules

The requirements for consultation in the Regional Haze Rules are as follows: 

A. Development of the Reasonable Progress Goal:

Section 51.308(d) of the Regional Haze Rules specifies that “–[I]n developing 

each reasonable progress goal, the State must consult with those States which may 

reasonably be anticipated to cause or contribute to visibility impairment in the mandatory 

Class I Federal area. 

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

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

submittal the actions taken to resolve the disagreement. 

In reviewing the State's implementation plan submittal, the [EPA] Administrator 

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

visibility improvement provides for reasonable 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 contribute to visibility impairment in any mandatory Class I 

Federal area located in another 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 emissions 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 public 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 affected 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 between the State and Federal Land Manager on 

the implementation of the visibility protection program required by [Subpart P], including 

development and review of implementation plan revisions and 5-year progress reports, 

2
and on the implementation of other programs having the potential to contribute to 

impairment of visibility in mandatory Class 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 future at each 10-year comprehensive State 

implementation plan (SIP) revision milestone. Although there is not an explicit 

consultation requirement in the regulations for 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 reasonable progress, the States must “collaborate” 

with other States through the regional planning process for the purpose of developing 

additional strategies to address 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 investigating the nature of the visibility 

problem, the pollutants and sources contributing to the problem, and possible control 

measures and strategies to improve visibility. The book is organized into tabbed sections 

that will allow MANE-VU Class I States to walk our consultation partners through these 

analytical pieces in a systematic manner from beginning to end, as well as provide a 

quick reference for locating information responding to specific issues or questions. 

Tab 2, “Consultation Overview,” includes a brief explanation of the approach that 

MANE-VU applied in developing a single “consulting 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’ Resolution and Statements,” includes four 

recently approved actions: 

• The first is a Resolution adopted by the 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 assuring reasonable progress. 

3
• 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 progress in improving visibility at our Class I areas. 

The course of action described is intended as a starting point for our 

discussions, and will be examined in light 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 SO2 reductions. 

Tab 4, “Uniform Rate of Progress,” contains 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 calculation 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 various 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 summarizes 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 Reasonable Progress Goals and Long Term 

Strategies,” comprises 3 subsections. The first, 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 “Reasonable Progress Goals Project” 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 stacks 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 SO2 and NOx controls at EGUs in the Eastern U.S., 

which supports the fourth action included 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 technical reports and documents supporting MANEVU’s findings and proposed solutions for improving visibility at our mandatory Class I 

federal areas. 

4
MANE-VU is continuing to develop additional information, and further 

summaries may be provided for the call or meetings. We recognize the importance of 

modeling results to assess visibility 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-person consultation meeting. We 

look forward to working with you as we establish our reasonable progress goals and 

together adopt and promote long term strategies that will improve visibility in all of our 

Class I areas. 

5
Consultation Overview 
MANE-VU Approach to the Development of “Consulting Groups” 

On November 1, representatives from each RPO and the FLMs began a dialogue aimed at 

identifying groups of Class I areas that might serve to focus consultations for purposes of 

the regional haze rule. While it appears that consultations will be conducted state-tostate, the RPO representatives agreed that there may be a role for the RPO staff in 

identifying Class I areas with common visibility issues 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 the 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 consultations so as to ensure that RPOdeveloped technical products would be ready and available to facilitate state discussions. 

The Class I states within the MANE-VU RPO have considered 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 the sources of visibility impairment 

for each Class I site, they have proposed an approach 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 National Park, Maine; Brigantine 

Wilderness (within the Edwin B. Forsythe National Wildlife Refuge), New Jersey; Great 

Gulf Wilderness, New Hampshire; Lye Brook Wilderness, Vermont; Moosehorn 

Wilderness (within the Moosehorn National Wildlife Refuge), Maine; Presidential Range 

– Dry River Wilderness, New Hampshire; and Roosevelt Campobello International Park, 

New Brunswick. 

The Class I states of MANE-VU recognize some differences between the Brigantine 

Wilderness and the northern tier of Class I sites in Vermont, New Hampshire and Maine. 

However, when viewed from the perspective of contributions 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 group 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 MANE-VU consulting group to those 

already suggested by the Mid-West RPO in their October 19 memorandum. The revised 

“Table 1” on the next page reflects the proposed composition 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 states are planning to contact those 

states listed in the proposed consulting group shortly to initiate the consultation process. 

6
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 

7
 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 sources located over a wide region, and is an issue 

of great importance to both the future of our nation’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 (SOX), organic carbon, and nitrogen oxides (NOX). 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 degradation 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 manmade air pollution.’’ The 156 Class I areas 

across the country include many well-known national parks and wilderness areas, such as the 

Grand Canyon National Park in Arizona and Shenandoah 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) Roosevelt 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 Section 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 first 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 other 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 progress 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 consultation 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)

8
In an effort to better utilize technical resources and foster inter-state and inter-agency cooperation 

in regional haze planning, EPA established and 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 consultation process, and to send a representative to 

future meetings scheduled through our respective Regional Planning Organization. These 

meetings will provide a forum for discussing the 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 development of a coordinated program to address 

regional haze that will also significant public health 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 Crawford, 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 include 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, the 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). 

9
Appendix 1 

States to be Consulted During the Establishment of Maine’s Class I Area 2018 

Reasonable Progress Goals 

State Technical Justification for Inclusion3

 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. 

10
The State of New Hampshire

NHDES Department of Environmental Services

Thomas S. Burack

Commissioner

P.O. Box 95, 29 Hazen Drive, Concord, New Hampshire 03302-0095 

Telephone: (603) 271-1370 Fax: (603) 271-1381 TDD 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 two Class I areas as designated under Section 

169A of the U.S. federal Clean Air Act. The Great 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 known 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 Regional Haze rule requires that these areas and 154 

others nationwide gradually improve 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 Canadian provinces, as needed, to begin planning to 

take the first steps toward meeting this goal. I write today because 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 whether 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 regulations of 40 CFR 51.308(d)(1)(iv) specify 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 jurisdiction that may reasonably cause or contribute to 

visibility impairment in those areas. The Federal Land Managers for the Class I area are also 

required to be consulted in this process. 

While it is believed by the scientific community that every U.S. state contributes in some way to 

air pollution in The Great Gulf and the Presidential Range – Dry River Class I areas, we have 

limited our requests for consultations to only those states and Canadian providences that our 

analyses indicate have the potential for contributions over certain thresholds for PM2.5 and/or 

sulfate to regional haze in our Class I areas. Beyond this, we are asking all states within our own 

Regional Planning Organization, the Mid-Atlantic Northeast – Visibility Union (MANE-VU) to 

consult with us. Because we have asked you to join us in consultation does not necessarily imply 

that we will be asking for air pollution control beyond measures you may have already identified 

as necessary for your own state for ozone and PM2.5 ambient air standard attainment. By joining 

us, you can help us shape our regional haze progress goals for 2018 and help play a part in 

determining the best way to meet those goals for the New Hampshire Class I areas. 

11
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 participation in this consultation 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 (or 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, MARAMA 

12
13
14
15
AIR 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 Organization (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 addressing 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 responsible 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 describing 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 consultation process between all states involved in any multi-state 

strategy aimed at achieving the RPGs. This consultation record is one element required in the SIP of any state such 

as Vermont which contains one or more Class I areas. This letter serves to initiate the formal consultation process 

between our two states regarding the strategies to be incorporated in our state SIPs for submittal in December 2007. 

Because the development of an effective strategy for mitigation 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 will be met in Lye Brook Wilderness Area by 2018. Vermont is a member of 

16
the Regional Planning Organization MANE-VU which is comprised of the New England States and New York, 

New Jersey, Pennsylvania, Delaware, Maryland, 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 impact 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 Vermont 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 the 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 document entitled “Contributions to Regional 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 will already be aware of the consultation that has been 

ongoing internally through committees and workgroups involved in MANE-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 period 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: Paul.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 

17
TABLE 1 

States to be Consulted on Establishing Vermont’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 “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 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-wide sulfur oxide emission impacts on the ambient 

sulfate levels predicted at receptors in the Class I area. Any state with 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. 

 

18
MANE-VU Class I States’ 

Resolution 

and 

MANE-VU Statements 
19
20
21
22
23
24
25
26
27
28
29
Uniform Rate of Progress 
Contributions to PM2.5 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

Sulfate

Mass (ug/m3)

#

#

#

#

#

#

#

Contributions to PM2.5 Extinction at 7 Sites

20% Worst Visibility Days (2000-2004)

Soil

Sea Salt

OC

EC

Nitrate

Sulfate

0

20

40

60

80

100

120

140

160

180

1

1

1

1

1

Extinction (Mm-1)

Dolly Sods

Shenandoah

Brigantine

Lye Brook

Great Gulf

Acadia

Moosehorn

30
Shenandoah Glide Path to Natural Conditions 2004-2064

SHEN1

0

5

10

15

20

25

30

35

1990-19941992-19961994-19971996-20001999-20022000-2004200920142019202420292034203920442049205420592064

Deciviews (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

35

1994-19981996-20001998-20022000-2004200920142019202420292034203920442049205420592064

Deciviews (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

31
Brigantine Glide Path to Natural Conditions 2004-2064

BRIG1

0

5

10

15

20

25

30

35

1993-19981996-20001998-20022000-2004200920142019202420292034203920442049205420592064

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

30

1993-19981996-20001998-20022000-2004200920142019202420292034203920442049205420592064

Deciviews (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

32
Great Gulf Glide Path to Natural Conditions 2004-2064

GRGU1

0

5

10

15

20

25

30

2001200220032004200920142019202420292034203920442049205420592064

Deciviews (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

30

1990-19941992-19961994-19981996-20001998-20022000-2004200920142019202420292034203920442049205420592064

Deciviews (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

33
Moosehorn Glide Path to Natural Conditions 2004-2064

MOOS1

0

5

10

15

20

25

1995-19981996-20001998-20022000-2004200920142019202420292034203920442049205420592064

Deciviews (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

Lye Brook Moosehorn

Brigantine Dolly Sods Great Gulf

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:VAL

34
Acadia

Lye Brook Moosehorn

Brigantine Dolly Sods Great Gulf

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

Lye Brook Moosehorn

Brigantine Dolly Sods Great Gulf

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:VAL

35
Acadia

Lye Brook Moosehorn

Brigantine Dolly Sods Great Gulf

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

Dolly Sods

Shenandoah

Brigantine

Lye Brook

Great Gulf

Acadia

Moosehorn

Mass (μg/m3

)

Baseline (2000-04)

2009

2018

36
18.0

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 2020

Deciview

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 2020

Deciview

Brigantine

Dolly Sods

Shenandoah

Brig BOTW_BaseB4

Dolly BOTW_BaseB4

Shen BOTW_BaseB4

Relative mass reductions applied to visibility metric 

for Mid-Atlantic sites

37
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 days

38
0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Shenandoah

CANADA

CENRAP

SE_BC

W_BC

N_BC

VT

RI

ME

DC

MS

NH

CT

MA

NJ

DE

SC

WI

AL

TN

IL

GA

NY

NC

MI

MD

VA

KY

IN

WV

PA

OH

Shenandoah 

20% Worst Days

IMPROVE mass 00-04 Threshold options

0.1 μg/m3 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/m3 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

#

39
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/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

μg/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/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

μg/m3

#

#

0

2

4

6

8

10

12

14

16

Lye Brook

Sulfate Nitrate EC OC Sea Salt Soil

#

40
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/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD 2002 Contribution to Sulfate Threshold options

μg/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/m3 Sulfate

2 % of Sulfate

Top 10 States

IMPROVE mass 00-04 REMSAD Threshold options 2002 Contribution to Sulfate

μg/m3

#

#

0

2

4

6

8

10

12

Moosehorn

Sulfate Nitrate EC OC Sea Salt Soil

#

41
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/m3 Sulfate

2 % of Sulfate

Top 10 States

μg/m3

#

#

0

2

4

6

8

10

12

14

Great Gulf

Sulfate Nitrate EC OC Sea Salt Soil

#

2002/2018 Sulfate Attribution

42
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%

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 Sulfate

μg/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 Days

μg/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 Mass

43
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%

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 Sulfate

μg/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 Days

μg/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 Mass

44
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%

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 Days

μg/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 Days

μg/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 Mass

45
0

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 Days

μg/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

#

#

46
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

#

#

#

#

47
States Contributing to >2% Sulfate

REMSAD 2002 vs. 2018

2002 2018

Dolly Sods

#

#

2002 2018

# Any MV Site

#

#

#

#

#

#

#

#

#

48
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-basis-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 demonstration that broad regions of the 

Eastern U.S. were likely to contribute 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 assessment of contributing sources to sulfate 

in the Eastern U.S. in their contribution assessment report (Contributions to 

Regional Haze in the Northeast and Mid-Atlantic United States; 

http://www.nescaum.org/documents/contributions-to-regional-haze-in-thenortheast-and-mid-atlantic--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 assessment for four primary source 

categories that were most common in our region. This report focused on available 

control options and costs for EGUs, Industrial 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 working 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 develop 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 considering each of the five statutory BART 

factors including the degree of visibility improvement that may result from 

installation of controls. For this factor it was suggested that a weight be given 

49
 

such that no additional controls would be warranted for any source that has a 

current annual average contribution to visibility 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 that the majority of BART-eligible sources 

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. 

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. 

50
 

Table 1. Possible range of SO2 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 

SO2 

Emissions 

Total 

Estimated 

Decrease in 

SO2 (tons/yr) 

Estimated Cost 

($/Ton SO2) Notes 

Chemical SO2 Scrubber 1 24000 9600 400-8000 Mid Range (1) 

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 (SO2 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 SO2 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. 

 

51
 

Table2. Possible range of NOX 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 

NOx

Emissions 

Total 

Estimated 

Decrease in 

NOx (tons/yr) 

Estimated 

Cost ($/Ton 

NOx) 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 NOx 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 

Portland Controlled 1 1700 0 0 

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. 

52
 

Table 3. Possible range of PM10 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 

PM10 

Emissions 

Total 

Estimated 

Decrease in 

PM10 

(tons/yr) 

Estimated 

Cost ($/Ton 

PM10 ) 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. 

53
Technical Support for 

Reasonable Progress Goals and 

Long-Term Strategies 
 

Technical Support for MANE-VU Statements 

-Control Option AssessmentFocus on SO2

• MANE-VU has conducted a contribution assessment and developed a conceptual 

model that indicates that the dominant contributor to visibility impairment at all 

sites during all seasons is particulate sulfate formed from emissions of SO2. 

While other pollutants, including organic carbon, need to be addressed in order to 

achieve the national visibility goals, our technical assessments suggest that an 

early emphasis on SO2 will yield the greatest near-term benefit. See Figure 1. 

• Source region for SO2 emissions is generally south and west (upwind) of MANEVU Class I areas on worst visibility days. 

• Wood combustion near Class I areas contributes 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

1

Extinction (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

1

Extinction (Mm-1)

0

20

40

60

80

100

120

140

160

180

1

1

1

1

1

Extinction (Mm-1)

Dolly Sods Shenandoah

Brigantine

Lye Brook

Great Gulf

Acadia

Moosehorn

54
 

Inventory Analysis

• By 2018, implementation of CAIR is projected to reduce 1.3 million tons of 

MANE-VU SO2 emissions annually. Relative to our current 2002 total of 1.6 

million tons per year in the power sector, this represents a very significant 

reduction of over 80% of power sector emissions in the MANE-VU region. 

• By contrast, non-EGU SO2 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 SO2 emissions of 

667,000 tons per year down to approximately 643,000 tons per year. 

• Significant opportunities remain to further reduce the projected remaining 

312,000 tons of annual EGU SO2 emissions as well as the 643,000 tons of annual 

non-EGU SO2 emissions. See Figure 2. 

EGUs

• MANE-VU remains interested in CAIR+ for SO2 as a means of achieving PM2.5

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 for these sources are being considered. 

Non-EGU SO2

• The 643,000 tons in non-EGU SO2 emissions can be broken down into the 

following categories: Industrial Boilers (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 Opportunities 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

55
 

• 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 percent and 35 to 90+ percent control at 

reasonable costs in the range of $500 to $1000 per ton of SO2 removed. A 

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

• Limits on the fuel-sulfur content of oil-burning industrial boilers could also yield 

reductions on the order of 50% from this category by requiring the use of 0.5 

percent S residual oil. Such a strategy might yield a 19,000 ton reduction. 

• Low-sulfur fuel requirements would offer 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 SO2 reduction annually. 

• The use of 0.5 percent (5000 ppm) residual oil (relative to current residual oil that 

has sulfur content of 1 percent or higher) could result in ~19,000 tons reduction. 

• Preliminary findings from our BART analysis suggest additional emissions 

reduction potential in the 35,000 ton range from several MANE-VU BARTeligible sources. 

• The combined emission reduction of all these measures would result in nearly a 

40 percent reduction in SO2 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 large non-EGUs (both 

within and outside MANE-VU) with significant impact on MANE-VU Class I 

visibility during 2002. Control options for these sources are being considered. 

Figure 3: 2018 Projected Non-EGU SO2 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

56
 

Long-term Emissions Management Options for MANE-VU

MANE-VU is considering (1) a CAIR+ EGU program for SO2, (2) measures to reduce 

non-EGU emissions in MANE-VU by up to 40 percent or 250,000 tons of SO2, and (3) 

programs to reduce wood combustion-related emissions in MANE-VU. 

Figure 4: 2018 Potential Non-EGU SO2 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 

57
 

MANE-VU Reasonable Progress 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 existing 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 reasonable progress requirement (dated 11/28/2005). 

The guidance recommends the following process for developing reasonable progress goals: 1) identify 

pollutants and associated source categories affecting visibility in Class 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 the visibility improvement resulting from various 

combinations of strategies and select the Reasonable Progress Goals. 

MANE-VU has developed information about the pollutants and sources affecting visibility and has 

developed a list of possible control measures for consideration. In order to assist MANE-VU in 

applying the four statutory factors, in January 2007, MARAMA signed a contract with MACTEC 

Federal Programs Inc., to prepare a technical support 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 areas in and near MANE-VU, lists possible control measures for those 

pollutants and source categories, and develops the requisite four factor analysis. NESCAUM will 

assist MANE-VU by conducting air quality and visibility modeling to address the fourth step of the 

process described in EPA’s guidance. 

POLLUTANTS AND SOURCE CATEGORIES 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 Mid-Atlantic and Northeastern Class I areas. Organic 

carbon is typically the second-largest contributor to regional haze in the MANE-VU region. 

What are the Major Source Categories of these Pollutants?

The largest source category of sulfur dioxide in the region is electric generating units (EGUs). 

Additional SO2 source categories analyzed include oil-fired installations at residential, commercial, 

institutional, or industrial facilities; industrial, commercial, and institutional (ICI) boilers; and cement 

and lime kilns. 

58
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 burning, and occasional large 

summer impacts at all sites from 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 fires 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 POLLUTANTS ORIGINATE? 

Specific EGUs are Important

Roughly 70% of the 2.3 million tons of SO2 emission in the 2002 MANE-VU emissions inventory 

(2002 MANE-VU Emission Inventory Version 3) were from EGUs, making them the largest SO2

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 represented by the circles, but these are located 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) 

59
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 apportionment and trajectory analyses. It illustrates that the impacts of 

woodsmoke on MANE-VU Class I areas are more likely due to emissions from within MANE-VU and 

Canada. The green highlighted section of the map shows the woodsmoke 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 visibility in MANE-VU Class I 

areas, analyses such as represented 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 plus other states that modeling showed contributed at least 2% of 

the sulfate ion at MANE-VU Class I areas in 2002. 

Figure 3 shows for Acadia, Brigantine, Lye Brook, and Great Gulf the modeled percent of sulfate ion 

impact from specific states. The state with the largest individual sulfate 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 slice is proportional to the 

modeled impact (using the REMSAD model). The percentages at the left of the bar refer to the percent 

of SO4 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. 

60
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 useful 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 Contribution Assessment 2006 

61
Table 1: Summary of Results from 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 

SO2 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 

SO2 $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 

SO2 $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 SO2 $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 4th 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 Reasonable Progress Workgroup, which reviewed draft 

documents and reports to MANE-VU’s Technical 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. 40th Street Suite 312 Baltimore MD 21211 

62
MANE-VU’s Approach to Developing Regional Haze Control Measures 

for the 2018 Milestone

MANE-VU’s approach towards deciding which control measures to pursue for regional 

haze is based on technical analyses documented in the following reports: 

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

(called the Contribution Assessment), 

• Comparison of CAIR and CAIR Plus Proposal using the Integrated Planning Model 

(called the CAIR+ Report), and 

• Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas 

(callsed the Reasonable Progress Report). 

Pollutants of Concern

Finalized in August 2006, the Contribution Assessment 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-half to two-thirds of total fine particle 

mass on the 20 percent haziest days at MANE-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 effective emissions management 

approach would rely heavily on broad-based regional SO2 control efforts in the eastern 

United States.” 

Contributing Sources

The Contribution Assessment reviewed various modeling techniques, air quality data 

analysis, and emissions inventory analysis to identify source categories and states that 

contribute to visibility impairment in MANE-VU 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. Sources in the MRPO and VISTAS regions were 

responsible for about 15-25 percent each. Point sources dominated the inventory of SO2

emissions. Biomass combustion was also identified 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 started 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 some 900 potential control 

measures, based on experience and previous state implementation plan work. With the 

help of an internal OTC control measure workgroup, the contractor identified reasonably 

63
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 measure selection process was to further refine 

the interim list. The beyond-CAIR EGU strategy continued to stay on the list since EGU 

sulfate emissions have, by far, the largest impact 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 suppliers concluded that such a strategy could 

realistically be implemented in the 2014 timeframe. Thus the low-sulfur heating oil and 

the oil-fired ICI boiler sector control measures 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 “regional” strategy, but could be a sector pursued 

by individual states. They also determined that lime and cement kilns, 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 may be of concern even though emissions from 

these sources are primarily organic carbon and direct 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 enforceability and penetration of existing state 

regulations. 

The CAIR+ Report documents the analysis of the cost of additional SO2 and NOx controls 

at EGUs in the Eastern U.S. The Reasonable Progress Report documents the assessment 

of control measures for EGUs and the other 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 milestone 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 existing source subject to such requirements. 

Guided by these principles, MANE-VU has arrived at a suite of suggested control 

measures that the MANE-VU states will pursue as a region. The corollary is that the 

64
MANE-VU Class I states (Maine, 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 from 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 for more equivalent reductions than we are 

willing to pursue ourselves. 

The regional strategies to reduce SO2 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 specific 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 targets 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 SO2 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 (BART) sulfate reductions from specific source sectors 

defined in the Clean air Act); 2) an EGU strategy that targets 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; and 3) the 

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

non-EGU SO2 emissions, relative to on-the-books, on-the-way 2018 projections used in 

regional haze planning, by 2018, which is comparable to the projected reductions 

MANE-VU will achieve through its low sulfur oil strategy. 

MANE-VU has considered potential SO2 reductions available from the coal-fired ICI 

sector, and has concluded that states outside of MANE-VU may find this to be a viable 

source sector for SO2 reductions comparable to those obtained from oil-fired ICI boilers 

within MANE-VU. As noted above, additional 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 emissions from all coal-burning facilities by 2018, 

relative to 2002. Finally, MANE-VU is considering how to best deal with residential 

wood combustion and outdoor wood boilers. Although neither have significant SO2

emissions, both of these source categories emit volatile and semi-volatile organic carbon 

and direct particulate matter that also impact visibility. Regarding these and other source 

sectors, the contributing states should continue 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. 

65
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 sulfur 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 using 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 the Reasonable Progres Report, estimated at 

$550 to $750 per ton. 

MANE-VU is cognizant of the fact that the use of #2 distillate for residential, 

commercial, and industrial heating and process applications is primarily a Northeast state 

phenomenon. The MANE-VU Class I states would then ask other states outside of 

MANE-VU to pursue equivalent reasonable sulfur 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 PM2.5 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 MANE-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 option to forgo sulfur controls in favor of 

allowance purchases. MANE-VU’s approach for this source sector is to pursue a 90% 

control level on SO2 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 SO2 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 process. MANE-VU is expecting significant 

sulfur reductions from this mandated control measure. Since this is a very sector and 

66
source-specific process, MANE-VU does not anticipate that the level of BART 

reductions achieved in one region will necessarily be the same as the level of BART 

reductions achieved in another region. 

67
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 approach was taken to develop that table. 

As part of the MANE VU Contribution 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 Contribution Assessment. The 100 top stacks for each 

Class I area are documented in Tables 10 and 20 from Appendix D “Dispersion Model 

Techniques” of the Contribution Assessment. 

The modeling was performed by two independent modeling centers using two sets 

of meteorological data—the MM5 and the NWS observation-based meteorology. 

Because of the differences in meteorological input 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 Class I area that were not identified by the 

VTDEC modeling, and vice versa. For purposes of the table, all 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 Assessment. 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 previously 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 unique 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 name and type where the stack was located. 

The modeling used 2002 emissions data from EPA’s records of Continuous 

Emission Monitoring System (CEMS) data reported 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. 

68
Although the modeling was done on an hourly basis, the emissions data reported 

in the table represents the aggregate 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 (TPY). This summing exercise was performed 

independently as part of the two modeling efforts. Because of round-off error, the annual 

emission numbers generated by the two modeling efforts shown in the Contribution 

Assessment are slightly different. For this table, the two annual emission rates were 

averaged to provide a single annual 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 areas 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 previously included because they were only 

identified by the MM5 modeling, not the VTDEC modeling. The use of stacks rather 

than units or facilities was chosen as more consistent with the results of the modeling 

presented in the Contribution Assessment. 

69
TOP ELECTRIC GENERATING EMISSION POINTS CONTRIBUTING TO VISIBILITY IMPAIRMENT IN MANE-VU - MODE

Row number

CEMS Unit

ORIS ID

Acadia MM5

Acadia VTDEC

Brig MM5

Brig VTDEC

Lye MM5

Lye VTDEC

MM5 2002 S02 TPY

VTDEC 2002 SO2 TPY

Plant Name

Plant Type

1 D005935 593 90 54 2,138 2,136 1 EDGE MOOR O/G Steam Delaw2 D005941 594 95 3,742 2 INDIAN RIVER Coal Steam Delaw3 D005942 594 74 3,760 2 INDIAN RIVER Coal Steam Delaw4 D005943 594 84 44 4,686 4,682 2 INDIAN RIVER Coal Steam Delaw5 D005944 594 69 21 7,390 7,384 2 INDIAN RIVER Coal Steam Delaw6 D007031LR 703 79 86 75 38,520 38,486 3 BOWEN Coal Steam Georg7 D007032LR 703 72 89 61 68 37,289 37,256 3 BOWEN Coal Steam Georg8 D007033LR 703 71 99 74 64 63 94 43,067 43,029 3 BOWEN Coal Steam Georg9 D007034LR 703 69 95 86 58 60 89 41,010 40,974 3 BOWEN Coal Steam Georg

10 D00709C02 709 84 75 89 71 47,591 47,549 4 HARLLEE BRANCH Coal Steam Georg11 D00861C01 861 28 96 65 46 62 42,355 42,318 5 COFFEEN Coal Steam Illinois 12 D010011 1001 53 28,876 28,851 6 CAYUGA Coal Steam Indian13 D010012 1001 95 46 68 26,016 25,992 6 CAYUGA Coal Steam Indian14 D00983C01 983 52 19,922 7 CLIFTY CREEK Coal Steam Indian15 D00983C02 983 54 18,131 7 CLIFTY CREEK Coal Steam Indian16 D0099070 990 55 100 70 37 29,801 29,774 8 ELMER W STOUT O/G Steam Indian17 D06113C03 6113 30 48 14 43 22 41 71,182 71,119 9 GIBSON Coal Steam Indian18 D06113C04 6113 44 70 97 83 73 83 27,848 27,823 9 GIBSON Coal Steam Indian19 D01008C01 1008 73 100 47 24,109 24,087 10 R GALLAGHER Coal Steam Indian20 D01008C02 1008 98 55 23,849 23,828 10 R GALLAGHER Coal Steam Indian21 D06166C02 6166 62 44 30 81 33 57 51,708 51,663 11 ROCKPORT Coal Steam Indian22 D00988C03 988 77 15,946 12 TANNERS CREEK Coal Steam Indian23 D00988U4 988 14 29 52 34 7 19 45,062 45,022 12 TANNERS CREEK Coal Steam Indian24 D01010C05 1010 43 32 12 28 31 17 60,747 60,693 13 WABASH RIVER Coal Steam Indian25 D067054 6705 34 60 34 44 73 40,118 40,082 14 WARRICK Coal Steam Indian26 D06705C02 6705 92 75 96 27,895 14 WARRICK Coal Steam Indian27 D01353C02 1353 38 30 15 26 85 29 41,545 41,508 15 BIG SANDY Coal Steam Kentuc28 D01384CS1 1384 22 58 21,837 21,817 16 COOPER Coal Steam Kentuc29 D01355C03 1355 21 51 99 68 52 38,104 38,070 17 E W BROWN Coal Steam Kentuc30 D060182 6018 83 39 12,083 18 EAST BEND Coal Steam Kentu31 D01356C02 1356 93 71 88 50 59 25,646 25,623 19 GHENT Coal Steam Kentuc32 D060411 6041 61 18,375 20 H L SPURLOCK Coal Steam Kentuc33 D060412 6041 53 91 98 20,491 20,473 20 H L SPURLOCK Coal Steam Kentuc34 D013644 1364 81 7,185 21 MILL CREEK Coal Steam Kentu35 D013782 1378 87 20,245 22 PARADISE Coal Steam Kentu

Notes: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 Maryland 
Row

number

CEMS

Unit

ORIS

ID

Acadia

MM5

Acadia

VTDEC

Brig

MM5

Brig

VTDEC

Lye

MM5

Lye

VTDEC

MM5

2002

S02

TPY

VTDEC

2002

SO2

TPY

Plant

Name

Plant

Type

36 D013783 1378 76 100 11 84 55 42 46,701 46,660 22 PARADISE Coal Steam Kentuc37 D015074 1507 78 1,170 23 WILLIAM F WYMAN O/G Steam Maine 38 D006021 602 90 38 100 20,014 19,996 24 BRANDON SHORES Coal Steam Maryla39 D006022 602 99 29 99 19,280 19,263 24 BRANDON SHORES Coal Steam Maryla40 D015521 1552 63 17,782 17,767 25 C P CRANE Coal Steam Maryla41 D015522 1552 68 14,274 14,262 25 C P CRANE Coal Steam Maryla42 D01571CE2 1571 42 47 1 4 20 28 48,566 48,522 26 CHALK POINT Coal Steam Maryla43 D01572C23 1572 73 79 47 45 69 32 32,188 32,159 27 DICKERSON Coal Steam Maryla44 D015543 1554 77 10,084 10,075 28 HERBERT A WAGNER O/G Steam Maryla45 D015731 1573 67 50 16 12 56 38 36,823 36,790 29 MORGANTOWN Coal Steam Maryla46 D015732 1573 59 53 10 13 51 39 30,788 30,761 29 MORGANTOWN Coal Steam Maryla47 D016191 1619 37 80 9,252 9,244 30 BRAYTON POINT Coal Steam Massa48 D016192 1619 35 66 8,889 8,881 30 BRAYTON POINT Coal Steam Massa49 D016193 1619 4 14 65 56 79 19,325 19,308 30 BRAYTON POINT Coal Steam Massa50 D015991 1599 5 36 65 13,014 13,002 31 CANAL O/G Steam Massa51 D015992 1599 7 27 74 8,980 8,971 31 CANAL O/G Steam Massa52 D016061 1606 48 5,249 32 MOUNT TOM Coal Steam Massa53 D016261 1626 85 3,430 33 SALEM HARBOR Coal Steam Massa54 D016263 1626 91 78 4,971 4,966 33 SALEM HARBOR Coal Steam Massa55 D016264 1626 32 25 2,880 2,878 33 SALEM HARBOR O/G Steam Massa56 D016138 1613 94 4,376 34 SOMERSET Coal Steam Massa57 D01702C09 1702 96 4,565 35 DAN E KARN Coal Steam Michig58 D01733C12 1733 49 24 80 80 45 22 46,081 46,040 36 MONROE Coal Steam Michig59 D01733C34 1733 27 26 76 26 27 39,362 39,327 36 MONROE Coal Steam Michig60 D017437 1743 91 15,805 37 ST CLAIR Coal Steam Michig61 D017459A 1745 76 61 18,341 18,324 38 TRENTON CHANNEL Coal Steam Michig62 D023641 2364 2 57 9,356 9,348 39 MERRIMACK Coal Steam New H63 D023642 2364 1 17 99 28 87 19,453 19,435 39 MERRIMACK Coal Steam New H64 D080021 8002 45 74 5,033 5,028 40 NEWINGTON O/G Steam New H65 D023781 2378 81 2 15 9,747 9,738 41 B L ENGLAND Coal Steam New J66 D024032 2403 63 97 25 50 40 44 18,785 18,768 42 HUDSON O/G Steam New J67 D024081 2408 95 8,076 43 MERCER Coal Steam New J68 D024082 2408 60 5,675 43 MERCER Coal Steam New J69 D02549C01 2549 64 41 42 72 25,343 25,320 44 C R HUNTLEY Coal Steam New Y70 D02549C02 2549 99 12,317 44 C R HUNTLEY Coal Steam New Y71 D024804 2480 71 7,720 45 DANSKAMMER O/G Steam New Y

Notes: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 Maryland 
Row

number

CEMS

Unit

ORIS

ID

Acadia

MM5

Acadia

VTDEC

Brig

MM5

Brig

VTDEC

Lye

MM5

Lye

VTDEC

MM5

2002

S02

TPY

VTDEC

2002

SO2

TPY

Plant

Name

Plant

Type

72 D02554C03 2554 33 51 62 27 51 30,151 30,125 46 DUNKIRK Coal Steam New Y73 D02526C03 2526 78 14,929 47 WESTOVER Coal Steam New Y74 D025276 2527 80 12,650 48 GREENIDGE Coal Steam New Y75 D025163 2516 96 7,359 49 NORTHPORT O/G Steam New Y76 D025945 2594 76 1,747 50 OSWEGO O/G Steam New Y77 D02642CS2 2642 91 14,086 51 ROCHESTER 7 Coal Steam New Y78 D080061 8006 93 3,817 52 ROSETON O/G Steam New Y79 D080062 8006 88 2,840 52 ROSETON O/G Steam New Y80 D080421 8042 13 12 18 5 10 34 57,820 57,769 53 BELEWS CREEK Coal Steam North 81 D080422 8042 23 15 32 10 15 49 45,296 45,256 53 BELEWS CREEK Coal Steam North 82 D027215 2721 98 45 87 39 97 85 19,145 19,128 54 CLIFFSIDE Coal Steam North 83 D027133 2713 61 14,460 55 L V SUTTON Coal Steam North 84 D027093 2709 97 9,390 56 LEE Coal Steam North 85 D027273 2727 100 40 48 75 84 26,329 26,305 57 MARSHALL Coal Steam North 86 D027274 2727 89 39 83 51 66 82 27,308 27,284 57 MARSHALL Coal Steam North 87 D06250C05 6250 60 59 35 37 27,395 27,371 58 MAYO Coal Steam North 88 D027121 2712 59 12,031 12,020 59 ROXBORO Coal Steam North 89 D027122 2712 82 41 54 23 94 29,337 29,310 59 ROXBORO Coal Steam North 90 D02712C03 2712 56 37 57 24 21 78 30,776 30,749 59 ROXBORO Coal Steam North 91 D02712C04 2712 88 72 47 47 22,962 22,941 59 ROXBORO Coal Steam North 92 D0283612 2836 55 20 48 89 29 35 41,432 41,395 60 AVON LAKE Coal Steam Ohio 93 D028281 2828 29 9 31 30 24 8 37,307 37,274 61 CARDINAL Coal Steam Ohio 94 D028282 2828 56 20,598 20,580 61 CARDINAL Coal Steam Ohio 95 D028283 2828 80 15,372 61 CARDINAL Coal Steam Ohio 96 D028404 2840 316223 87,801 87,724 62 CONESVILLE Coal Steam Ohio 97 D02840C02 2840 84 73 81 63 22,791 22,771 62 CONESVILLE Coal Steam Ohio 98 D028375 2837 86 56 35 70 35,970 35,938 63 EASTLAKE Coal Steam Ohio 99 D081021 8102 23 71 59 95 18,207 18,191 64 GEN J M GAVIN Coal Steam Ohio 

100 D081022 8102 78 12,333 12,322 64 GEN J M GAVIN Coal Steam Ohio 101 D028501 2850 36 67 39 53 45 30,798 30,771 65 J M STUART Coal Steam Ohio 102 D028502 2850 24 65 40 49 98 46 28,698 28,673 65 J M STUART Coal Steam Ohio 103 D028503 2850 26 72 62 27,968 27,944 65 J M STUART Coal Steam Ohio 104 D028504 2850 20 77 45 52 88 54 27,343 27,319 65 J M STUART Coal Steam Ohio 105 D060312 6031 67 77 90 19,517 19,500 66 KILLEN STATION Coal Steam Ohio 106 D02876C01 2876 40 7 3 9 30 10 72,593 72,529 67 KYGER CREEK Coal Steam Ohio 107 D028327 2832 65 28 59 22 48 20 46,991 46,950 68 MIAMI FORT Coal Steam Ohio 

Notes: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 Maryland 
Row

number

CEMS

Unit

ORIS

ID

Acadia

MM5

Acadia

VTDEC

Brig

MM5

Brig

VTDEC

Lye

MM5

Lye

VTDEC

MM5

2002

S02

TPY

VTDEC

2002

SO2

TPY

Plant

Name

Plant

Type

108 D02832C06 2832 60 43 64 23,694 23,673 68 MIAMI FORT Coal Steam Ohio 109 D028725 2872 74 92 78 90 36 30,079 30,052 69 MUSKINGUM RIVER Coal Steam Ohio 110 D02872C04 2872 6 19 13 6 19 15 83,134 83,060 69 MUSKINGUM RIVER Coal Steam Ohio 111 D02864C01 2864 70 56 61 63 49 24 35,193 35,162 70 R E BURGER Coal Steam Ohio 112 D07253C01 7253 89 58 57 33 30,977 30,949 71 RICHARD GORSUCH Ohio 113 D028665 2866 82 53 19,796 19,779 72 W H SAMMIS Coal Steam Ohio 114 D028667 2866 57 16 42 41 41 16 33,601 33,572 72 W H SAMMIS Coal Steam Ohio 115 D02866C01 2866 97 54 93 96 92 30 24,649 24,627 72 W H SAMMIS Coal Steam Ohio 116 D02866C02 2866 69 92 50 26,022 25,999 72 W H SAMMIS Coal Steam Ohio 117 D02866M6A 2866 85 58 19,564 19,546 72 W H SAMMIS Coal Steam Ohio 118 D060191 6019 93 72 60 21,496 73 W H ZIMMER Coal Steam Ohio 119 D028306 2830 46 38 70 40 12 69 30,466 30,439 74 WALTER C BECKJORD Coal Steam Ohio 120 D031782 3178 77 63 81 16,484 16,469 75 ARMSTRONG Coal Steam Penns121 D031403 3140 31 34 9 46 18 18 38,801 38,767 76 BRUNNER ISLAND Coal Steam Penns122 D03140C12 3140 52 46 49 69 25 23 29,736 29,709 76 BRUNNER ISLAND Coal Steam Penns123 D082261 8226 25 21 33 42 36 9 40,268 40,232 77 CHESWICK Coal Steam Penns124 D03179C01 3179 16 10 5854 79,635 79,565 78 HATFIELD'S FERRY Coal Steam Penns125 D031221 3122 11 6 26 38 17 14 45,754 45,714 79 HOMER CITY Coal Steam Penns126 D031222 3122 9 4 37 92 13 11 55,216 55,167 79 HOMER CITY Coal Steam Penns127 D031361 3136 8 2 4 14 6 1 87,434 87,357 80 KEYSTONE Coal Steam Penns128 D031362 3136 18 3 8 19 8 2 62,847 62,791 80 KEYSTONE Coal Steam Penns129 D03148C12 3148 71 84 17,214 81 MARTINS CREEK Coal Steam Penns130 D031491 3149 19 8 35 7 1 6 60,242 60,188 82 MONTOUR Coal Steam Penns131 D031492 3149 15 5 21 20 3 5 50,276 50,232 82 MONTOUR Coal Steam Penns132 D031131 3113 82 9,674 83 PORTLAND Coal Steam Penns133 D031132 3113 36 93 14,294 83 PORTLAND Coal Steam Penns134 D03131CS1 3131 54 31 79 32 65 22,344 22,324 84 SHAWVILLE Coal Steam Penns135 D033193 3319 100 11,045 85 JEFFERIES O/G Steam South 136 D033194 3319 90 87 11,838 85 JEFFERIES O/G Steam South 137 D03297WT1 3297 68 61 17,671 86 WATEREE Coal Steam South 138 D03297WT2 3297 83 73 17,199 86 WATEREE Coal Steam South 139 D03298WL1 3298 35 94 37 25,170 25,148 87 WILLIAMS Coal Steam South 140 D062491 6249 58 82 17,920 88 WINYAH Coal Steam South 141 D03403C34 3403 85 20,314 89 GALLATIN Coal Steam Tenne142 D03405C34 3405 39 19,368 90 JOHN SEVIER Coal Steam Tenne143 D03406C10 3406 10 11 27 33 4 43 104,523 104,431 91 JOHNSONVILLE Coal Steam Tenne

Notes: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 Maryland 
Row

number

CEMS

Unit

ORIS

ID

Acadia

MM5

Acadia

VTDEC

Brig

MM5

Brig

VTDEC

Lye

MM5

Lye

VTDEC

MM5

2002

S02

TPY

VTDEC

2002

SO2

TPY

Plant

Name

Plant

Type

144 D03407C15 3407 64 87 66 67 76 37,308 37,274 92 KINGSTON Coal Steam Tenne145 D03407C69 3407 48 98 91 82 91 38,645 38,611 92 KINGSTON Coal Steam Tenne146 D038033 3803 55 9,493 93 CHESAPEAKE Coal Steam Virgini147 D038034 3803 94 16 10,806 93 CHESAPEAKE Coal Steam Virgini148 D037974 3797 90 9,293 94 CHESTERFIELD Coal Steam Virgini149 D037975 3797 88 44 27 86 19,620 19,602 94 CHESTERFIELD Coal Steam Virgini150 D037976 3797 66 18 7 3 34 66 40,570 40,534 94 CHESTERFIELD Coal Steam Virgini151 D03775C02 3775 47 16,674 95 CLINCH RIVER Coal Steam Virgini152 D038093 3809 52 64 29 10,477 10,468 96 YORKTOWN Coal Steam Virgini153 D03809CS0 3809 96 43 19 17 62 21,219 21,201 96 YORKTOWN Coal Steam Virgini154 D039423 3942 79 10,126 97 ALBRIGHT Coal Steam West V155 D039431 3943 51 23 20 32 16 13 42,385 42,348 97 FORT MARTIN Coal Steam West V156 D039432 3943 50 22 22 31 14 12 45,850 45,809 97 FORT MARTIN Coal Steam West V157 D039353 3935 41 33 28 11 64 26 42,212 42,174 98 JOHN E AMOS Coal Steam West V158 D03935C02 3935 17 42 43 1 11 21 63,066 63,010 98 JOHN E AMOS Coal Steam West V159 D03947C03 3947 86 62 55 57 25 38,575 38,541 99 KAMMER Coal Steam West V160 D03936C02 3936 98 15,480 15,467 100 KANAWHA RIVER Coal Steam West V161 D03948C02 3948 58 13 17 36 9 7 55,405 55,356 101 MITCHELL Coal Steam West V162 D062641 6264 75 49 50 18 77 40 42,757 42,719 102 MOUNTAINEER Coal Steam West V163 D03954CS0 3954 68 24 25 23 67 20,130 20,112 103 MT STORM Coal Steam West V164 D0393851 3938 79 97 12,948 12,936 104 PHILIP SPORN Coal Steam West V165 D03938C04 3938 94 26,451 26,427 104 PHILIP SPORN Coal Steam West V166 D060041 6004 66 83 31 21,581 21,562 105 PLEASANTS Coal Steam West V167 D060042 6004 88 92 20,550 20,532 105 PLEASANTS Coal Steam West V

Notes: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 Maryland 
Mid-Atlantic/Northeast Visibility Union 

444 N. Capitol Street, NW, Suite 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 control strategy for Electric Generating Units 

(EGUs) that further reduced emissions beyond current federal requirements 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 regional haze in Class I areas throughout the 

eastern US. Therefore, states must evaluate strategies for reducing emissions from EGUs as 

part of their efforts to achieve reasonable progress in improving visibility at Class I areas. 

• Which Model: To predict future emissions from EGUs, the Mid-Atlantic/Northeast Visibility 

Union (MANE-VU) and other Regional Planning Organizations have followed the example of 

the US Environmental Protection Agency (EPA) in using the Integrated Planning Model (IPM®), 

an integrated economic and emissions model. IPM projects energy supply based on various 

assumptions and develops a least-cost solution to generating needed electricity within 

specified emissions targets. 

• Strategy: EPA’s Clean Air Interstate Rule (CAIR) and Clean Air Mercury Rule (CAMR) will 

reduce SO2 and NOx 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 economic 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). (Recently, EPA updated their input data and 

developed Base Case v.3.0. Due to timing, 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 using more current data about EGUs with 

more realistic fuel prices, creating an IPM 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 

75
Mid-Atlantic/Northeast Visibility Union 

444 N. Capitol Street, NW, Suite 638, Washington, DC 20001 

updated, (e.g., fuel prices, control constraints, etc.) to better reflect 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 NOx emission 

caps and higher SO2 retirement ratios. Consistent with 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 current information. The 

MARAMA CAIR Plus run is also sometimes referred to as MARAMA_4c. 

ASSUMPTIONS 

• The assumptions for and results of the MARAMA 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 Integrated Planning Model (IPM), May 30 2007. 

• For purposes of this analysis, the CAIR region included all states included 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 the 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 NOx 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

AR

TX

LA

WI

MI

IL IN OH

KY

TN

MS AL GA

FL

SC

NC

VA

WV

PA

NY

ME VT

NH 

MD 

DE 

NJ CT IA

MA

DC 

CAIR Plus Policy 

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Mid-Atlantic/Northeast Visibility Union 

444 N. Capitol Street, NW, Suite 638, Washington, DC 20001 

overall reduction in NOx emissions to be achieved through the implementation of CAIR Plus 

as compared to CAIR. 

 Table 3: NOx Budgets in the CAIR/CAIR Plus Region (Thousand Tons) 

NOx Ozone Season Budget NOx 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 NOx Compliance Supplement Pool of 199,997 tons included in 2009. 

Note: The 2015 budgets as modeled in IPM are the average of the budgets over the period 2013-2017. The 

actual ozone season NOx budgets proposed are 485 thousand tons in CAIR and 382 thousand tons in CAIR plus 

for 2015. The actual annual NOx 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 CAIR Plus run required a greater 

number of SO2 allowances be retired for each ton of pollution discharged. This effect of this 

was to reduce the total amount of SO2 emissions allowed within the CAIR Plus region. 

 Table 4: SO2 Allowance Retirement Ratios in the CAIR/CAIR Plus Region 

SO2 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 retirement 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 emission 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 that CAIR Plus would reduce national SO2 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 SO2 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.) 

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Mid-Atlantic/Northeast Visibility Union 

444 N. Capitol Street, NW, Suite 638, Washington, DC 20001 

• The report also projects that CAIR Plus would reduce national NOx emissions in 2018 from all 

fossil and non-fossil fuel-fired Electric 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 annualized incremental cost of the CAIR Plus policy (over and 

above the cost of the CAIR program) would be $2.57 Billion (1999$) in 2018 (Table 5). This 

includes the annualized capital costs of new control equipment and new plants, fuel costs, and 

variable and fixed operation and maintenance costs. This is a 2% increase (Table A5.8). 

• The report projects that the marginal cost of SO2 emission reductions as manifested in the 

projected SO2 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 CAIR Plus, in the US an additional 17 gigawatts (GWs) of coal 

plant capacity would be controlled by SO2 scrubbers and an additional 65 GW controlled by 

SCR (for NOx) 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 lower emission intensive fuel and plant types, 

including more IGCCs (pp. 16-17); and 

o natural gas-fired generation would increase 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 SO2

scrubber feasibility constraints were no longer applied in the CAIR Plus strategy. In 

years after 2012, the CAIR Plus SO2 and NOx policies continue to become more 

stringent resulting in an increase in natural gas-based generation. (See p. 15.) 

MORE INFORMATION

• The final draft ICF report summarizing the results 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 state have participated in reviewing draft materials prepared under this project. 

Team members include: 

New Hampshire: Andy Bodnarik, Liz Nixon, Jeff Underhill New Jersey: 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, Brian 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) 

78
Summary of Work 
 

Baseline, Natural Conditions, and Uniform Rate

1) Baseline and Natural Background 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/regional-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/topics/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0

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MANE-VU Emissions Inventory Data and Documentation - June 2007

I. 2002 Emissions Inventory

MANE-VU 

Contractor: Pechan – Randy Strait 

Documentation and Database 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 conversion 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/Inventory%20Summary/FutureEmissionsInventory.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. 

80
• 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 Venkatesh & 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 using for all of our base case CMAQ 

modeling.

• 2009/12/18 VISTAS 2.1.9 IPM output was converted 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 inventory. (Alpine – Greg Stella) 

IV. MANE VU Inventories for Sensitivity Analysis 

• MANE-VU Fuel Oil sulfur content sensitivity 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 subject to emissions trading. Therefore 

81
restrictions on the sulfur content of these fuels would free up allowances in the 

market that would be used elsewhere, resulting 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 Inventory 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%20Summary/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. 

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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 MANE-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 Database files can be found at

http://www.marama.org/visibility/ResWoodCombustion/ 

MARAMA has provided two updates of the National Emissions Inventory for residential 

wood combustion. Some states have chosen to use some of these results in preparing 

their 2002 inventories. In general, these updates are part of an ongoing process to refine 

information about this source category as it is a large source of emissions with very 

uncertain emission estimates. 

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BART

1) Five-Factor Analysis of BART-Eligible Sources: 2/2007 

 Survey of Options for Conducting BART Determinations 

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

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Areas of Influence

1) Contributions to Regional Haze in the Northeast and 8/2006 

 Mid-Atlantic United States, 122 pages + Appendices A-D 

 http://www.nescaum.org/documents/contributions-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 Subcontract: Manuscripts on Data from 2/2006 

 the 2002 MANE-VU UMD Flights 

 www.nescaum.org/topics/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0

4) Upper Air Balloon Study – Millersville, PA, Winter 2004 2/2006 

 www.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 Characterization in Support of MANE-VU, 17 pages 

 http://www.nescaum.org/topics/regional-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/regional-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/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50 

85
 

9) Trajectory Analysis of Potential Source Regions Affecting Class I 2/2002 

 Areas in the MANE-VU Region, Technical Memo #3, 32 pages 

 http://www.nescaum.org/topics/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50

10) REMSAD Modeling Exercises, Technical Memo #2, 44 pages 2/2002 

 http://www.nescaum.org/topics/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50

11) GIS Mapping of Regional Haze-Related Data in the 2/2002 

 MANE-VU Region, Technical Memo #4, 41 pages 

 http://www.nescaum.org/topics/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50

12) Updated Visibility Statistics for the MANE-VU Region, 2/2002 

 Technical Memo #1, 50 pages 

 http://www.nescaum.org/topics/regional-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 Feasibility Assessment, 3 pages 1/2002 

 http://www.nescaum.org/topics/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50

15) Determination of Fine Particle and Coarse Particle Concentrations 12/1999 

 in the Northeast United States, 1995, 85 pages 

 http://www.nescaum.org/topics/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50 

86
Reasonable Progress and Long Term Strategy

1) Reasonable Progress Goal Project 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 Regional 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 Technical 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

87
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 Under 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/regional-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/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=0 

88
12) Haze Communication Using CAMNET and IMPROVE Archives: 1/2005 

 Case Study at Acadia National Park, 13 pages 

 http://www.nescaum.org/topics/regional-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/regional-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/regional-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/regional-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/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50

89
Miscellaneous

1) TSD on Measures to Mitigate the Visibility 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/regional-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/regional-haze/regional-hazedocuments/atct_topic_view?b_start:int=50

90