10-1 10.0 Long Term Strategy

40 CFR Section 51.308(d)(3) requires states like New York to submit long-term strategies that address regional haze visibility impairment for each Class I

Federal area located within and each Cla ss I Federal area located outside the states which may be affected by emissions from within the states. The long-term strategy must include enforceable emissi ons limitations, compliance schedules and other measures necessary to achi eve reasonable progress goals established by the states where the Class I areas are lo cated. While much of the material in

this section describes MANE-VU
= s development of a long term strategy regionwide, this section also describes how New York will meet the long-term strategy requirement and demonstrates that the pr ograms to be implemented in New York meet reasonable control levels to address progress.

This long term strategy addresses visib ility impairment for each of the following Class I areas: Acadia National Park, Brigantine Wilderness, Great Gulf Wilderness, Lye Brook Wilderness, Pr esidential Range/Dry River Wilderness, Moosehorn National Wildlife Refuge, and Roosevelt/Campobello International Park. As explained in the sections that follow, these are the Class I areas whose visibility has been determined to be affected by emissions from within New York.

There are no federal Class I areas in New York.

The long term strategy outlined in this section includes descriptions of how enforceable emissions limitations, co mpliance schedules, and other measures necessary to achieve the reasonable progress goals established for the above Class I areas will be used to achieve the visibility goals in each of the Class I areas mentioned above. Some have already been adopted by New York, while others are either planned for adoption or will be adopted as determined to be

reasonable at a later date after further c onsideration and review at the five-year reevaluation periods. Controls are discussed in several portions of this document, with most detail in Sections 9.4, 10.3 and 10.4.

10.1 Overview of the Long Term Strategy Development Process

As a participant in MANE-VU, New York State supported an approach that

determined which control measures to pursue that was based on technical analyses documented in several reports including the following:

- Contributions to Regional Haze in the Northeast and Mid-Atlantic United States (called the Contribution Assessment), (prepared by NESCAUM 8/1/06), - Comparison of CAIR and CAIR Plus Proposal using the Integrated Planning Model 7 (called the CAIR + Report [Final Draft Report]), (prepared by MARAMA 5/30/07),10-2 - Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas (called the Reasonabl e Progress Report), (prepared by NESCAUM 7/9/07), and - Five-Factor Analysis of BART-Eligible Sources (called the BART 5 Factor Report), (prepared by NESCAUM 6/1/07).

The regional strategy development proce ss identified reasonable measures that would reduce emissions contributing to visibility impairment at Class I areas affected by emissions from within the MANE-VU region by 2018 or earlier. The technical basis for the long term strategy is discussed in Section 10.2. This section describes the process of identifying potential emission reduction strategies.

10.1.1 Regional Process of I dentifying Potential Strategies

MANE-VU reviewed a wide range of potent ial control measures to reduce emissions from sources contributing to visibility impairment in affected Class I areas. The process by which MANE-VU arrived at a set of proposed regional haze control measures to pursue for t he 2018 milestone started in late 2005 in conjunction with efforts to identify m easures to reduce ozone pollution. The Ozone Transport Commission (OTC) selected a contracting firm to assist with the analysis of ozone and regional haze control measure options. OTC provided the

contractor with a A master list @ of some 900 potential control measures, based on experience and previous state implement ation plan work. With the help of an internal OTC control measure workgroup, t he contractor also identified 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 (CAIR+) sulf ate reductions from electricity generating units (EGUs), low-sulfur heat ing oil (residential and commercial), and controls on 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 contro l measure selection process was to

further refine the interim list. The CA IR+ Report mentioned above documents the analysis of the cost of additional SO2 and NO x controls at EGUs in the Eastern U.S. The Reasonable Progress Report documents the assessment of control

measures for EGUs and the other sour ce categories selected for analysis. Further analysis is provided in the NESCAUM document entitled, A Assessment of Control Technology Options for BART-Elig ible Sources: Steam Electric Boilers, Industrial Boilers, Cement Plant s and Paper and Pulp Facilities. @

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 st rategy gained traction after a NESCAUM-10-3 initiated conference with refiners and fuel -oil suppliers concluded that such a strategy could realistically be implement ed in the 2014 timeframe. Thus the lowsulfur heating oil and the oil-fired ICI boile r 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 measur es to make further refinements. States determined, for example, that there may be too few coal-fired ICI boilers in the

MANE-VU states for that to be considered as a A regional @ strategy, but could be a sector pursued by individual states. T hey also determined that lime and cement kilns, of which there are few in the MANE-VU region, would likely be handled via the BART determination process, which will be the case for New York. Residential wood burning and outdoor wood boilers remained on the list for those states where localized visibility im pacts may be of concern even though emissions from these sources are primar ily organic carbon and direct particulate matter. 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.

10.2 Technical Basis for Emission Reduction Obligations

40 CFR Section 51.308(d)(3)(iii) requires st ates/tribes to document the technical

basis for the state
= s/tribe

= s apportionment of emission reductions necessary to meet reasonable progress goals in each Class I area affected by the

state = s/tribe

= s emissions. The Department relied on technical analyses developed by MANE-VU to demonstrate that emission reductions in New York,

when coordinated with those of other States and Tribes are sufficient to achieve reasonable progress goals in Class I areas affected by New York. MANE-VU

= s technical documentation of the emi ssion reductions necessary to meet reasonable progress goals in each Class I area affected by New York is summarized in the following sections of this SIP and in additional documentation

referenced in those sections and below:

- Baseline and Natural Background Visibility Conditions C Considerations and Proposed Approach to the Calculation of Baseline and Natural Background Visibility Conditions at MANE-VU Class I Areas (NESCAUM, December 2006), Appendix L

- The Nature of the Fine Particle and Regional Haze Air Quality Problems in the MANE-VU Region: A Conceptual Descr iption (NESCAUM, November 2006), Appendix M

- Contributions to Regional Haze in the Northeast and Mid-Atlantic United States (NESCAUM, August 2006) (ca lled the Contribution Assessment),10-4 (Appendix A)

- Comparison of CAIR and CAIR Plus Proposal using the Integrated Planning

Model 7 (called the CAIR+ Report) (ICF, May 2007), (Appendix T)

- Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas (MACTEC, July 2007) (called the Reasonable Progress Report), (Appendix J)

- Five-Factor Analysis of BART-Eligible Sources: Survey of Options for Conducting BART Determinations (July, 2007), (Appendix Q)

- Assessment of Control Technology Op tions for BART-Eligible Sources: Steam Electric Boilers, Industrial Bo ilers, Cement Plants and Paper and Pulp Facilities (NESCAUM, March 2005), (Appendix U)

- MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionmen t, and Control Measure Benefits (NESCAUM, February 2008), (Appendix R)

- 2018 Visibility Projections (NESCAUM, March 2008), (Appendix V). In addition, New York relied on analysis conducted by neighboring RPOs, including the following documents, wh ich are available but are not incorporated into this SIP;

- VISTAS Reasonable Progress Analysis Plan by VISTAS, dated September
18, 2006

http:// www.vistas-sesarm.org/docum ents/VISTASReasonableProgress_Sep182006.pdf

- Reasonable Progress for Class I Areas in the Northern Midwest-Factor Analysis, by EC/R, dated July 18, 2007

http://www.ladco.org/docs2/MRPO%20Report_071807.pdf

40 CFR Section 51.308(d)(3)(iii) requires stat es to document the technical basis for the apportionment of emission reductions nec essary to meet reasonable progress goals in each Class I area affected by the state

= s emissions. New York relied on technical analyses and weight-of-evidence assessments developed by MANE-VU to demonstrate that emission reductions, when coordinated with those of other states, are sufficient to achieve reasonable progress goals in Class I areas affected by emissions from New York. To assess the degree to which specific geographic regions or states are contributing to vi sibility impairment at MANE-VU Class I areas, a weight-of-evidence approach was used that relies on several independent

methods to determine the sources of visib ility impairing pollutants. A weight-of-10-5 evidence assessment is intended to support anal ytical results that might otherwise have relied on the use of a single model by itself. The weight-of-evidence analysis included the use of models, including Eu lerian (grid-based) source models and Lagrangian (air pollution-based) source disper sion models. Additionally, other data analysis techniques were applied, such as source apportionment models, back trajectory calculations, and the use of m onitoring and inventory data. The modeling efforts provided a definitive basis for a weight-of-evidence assessment of state contributions. The weight-of-evidence analysi s conducted for this submission can be found in Contributions to Regional Haze in the Northeast and Mid-Atlantic United States, (prepared by NESCAUM 8/1/06), Appendix A.

The demonstration of attainment of r easonable progress goals relies on the analysis

of monitored and modeled data in a wei ght of evidence analysis to determine whether visibility is improved on days when it is usually poor and does not deteriorate on days when it is usually good. Current visibility is estimated from monitored components of PM2.5 and coarse mass. Models are used in a relative

sense to estimate how current concent rations respond to emission reduction measures. Data analysis is used to identif y source categories and regions. Current concentrations of particulate matter components are adjusted by the relative modeled response to estimate concentrations at the end of the first implementation period in 2018.

Future visibility is estimated from predi cted component concentrations of PM2.5 and coarse particulate matter at the end of the first implementation period. The difference between present visibility and futu re estimated visibility is compared with the reasonable progress goal to determine if the goal is met. The MANE-VU technical report on current visibility conditions is found in Appendix D, Updated Visibility Statistics for the MANE-VU Region . The inventories and supporting data that were prepared included: county-level, mass emissions and modeling inventories of 2002 emissions for the State and local agenc ies; temporal, speciation, and spatial allocation profiles; wildfires, prescribed bur ning, and agricultural field burning for the southeastern provinces of Canada; as well as inventories for other RPOs, Canada, and Mexico. The inventory includes emissions for sulfur dioxide (SO2), oxides of nitrogen (NOx), volatile organic com pounds (VOC), carbon monoxide (CO), ammonia (NH3), and particulates, pr imary PM10 and PM2.5. The modeling methodology appears in the Technical Support Document for 2002 MANE-VU SIP Modeling Inventories, Version 3 , (prepared by Pechan, published by MANE-VU 11/20/06), Appendix H. Details on the devel opment of project ed inventories are found in Appendix E, Development of Emission Projections for 2009, 2012 and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region . The following sections discuss the pollutants, source regions, and types of sources considered in developing this long term strategy.10-6 10.2.1 Visibility Impairing Pollutants

40 CFR Section 51.308(d)(3)(iv) requires stat es to identify all anthropogenic sources of visibility impairment considered by the state in developing its long-term strategy.

EPA
= s Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program (June, 2007) notes that this proc ess begins with the identification of key pollutants and source categories that contri bute to visibility impairment at the Class I area(s) affected by emissions from the st ate. Finalized in August 2006, the MANEVU Contribution Assessment reflects a c onceptual model in which sulfate emerges as the most important single constituent of haze-forming fine particle pollution and the principal 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 resu lt of the dominant role of sulfate in the formation of regional haze in the Nort heast and Mid-Atlantic region, MANE-VU

concluded that an effective emissions management approach would rely heavily on broad-based regional SO2 control efforts in the eastern United States. The following figure shows the dominance of sulfate in the extinction calculated from the 2000-

2004 baseline data.

Figure 10-1 - Contributions to PM 2.5 Extinction at Seven Class I Sites10-7 10.2.2 Contributing States and Regions

The MANE-VU Contribution Assessment us ed various modeling techniques, air quality data analysis, and emissions inventor y analysis to identify source categories and states that contribute to visibility im pairment in MANE-VU Class I areas. With respect to sulfate, based on estimates from four different techniques, the

Contribution Assessment estimated emissi ons from within MANE-VU in 2002 were responsible for about 25-30 percent of t he sulfate at MANE-VU and nearby Class I areas. (See Chapter 8 of the Contributi on Assessment.) Emissions from other regions, Canada, and outside the modeling domain were also important.

Table 10-1, below, shows the results of one of the four methods of assessing stateby-state contributions to sulfate impacts (the REMSAD model). This table highlights the importance of emissions from outsi de the MANE-VU region. Note that percentage contributions differ between methods.

Table 10-1 - Percent of Modeled Sulfate Due to Emissions from Listed States 1

Contributing Acadia Brigantine Dolly Great Gulf Lye Moosehorn Shenandoah

Connecticut 0.76 0.53 0.04 0.48 0.55 0.56 0.08

Delaware 0.96 3.20 0.30 0.63 0.93 0.71 0.61

District of

C l bi 0.01 0.04 0.01 0.01 0.02 0.01 0.04

Maine 6.54 0.16 0.01 2.33 0.31 8.01 0.02

Maryland 2.20 4.98 2.39 1.92 2.66 1.60 4.84

Massachusetts 10.11 2.73 0.18 3.11 2.45 6.78 0.35

New Hampshire 2.25 0.60 0.04 3.95 1.68 1.74 0.08

New Jersey 1.40 4.04 0.27 0.89 1.44 1.03 0.48

New York 4.74 5.57 1.32 5.68 9.00 3.83 2.03

Pennsylvania 6.81 12.84 10.23 8.30 11.72 5.53 12.05

Rhode Island 0.28 0.10 0.01 0.11 0.06 0.19 0.01

Vermont 0.13 0.06 0.00 0.41 0.95 0.09 0.01

MANE-VU 36.17 34.83 14.81 27.83 31.78 30.08 20.59

Midwest RPO 11.98 18.16 30.26 20.10 21.48 10.40 26.84

VISTAS 8.49 21.99 36.75 12.04 13.65 6.69 33.86

Other 43.36 25.02 18.18 40.03 33.09 52.83 18.71

The following two figures are from the Contribution Assessment and show another method used to identify and rank states
= contributions to sulfate at MANE-VU and nearby Class I areas using 2002 data. One simple technique for deducing the relative impact of emissions from specific point sources on a specific receptor site involves calcul ating the ratio of annual emissions (Q) to

1 Percentages based on 2002 annual average sulfate impact estimated with REMSAD model as described in MANEVU Contribution Assessment Chapter 4 and summarized on page 8-2 of the Contribution Assessment.10-8 source-receptor distance (d). This ratio is then multiplied by a factor designed to account for the effects of prevailing winds and to convert units. The use of this technique is explained in the Contribution Assessment. (See pages 4-13 and following of Contribution Assessment document.)

Based on the results of the Q/d technique, the following figures show the resulting rankings across a set of nort hern and southern Class I areas in or near MANE-VU. The first figure covers the f our northern Class I areas in MANE-VU. The second figure covers one Class I area in the southern part of MANE-VU as well as two neighboring Class I areas in t he VISTAS region. In both figures, New

York is shown to be a moderate contributor to visibility impairment, but much less

than several other MANE-VU and non-MANE-VU states. Emissions from Canada are also shown to have a significant effect.

For more details about the methods us ed to identify contributing states and regions, please see the Contributi on Assessment document, Appendix A.

Figure 10-2 - Ranked state percent sulf ate contributions to Northeast Class I receptors based on emissions divided by distance (Q/d) results adjusted for prevailing winds10-9 Figure 10-3 - Ranked state percent sulfate contributions to Mid-Atlantic Class I

receptors based on emissions divided by distance (Q/d) results adjusted for prevailing winds

0.00 0.10 0.20 0.30 0.40 0.50 0.60 0.70OHPAWVNCCanadaMDINVAKYGANYILTNMIALNJTXFLDESCMOWIMAMSKSMNOKIALACTNHARNEMEDCRIVTAnnual Average Contribution (μg/m3 SO4)

Brigantine

Dolly Sods

Shenandoah

The above three figures show that New York
= s contributions, while important, are not the most significant, with the impacts of Canada and several states outside the MANE-VU region being significantly larger than New York
= s. MANE-VU considered modeling results documented in the Cont ribution Assessment to determine which states should be consulted in developing the long term strategy for improving visibility in MANE-VU Class I areas. Becaus e sulfate was the pr imary pollutant of concern and the REMSAD model results quant ified sulfate impacts, three methods of evaluating states
= impacts using REMSAD results were considered:

1. States/regions that contributed 0.1 ug/m 3 sulfate or greater on the 20 percent worst visibility days in the base year (2002)

2. States/regions that contributed at least 2 percent of total sulfate observed on 20 percent worst visibility days in 2002

3. The top ten contributing states on t he 20 percent worst visibility days in 2002.

Each of the following seven figures show s on the left side the IMPROVE monitored

PM 2.5 mass data by species for 2000-2004 (the baseline years). The yellow, bottom portion of the bar chart is the measured su lfate concentration. The second part of each figure, in the center, shows the RE MSAD sulfate modeling results for 2002.

The middle bar chart indicates contributi ons of states and regions to the total10-10 modeled sulfate concentrations. Finally, on the right, are three maps indicating

which states met the criteria identifi ed above as the three potential methods for identifying states with the gr eatest contribution to sulfates in MANE-VU Class I areas in 2002. The top map shows states contributing at least 0.1 ug/m 3 of sulfate. The middle map shows states contributing at leas t 2 percent of total sulfate. The bottom map highlights the ten states contributing the greatest amount of the sulfate in 2002. In each of these figures, New York is shown to have either contributed 0.1 ug/m3 sulfate or greater on the 20 percent worst vi sibility days in the base year, contributed at least 2 percent of total sulfate obser ved on 20 percent worst visibility days in 2002, or to have been one of the top 10 cont ributors in each of the Class I areas shown, including the Shenandoah and Dolly Sods ar eas. Due to its proximity to New York, the proportion of sulfate impacts in the Lye Brook area are the highest. Shenandoah and Dolly Sods are Class I areas in the VISTAS region that are impacted by emissions from MANE-VU states . The other five Class I areas are in

MANE-VU. The IMPROVE monitor at Great Gulf also represents the Presidential Range/Dry River Wilderness. The IMPRO VE monitor at Moosehorn also represents Roosevelt Campobello International Park. For purposes of deciding how broadly to consult, the MANE-VU states decided to use method 2, including states that contributed at least 2 percent of total sulfate observed on the 20 percent worst visibility days in 2002. CT, DC, RI, and VT were not identified as being among the states contributing at least 2 percent of sulfate to any of the above Class I areas. However, as participants in MANE-VU, those states have agreed to pursue adoption of regional control measures in order to contribute to visibility improvement on the worst days and to the prevention of visibility degradation on clear days.10-11 Figure 10-4 - Modeled 2002 Contributions to Sulfate by State at Brigantine

Figure 10-5 - Modeled 2002 Contributions to Sulfate by State at Lye Brook10-12 Figure 10-6 - Modeled 2002 Contributions to Sulfate by State at Great Gulf

Figure 10-7 - Modeled 2002 Contributions to Sulfate by State at Acadia10-13 Figure 10-8 - Modeled 2002 Contributions to Sulfate by State at Moosehorn

Figure 10-9 - Modeled 2002 Contributions to Sulfate by State at Shenandoah10-14 Figure 10-10 - Modeled 2002 Contributions to Sulfate by State at Dolly Sods

10.2.3 Baseline Emissions

40 CFR Section 51.308(d)(3)(iii) requi res that New York identify the baseline emissions information on which the long-term strategy is based.

- For the MANE-VU region, New York used the 2002 MANE-VU Emissions Inventory Version 3.0 as its baseline inventory. The inventory is documented in Section 7 of this SIP.

- For other regions, MANE-VU used emissions inventories developed by the RPOs for those regions, including VISTAS Base G2,

MRPO

= s Base K, and CenRAP

= s emissions inventory.

More specific information about the baseline emissions inventory data used may be found in the inventory sect ion of this SIP, Section 7.0.10-15 10.2.4 Modeling Techniques Used

The following documents describe pre liminary and final modeling runs conducted by MANE-VU and used in developing this long term strategy:

− Contributions to Regional Haze in the Northeast and Mid-Atlantic United States (NESCAUM, Augus t 2006)(called the Contribution Assessment), (Appendix A)

− MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Control Measure Benefits (NESCAUM, February 2008), (Appendix R)

− 2018 Visibility Projections (NESCAUM, March 2008), (Appendix V)

As documented in the MANE-VU Contribution Assessment, two regionalscale air quality models were used to perform air quality simulations for MANE-VU. These are the Community Multi-scale Air Quality modeling system (CMAQ; Byun and Ching, 1999) and the Regional Modeling System for Aerosols and Deposition (REMSAD; SAI, 2002). CMAQ was developed by EPA, while REMSAD was developed by ICF Consulting/Systems Applications In ternational (ICF/SAI) with EPA support. CMAQ provides one-atmosphere result s for multiple pollutants while the REMSAD model was used primarily for a ttribution of sulfate species in the Eastern US via the species-taggi ng scheme included in Version 7.10 and

newer versions of the model.

Three rounds of modeling were conducted:

− CMAQ was run for a complete set of baseline simulations including 2002, 2009 and 2018. Preliminary runs are described in greater detail in Appendix C of the MANE-VU Contribution Assessment (Appendix A).

− Runs assessing impacts of potential control measures are described in MANE-VU Modeling for Reasonable Progress Goals : Model Performance Evaluation, Pollution Apportionment, and Control

Measure Benefits (NESCAUM, February 2008, Appendix R).

− Final modeling to help develop reasonable progress goals is described

in the 2018 Visibility Projections report (NESCAUM, 2008, Appendix V).

The modeling tools utilized for these analyses include MM5, SMOKE, CMAQ and REMSAD, and incorporate taggi ng features that allow for the tracking of individual source regions or measures.

A significant feature of the REM SAD work used to evaluate regional contributions is that NESCAUM reprocessed the SO 2 emission data from each state to take advantage of REMSAD

= s tagging capabilities. Thus, all10-16 SO 2 emissions included in the model for the eastern half of the country were tagged according to state of origin, and emissions from Canada and the boundary conditions were also tagged. This allowed for a rough

estimation of the total contribution fr om elevated point sources in each

state to simulated sulfate concentrations at eastern receptor sites. Using identical emission and meteorologica l inputs to those prepared for the Integrated SIP (CMAQ) platform, RE MSAD was used to simulate the annual average impact of each state
= s SO 2 emission sources on the

sulfate fraction of PM 2.5 over the northeastern United States. For more information see Appendix C of the MANE-VU Contribution Assessment, Appendix A.

In addition to the REMSAD run wit h tagging, NESCAUM and its modeling partners at the University of Mary land and Rutgers University performed a sensitivity run with the CMAQ Particle and Precursor Tagging Methodology (CMAQ-PPTM) system. This run was used to assess the impacts of potential control measures under consideration. This work is

described in the Modeling for Reasonable Progress report.

The modeling platform is further described in the reports Modeling for Reasonable Progress and 2018 Visibility Protections . MANE-VU used the Inter-RPO modeling domain. The 36-km gridded domain covers the continental US, southern Canada, and northern Mexico. The 12-km gridded inner domain covers the nort heastern, central, and southeastern

U.S. as well as southeastern Canada.

Meteorological inputs for CMAQ, provided by Dalin Zhang

= s group at the University of Maryland, were derived from the Fifth-Generation Pennsylvania State University /National Center for Atmospheric Research (NCAR) Mesoscale Model (MM5). A detailed description of the meteorological inputs can be found in the Modeling for Reasonable Progress report.

The evaluation of model performance is also described in the report on Modeling for Reasonable Progress . The modeling tools were evaluated and found to perform adequately relative to USEPA modeling guidance.

10.2.5 Monitoring and Emissions Data Analysis

Chapters 4 and 5 of the MANE-VU Contribution Assessment document the techniques for analyzing air monitoring data and emissions data used by MANE-VU to assess the contributi on of various states, regions, and source categories to visibility impai rment at MANE-VU Class I areas. Some examples of these analyses have been included here. (Figures 10- 2 and 10-3 in Section 10.2.2, above, show the results of emissions inventory analysis (Q/d) to estimate t he percent sulfate contribution from

each state on MANE-VU
= s Class I areas. Figure 10-12, in Section 10.2.6,10-17 below, shows results of source appor tionment analysis of monitoring data to assess the areas contributing to wood smoke emissions affecting

MANE-VU Class I areas.

10.2.6 Anthropogenic Sources of Visibility Impairment

40 CFR Section 51.308(d)(3)(iv) requires that New York identify all anthropogenic sources of visibility impai rment considered in developing its long-term strategy. Chapter 4 of the MANE-VU Contribution Assessment Document summarizes an analysis of haze-associated pollutant emissions. Chapter 5 of the same document describes the results of numerous source apportionment analyses, which are further explained in Appendix B of the Contribution A ssessment (Appendix A). Together, these studies identify the major sour ce categories affecting Class I areas

in and near MANE-VU. These are identified below.

10.2.6.1 Sources of SO 2 Emissions

For the reasons described above in Section 10.2.1, the emphasis in developing this SIP revision was placed on sources of SO 2 . Emissions inventory analysis shows that point sources dominated the 2002 inventory of SO2 emissions. The largest source category of sulfur dioxide in the region is electric generating units (EGUs). Additional SO 2 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. Roughly 70 percent of

the 2.3 million tons of SO 2 emission in the 2002 MANE-VU emissions inventory Version 3.0 were from EGUs, making them the largest SO 2 source category in terms of visib ility impairing emissions. MANE-VU found through modeling analysis documented in the Contribution Assessment, Appendix A, that emissi ons from specific EGUs were important contributors to visibility im pairment in MANE-VU Class I areas in 2002. The figure below shows the locations of 167 EGU stacks that impair visibility at one or more MANE-VU Class I area. Some of the stacks identified as important were outside the states identified as contributing at least 2 percent of the sulfate at MANE-VU Class I areas, these were dropped from the list. The lis t of these sources is found in the Emissions Inventory section of this document, Section 7.10-18 Figure 10-11 - 167 EGU Stacks Affect ing MANE-VU Class I Area(s)

10.2.6.2 Sources of Other Pollutants

Source apportionment documented in Appendix B of the MANE-VU Contribution Assessment (Appendix A) al so identified biomass combustion as a local source contributing to visibility impairment. According to Appendix B of the MANE-VU Contribution Assessment, woodsmoke also contributes to visibility impairment, wit h contributions typically higher in rural areas than urban areas, winte r peaks in northern areas from residential wood burning, and occasional large summer impacts at all sites from wildfires. Woodsmoke impacting MANE-VU Class I areas is more local in origin than sources of SO 2 , except for major transport events. The figure below is from Appendix B of the MANE-VU Contribution Assessment and represents the resu lts 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 highlighted section of the map shows the woodsmoke source region for several MANE-VU Class I areas represented by the stars within the se ctions. (Brigantine was not analyzed for this map.)10-19 Figure 10-12 - Woodsmoke Source Regional Aggregations

The MANE-VU Technical Support Document on Agricultural and Forestry Smoke Management in the MANE-VU Region (Appendix I) concluded that fire from land management activities was not a major contributor to regional haze in MANE-VU Class I areas, and that the majo rity of emissions from fires were

from residential wood combustion.

10.2.6.3 Identification of Key Source Categories

Based on available information about emissions and potential impacts, the MANE-VU Reasonable Progress Workgroup selected the following source categories for detailed analysis of t he four factors the Clean Air Act establishes as the basis for determining how much progress in visibility improvement is reasonable:

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

• Point and area source industrial, co mmercial and institutional boilers;

• Cement kilns;

• Lime kilns;

• The use of heating oil; and

• Residential wood combustion and open burning.

New York worked with other me mbers of the Ozone Transport

Commission and MANE-VU as described in Section 10.1 above to consider a wide variety of potential em ission reduction strategies covering a wide range of sources of SO 2 and other pollutants contributing to regional haze.10-20 10.3 Emission Reductions Due to Ongoing Air Pollution Control Programs

40 CFR Section 51.308(d)(3)(v)(A) requires New York to consider emission reductions from ongoing polluti on control programs. Significant emissions control programs will be implemented on a regional basis between the baseline period and 2018. In developing its Long Term Strategy, these emission control pr ograms were considered as discussed below. Further discussion regarding pr ograms in New York State can be found in Section 9, Reasonable Progress Goals.

MANE-VU
= s 2018 A beyond on the way @ (BOTW) emissions inventory accounts for emission controls already in place as well as emission controls that are not yet finalized as well as some emission control regulations that will be instituted as a result of this SIP. These are

discussed in this section.

The BOTW inventory was developed based on the MANE-VU 2002 Version 3.0 inventory and the MANE-VU 2018 on the books/on the way (OTB/OTW) inventory. Inventories used for other RPOs also reflect anticipated emissions controls that will be in place by 2018. The inventory

is termed A beyond on the way @ because it includes control measures that were developed for ozone SIPs which were not yet on the books in some

states. For some states it also included controls that were under consideration for regional haze SI Ps that have not yet been adopted. More information may be found in the following documents:

• Development of Emissions Projections for 2009, 2012, and 2018 for Non-EGU Point, Area, and Non-road Sources in the MANE-VU Region (MACTEC, February 2007) (Appendix E)

• Documentation of 2018 Emissions fr om Electric Generating Units in

the Eastern U.S. for MANE-VU

= s Regional Haze Modeling (Alpine Geophysics, March 2008) (Appendix W)

• MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Control Measure Benefits, (NESCAUM, February 2008) (Appendix R)

• 2018 Visibility Projections, (NESCAUM, March 2008) (Appendix V)

10.3.1 EGU Emissions Controls Expect ed by 2018 Due to Ongoing Air Pollution Control Programs10-21 Clean Air Interstate Rule (CAIR) The IPM 7 model was used to predict

future emissions from EGUs after implementation of CAIR. 2 Modifications to the output of IPM 7 made to better represent anticipated controls are described in the report Documentation of 2018 Emissions from Electric

Generation Units in the Eastern Un ited States for MANE-VU’s Regional Haze Modeling (Alpine Geophysics, March 2008) (Appendix W). CAIR will cap emissions of sulfur dioxide (SO2 ) and nitrogen oxides (NOx) in the

eastern United States. New York

= s CAIR Program became effective October 19, 2007. As discussed in preceding sections, a July 11, 2008 decision from the U.S. Court of Appeals for the District of Columbia Circuit vacated the Clean Air Interstate Rule (CAIR) and remanded the rule back to EPA. This disruption resulted in the need for both Class I states and contributing states to reevaluate the control strategies and other elements of their regional haze SIPs, which caused states to delay submissions further. Complicating this matter was EPA’s petition for rehearing and the Court’s request for a briefing asking if it should stay the mandate until EPA revises the rule in response to the remand. On December 23, 2008, the U.S. Court of Appeals for the Distric t of Columbia Circuit decided to remand the rule back to EPA without the vacatur of CAIR, but did not impose a particular schedule by which EPA must revise CAIR. The CAIR program, therefore, remains in effe ct, and the emission reductions are expected to occur in 2009 and 2010. Since CAIR has been remanded to EPA to fix its flaws and it is uncertain exactly how EPA will do this, it is not possible to determine with any amount of certainty the emission levels that will occur by 2018. One can surmise, however, that EPA would develop a program at least as stringent as CA IR. MANU-VU states determined that

Phase II level reductions were reasonable and reflect that in their selection of reasonable progress goals. New York commits to attain that level of emission reduction by 2018 to meet its reasonable progress requirement.

10.3.2 Other Point Source Contro ls Expected by 2018 Due to Ongoing Air Pollution Control Programs

Control factors were applied to the 2018 MANE-VU inventory to represent the following national, regional, or state control measures:

• NO
x SIP Call Phase I (NO
x Budget Trading Program)

• NO
x SIP Call Phase II

• NO
x RACT in 1-hour Ozone SIPs

• NO
x RACT in 8-hour Ozone SIPs

2 Although the IPM 7 model runs also anticipated the implementation of EPA = s Clean Air Mercury Rule (CAMR), that rule has since been vacated by the courts . However, it is anticipated the adjustments to the predicted SO 2 emissions from electric generating units (EGUs) used in the air quality modeling, which were

based on SO 2 controls to be installed through New York = s (and other states = ) regulations for mercury and CAIR, will have more of an impact on the air quality modeling analysis conducted for this SIP than the

vacatur of the CAMR rule.10-22 • NO
x OTC 2001 Model Rule for ICI Boilers

• 2-, 4-, 7-, and 10-year MACT Standards

• Combustion Turbine and Reciprocating Internal Combustion Engines

(RICE) MACT

• Industrial Boiler/Process Heater MACT 3

• EPA
= s Refinery Enforcement Initiative

• Acid Deposition Reduction SO 2 Budget Trading Program

In addition, states provided specific control measure information about specific sources or regulatory program s in their state. MANE-VU used state-specific data to the extent it was available.

For specific states, the measures included in this analysis reduce emissions for the following pollu tants and non-EGU point source categories due to strategies developed for purposes of reducing ozone in the Ozone Transport Region (OTR):

• NO
x measures:

o Asphalt production plants in CT, DC, NJ, and NY;

o Cement kilns in ME, MD, NY, PA;

o Glass and fiberglass furnaces in ME, MD, NY, PA;

o In addition, New York will be impl ementing controls on industrial,

commercial and institutional boilers , distributed generation sources, high electricity demand day (HEDD) operations.

These measures were included in the A Beyond on the Way @ inventory for

the states identified.

For other regions, MANE-VU used inventories developed by the RPOs for those regions, including VISTAS Base G2, MRPO

= s Base K, and

CenRAP

= s emissions inventory. (Emissions for CenRAP states in the MANE-VU modeling domain were taken from the VISTAS Base G2 inventory.)

New York Reasonably Available Control Technology (RACT) Reductions

CAA Section 172(c)(1) requires SIPs to A provide for the implementation of all reasonably available control measur es as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonably available control technology) and shall provide for attainment of the national primary ambient air quality standards. @ EPA interprets

3 The inventory was prepared before the MACT for Industrial Boilers and Process Heaters was vacated. Control efficiency was assumed to be at 4 percent for SO 2 and 40 percent for PM.10-23 Reasonably Available Control Technology (RACT) to mean A the lowest emissions limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility. @

New York State has a RACT program for sources which emit nitrogen oxides and volatile organic compounds C both major constituents of particulate matter C over certain threshold limits. Through the RACT regulations, New York State controls emissions from combustion sources, surface coating processes, graphic arts printing, and metal cleaning operations, among others.

Although emission reductions of VOC ar e not required to be addressed in this SIP, the reduction in their emissi ons are expected to improve visibility

in Class I areas as well as others. The other pollutant addressed by RACT requirements, however, is being addressed by this SIP and as such, the application of RACT in New York is of importance to the reduction of visibility impairment.

A number of additional RACT regulati ons are being instituted to update the current RACT requirements. A dditionally, the Department determined that source-specific RACT provisions presently in place also meet RACT requirements for all applicable EPA sour ce categories in operation in New York. Many permits in which these requirements appear contain conditions requiring the reassessment of RACT for the affected sources, resulting in the frequent updating of these requirements. These regulations will serve to reduce PM c oncentrations through the state in addition to ozone levels since VOCs and NOx act as precursors for both of these pollutants.

10.3.3 New York State and Federal Require ments for Particulate Matter, Sulfur and Nitrogen Oxides

Existing State Particulate Matter Measures

Part 215: Open Burning

6 NYCRR Part 215 has been revised and has been published in the New York State Register. The new version will become effective October 14, 2009. This revised regulation will allow (in any town with a total population less than 20,000) for the burning of downed limbs and branches (including branches with attached leaves or needles) less than six inches in di ameter and eight feet in length between May 15 th and the following March 15 th . The burning of all other household generated wastes is prohibited. The Department feels that the strengthened rule will reduce the impacts of pollutants such as dioxins, particulate matter and carbon monoxide. A strengthened ban will have the additional benefit of reducing forest10-24 fires and the impacts from them. Exemptions from this rule will include restricted categories such as camp fires, agricultural burning, prescribed burning, and ceremonial fires.

Existing Federal Particulate Matter Measures

Locomotive Engines and Marine Compression-Ignition Engines Final Rule

Locomotives and marine diesel engi nes are important contributors

to the nation
= s air pollution, as they emit large amounts of direct PM and NOx. In 2007, these engines accounted for approximately 25 percent of mobile source di esel PM2.5 emissions and 20 percent of mobile source NOx em issions. To dramatically reduce emissions from these engines, EPA is issuing its rule, A Control of Emissions of Air Pollution From Locomotive Engines and Marine Compression-Ignition Engines Less than 30 Liters per Cylinder. @ This final rule was effective on July 7, 2008, and set new exhaust emission standards on all types of locomotive engines, and on all types of marine diesel engines below 30 liters per cylinder displacement.

This program includes a set of near-term emission standards for newly-built engines, which will begin to be phased in starting 2009, and for existing locomotives, which would take effect as soon as 2008 but no later than 2010 (2013 for Tier 2 locomotives) B as soon as certified remanufacture system s are available. Further longterm standards would be phased in over time, starting in 2014. Provisions are also being included to reduce unnecessary locomotive engine idling. Compared to engines meeting current standards, these stricter requirem ents will ultimately result in estimated PM reductions of 90 per cent and NOx reductions of 80 percent. In addition to PM and NOx reductions, the standards will effectively reduce nonmethane hy drocarbons, carbon monoxide,

and air toxics.

New or Revised State Particulate Matter Measures

Part 227: Stationary Combustion Installations

The Department has cited a need to add PM2.5 RACT requirements to 6 NYCRR Part 227, A Stationary Combustion Installations. @ Sources with potential direct PM2.5 emissions great er than 100 tpy would be required to perform a case-by-case RACT analysis to determine the appropriateness of controls. The methods by which the RACT analysis would be

conducted will be similar to those of t he NOx RACT requirements of Part 227. The addition of this requirement would affect nearly 10 sources

within New York State.10-2510-26 Existing State Sulfur Measures

Part 225: Fuel Consumption and Use

6 NYCRR Part 225, A Fuel Consumption and Use, @ contains methods by which to reduce sulfur associated with different types of fuel use. Subpart 225-1 places rest rictions on the amount of sulfur in oil or coal which is bought or sold for the purpose of use in New

York State. These standards ar e area and facility-specific; the current standards were made effective in January 1988.

Subpart 225-4 declares that any motor vehicle diesel fuel or fuel additives sold or supplied in New York State must conform with the provisions provided in 40 CFR Part 80, Subpart I (July 1, 2003). These provisions commenced June 1, 2006 for all refiners and importers supplying diesel fuel to the State of New York, July 15,

2006 for locations in the diesel f uel distribution system downstream from refineries and import facilities except retail outlets and wholesale purchaser-consumer fa cilities, and September 1, 2006 for retail outlets and wholesale purchaser-consumer facilities. Included is a requirement for a maximum sulfur content in motor vehicle diesel fuel of 15 ppm, with some exceptions allowing for 500

ppm.

In addition to these requirements for sulfur content, subpart 225-3 addresses the volatility of gasoline. This regulation mandates a 9.0 psi Reid Vapor Pressure on gasoline sold during the ozone season. Retaining this level will limit t he amount of VOCs which vaporize

into the air.

Existing Federal Sulfur Measures

Clean Air Act Title IV B Acid Rain Program

Due to the ongoing problem of acid deposition, caused principally by the combustion of fossil fuels, Title IV of the CAA contained the goal of reducing annual emissions of SO 2 by 10 million tons from

1980 emissions levels within the c ontinental U.S. EPA proposed to meet these goals through two phases of SO 2 requirements. In CAA Section 403, EPA established an SO 2 allowance allocation and trading system.

The Phase I SO 2 requirements went into effect on January 1, 1995. Under CAA Section 404, EPA allocated allowances to sources in 21 eastern and midwest states, including New York State. A total of 445 units were held to emissions limitations by the Phase I requirements.10-27 On January 1, 2000, the emissions limitations established in CAA Section 404 were superseded by those established in the Phase II

SO 2 requirements of CAA section 405. This section served to place more stringent controls on the Phase I units, and imposed restrictions on smaller plants with oil-, coal- and gas-fired units as well. These requirements impacted over 2,000 units.

Also included in Title IV is a similar goal of reducing annual NOx emissions by 2 million tons from 1980 levels.

Nitrogen Oxides

Existing State NOx Measures

Part 210: Emissions and Labeling Requirements for Personal Watercraft Engines

6 NYCRR Part 210, A Emissions and Labeling Requirements for Personal Watercraft Engines, @ establishes an emissions reduction program for personal watercraft engines. Adopted in 2003, this regulation reduces emissions of NOx, PM and hydrocarbons past the levels achieved by federal standards.

This regulation includes lower emission certification levels beginning with model year 2006 and which become increasingly stringent; requires test procedures for new and in-use engines which guarantee compliance with the standards; establishes an environmental label program; and extends emission warranty requirements. Manufacturers must ensure that the emissions of their entire product line meet t he corporate average requirement.

CARB

= s average requirement declines through the 2008 model

year.

Part 217: Motor Vehicle Emissions

Included in 6 NYCRR Part 217, A Motor Vehicle Emissions, @ effective October 30, 2002, are pr ovisions which curb NOx, PM, hydrocarbon and carbon monoxide emissions from motor vehicles in New York State. The provisions of Part 217 cover inspection and maintenance programs as well as additional requirements for heavy-duty motor vehicles.

Under Subpart 217-1, motor vehicles statewide are required to conform to certain gas cap standards and, for model year 1996 and newer motor vehicles, specific on-board diagnostic system requirements. This subpart contains additional exhaust emissions requirements for applicable motor vehi cles registered or primarily10-28 operated in the New York Metropolitan Area (which includes New York City, Long Island, and Rockland and Westchester Counties).

Subpart 217-3 contains anti-idling provisions for heavy duty vehicles. These heavy duty vehicles, which have a gross vehicle weight rating greater than 8,500 lbs. and are designed for transporting persons or properties, are not permitted to idle for

more than five minutes while t he vehicle remains motionless, unless specifically excepted.

Since June 1, 1999, all heavy duty diesel vehicles (HDDVs) requiring registration in the New York City Metropolitan Area (except for buses, municipally owned vehicles and other vehicles exempted in the subpart) were r equired by Subpart 217-5 to pass an annual diesel emissions inspection test. Beginning June 1, 2000, buses and municipally owned vehicles were also held to this requirement. This time schedule also applies for which vehicles statewide are subject to roadsi de or random inspection along public highways and quasi-public locations.

Part 218: Emission Standards for Motor Vehicl es and Motor Vehicle Engines

Section 177 of the CAA permits states to adopt new motor vehicle

emissions standards that are identical to California's. New York has exercised this option in 6 NYCRR Part 218, "Emission Standards for Motor Vehicles and Motor Vehicle Engines," which incorporates

California's emissions standards fo r light-duty vehicles. These regulations apply to 1993, 1994, 1996 and newer model year

vehicles.

The Low Emission Vehicle (LEV) regulations provide flexibility to auto manufacturers by allowing them to certify their vehicle models

to one of several different emissions standards. These consist of several different tiers of increasingly stringent LEV emission standards to which a manufacturer may certify a vehicle, including LEV, ultra-low-emission vehicle (U LEV), super-ultra low-emission vehicle (SULEV), and zero-emission vehicle (ZEV). The different standards are intended to provide fl exibility to manufacturers in meeting program requirements. However, manufacturers must

demonstrate that the overall fleet for each model year meets the specified non methane organic gas (N MOG) standard for that year. These requirements are progressive ly lower with each model year.10-29 New or Revised New York State NOx Measures

Part 212: General Process Emission Sources

6 NYCRR Part 212.10, which applies to both NOx and VOC emissions, requires major stationary sources to apply Reasonably Available Control Technology (RACT) to all emission points of NOx

and VOC emissions. The definition of a major stationary source depends on the location of the sour ce within the State. Sources located in the New York Metropolitan Area and Orange County have a lower major source emission threshold (25 tons per year for both contaminants) than major sour ces located outside these areas (100 tons per year for NOx and 50 tons per year for VOCs).

The Department is in the process of revising Section 212.10 to

control emissions from hot mix asphalt production. This revision will affect only minor sources, as all asphalt production plants in New York State have capped out below the major source emissions threshold. The dryer operation is the main source of emissions in asphalt production plants, as high te mperatures amid the presence of nitrogen and oxygen result in NOx formation. These NOx emissions reductions can efficiently be realized through the implementation of lo w-NOx burners and flue gas recirculation.

Because smaller burners are incom patible with these controls, the Department will use annual burner tune-ups as the suggested control strategy.

NOx emissions from large bur ners can be reduced by 25-40 percent with low-NO x burners, and by an additional 10 percent through addition of flue gas recirculation. The proposed control

methods come at reasonable costs. Low-NOx burner costs are in the range of $500-$1,250 per ton of NOx reduced, and combining these with flue gas recirculation leads to costs of $1,000-$2,000 per ton of NOx removed, as calculat ed by the Department. The annual burner tune-up requirement for sm aller burners is expected to decrease NOx emissions by approximately 10 percent.

Subpart 220-1: Portland Cement Plants

The Department will target the r eduction of NOx emissions with updates made to 6 NYCRR Part 220, "Portland Cement Plants." NOx is created during fuel com bustion for the energy-intensive formation of cement. The state will investigate RACT controls to identify a feasible way to meet these reductions. In updating the rule, the regulations concerni ng Portland Cement plants will be identified as Subpart 220-1, as new regulations for glass manufacturing plants will be introduced as Subpart 220-2.10-30 There are currently three Portl and Cement plants in New York State (three long wet kilns, and one dry kiln). Upon the introduction of NOx RACT in 1995, the Depar tment promulgated revisions to Part 220 that required owners of t hese facilities to submit a plan

that identified RACT and included a schedule for installation of RACT. An all-inclusive regulation could not be established, as the variation in technology demanded a distinct analysis and application of NOx controls that were reasonably available at the

time.

The Department may retain the same approach, where each plant owner will be required to perform a RACT analysis that will identify the level of control technology and include a schedule for

installation.

Subpart 220-2: Glass Manufacturing

The Department is proposing to impl ement a new regulation to limit the emissions of NOx formed by t he high temperatures required in glass melting furnaces. The current 6 NYCRR Part 220, "Portland Cement Plants," will be altered to include a Subpart 220-2, under which the glass manufacturing plant s within the state will be subject

to certain restrictions. New York State currently does not contain specific emission limitation requi rements, but will propose those NOx limits proposed by the OTC in their 2006 model rule.

There are several alternate control technology options to reduce NOx from glass furnaces. These include combustion modifications (low NOx burners, oxy-fuel fi ring, oxygen-enriched air staging), process modifications (fuel switching, batch preheat, electric boost), and post-combustion modifications (fuel reburn, selective catalytic reduction, selective non-catalytic r eduction). Oxy-firing has proved

to be the most effective cont rol measure by reducing NOx emissions up to 85 percent, as well as reducing energy consumption, increasing producti on rates and improving glass quality.

6 NYCRR Part 212.10, which applies to both NOx and VOC emissions, will require major glass manufacturing facilities to conduct a Reasonably Available Control Technology (RACT) analysis. The definition of a major glass manufacturing facility depends on the location of the sour ce within the State. Sources located in the New York Metropolitan Area have a lower major source emission threshold (25 tons per year) than major sources

located elsewhere in New York State (100 tons per year).10-31 Part 227-2: NOx RACT

This regulatory revision will set new more stringent NOx limits on electricity generating units. On High Electricity Demand Days (HEDD) base loaded, load following and peaking units all increase operations to meet demand. HEDDs are generally those days when the potential for ozone formation is highest (hazy, hot and humid weather). The Department is specifically moving to revise

the NOx emission limits for all boilers and combustion turbines. These emission limits are expected to result in the reduction of 35 to 40 tons per day of NOx emissions.

Part 227: Stationary Combustion Installations

6 NYCRR Part 227, A Stationary Combustion Installations @ is undergoing a number of revisions. These include stricter requirements for NOx-emitting sour ces, and a new requirement for

sources with excessive direct PM emissions.

Subpart 227-2 will be revised to include stricter control requirements for major stationary s ources that contain natural gas

and/or oil-fired Industrial/Commerc ial/Institutional (ICI) boilers,

and/or coal-fired or combined cycle/cogeneration combustion turbines. The regulation contains presumptive RACT emission limits that vary depending on the size of the boiler and type of fuel burned. Unique boiler configurations may lead to problems meeting the proposed pres umptive RACT emission limits; in such events, case-by-case RACT determinations will be made.

Part 231: New Source Review for New and Modified Facilities

Revisions to Part 231 were approved by the State Environmental Board on January 6, 2009. Part 231 has been re-titled A New

Source Review for New and Modified Facilities @ and includes new Subparts 231-3 through 231-13. The new subparts implement nonattainment New Source Review (NNSR) and attainment New Source Review Prevention of Signi ficant Deterioration (PSD).

The revised Part 231 NNSR requirements are based on New

York
= s existing NNSR program Subpart 231-2, with revisions to include selected provisions from the December 31, 2002 Federal

NSR reform rule and EPA

= s December 21, 2007 Reasonable Possibility in Recordkeeping Rule. The newly added PSD requirements are also based largely on the December 31, 2002

Federal NSR reform rule as codified at 40 CFR 52.21.10-32 Revised Part 231 changes the basis of applicability for modifications and emission reduction credits (ERCs) from an

A Emission Unit @ basis to an A Emission Source @ basis, incorporates various federal requirements, provides clarification of existing requirements, and requi res comprehensive reporting, monitoring, and recordkeeping that will conform to the requirements

of Title V. Revised Part 231 establishes a new method for determining baseline actual emissions. Baseline actual emissions are determined by using any 24 consecutive month period of emissions in the previous five y ears. All facilities (no separate baseline period for electric ut ility steam generating units) will be required to determine their baseline actual emissions using this

method.

The Department has retained existing Subpart 231-1

A Requirements for emission sources subject to the regulation prior
to November 15, 1992 @ and Subpart 231-2, A Requirements for emission units subject to the regulation on or after November 15,

1992 @ . These regulations are currently cited in many air permits issued throughout the State and re taining them will facilitate implementation and enforcement of the NSR program. Existing Subpart 231-2 was revised only to indicate that the Subpart will not apply after the effective date of revised Part 231. Thus, permit applications received on or after the effective date of revised Part 231 will be processed according to the provisions of Subparts 231- 3 through 231-13, as applicable.

As required by 40 CFR 51.307, the review of any new major stationary source or major modifica tion that would be constructed in an area that is designated attainm ent or unclassified must provide

for written notification of all a ffected Federal Land Managers of any proposed new major stationary source or major modification that may affect visibility in any Federal Class I area, advance notification

of FLMs of the intended submission of an application or notification of intent to monitor, and t he consideration of any analysis performed by the Federal Land Manager.

Additionally, reviews must be requi red of any new major stationary source or major modification that may have an impact on any mandatory Class I area if it is ident ified at least 12 months before submission of a complete permit application, or that proposes to locate in an area classified as nonattainment that may have an impact on visibility in any mandatory Class I Federal area.

Finally, the review of any major stationary source or major modification under the PSD program in New York State must also

be conducted so as to assure that the source
= s emissions will be consistent with making reasonable progress toward the national10-33 visibility goal, accounting for the costs of compliance, the time necessary for compliance, the energy and non-air quality environmental impacts of complianc e, and the useful life of the

source.

Diesel Emissions Reduction Act of 2006

New York State enacted the Diesel Emissions Reduction Act of 2006, for which rulemaking is currently underway. This initiative will require thousands of state- owned or operated diesel-powered vehicles to be retrofitted with emission control equipment to cut down on the release of exhaust particles. The benefit will be seen with existing engines which are not expected to be replaced with new, cleaner engines for some time. This regulation will provide reductions beginning in 2008, and additional reductions in 2009 and 2010, which will contribute to the a ttainment of the PM NAAQS.

Existing Federal NOx Measures

Federal Diesel Fuel

EPA
= s motor vehicle diesel fuel r egulations treat diesel engine systems and fuels as a system. The EPA motor vehicle diesel fuel regulation is an integral part of EPA regulations establishing new emission standards that were effective for model year 2007 and apply to heavy-duty highway engines and vehicles greater than 8,500 pounds GVWR.

In addition to setting emission limits for PM, the requirements

establish standards for NOx and non-methane hydrocarbons (NMHC) of 0.20 grams per br ake horsepower-hr (g/bhp-hr) and 0.14 g/bhp-hr, respectively. The NOx and NMHC standards will be phased in between 2007 and 2010 for diesel engines. The phase-in will be on a percent-of-sales basis from 2007 into 2010. Gasoline engines are also subject to these standards, with a phase-in provision that requires 50 perc ent compliance in the 2008 model year and 100 percent compliance in the 2009 model year. Flexibility provisions to assist t he transition to the new standards are included that will provide an inc entive for the early introduction of clean technologies. They will also provide for flexibility in adapting new technologies and existing engine-based technologies.

Because many control devices are damaged by sulfur, it is necessary to reduce the level of sulfur in motor vehicle diesel fuel from 500 ppm to 15 ppm. This rule provides for production of 15 ppm motor vehicle diesel fuel beginning on June 1, 2006. The rule became effective at downstream locations (such as terminals) on10-34July 15, 2006, and at retail locations and wholesale purchaserconsumer facilities on October 15, 2006.

Table 10-2 - Recreational Mari ne Diesel Emission Standards

Subcategory HC+NOx (g /kW-hr ) PM (g /kWImplementation

Date

dis p * < 0.9 7.5 0.40 2007

0.9 < dis p < 1.2 7.2 0.30 2006

1.2 < dis p < 2.5 7.2 0.20 2006

dis p > 2.5 7.2 0.20 2009
*engine displacement

Small Spark-Ignition Engines

The first phase of regulations to control emissions from new nonroad spark-ignition engines at or below 19 kW (25 hp) was published in July 1995 (60 FR 34582). Covered under this rule are a wide variety of new engines manufactured during or after 1997 used in, among other things, lawn and garden equipment and small construction equipment. This first phase of standards was to reduce hydrocarbon emissions by 32 percent and carbon monoxide emissions by seven percent in 2020, when complete fleet turnover

would be achieved.

A second phase of control requirements was published in March1999 (64 FR 15208), specifically for Class I and Class II nonhandheld spark-ignition engines at or below 19 kW such as lawnmowers and garden tractors. These Phase 2 requirements, which were phased in from 2001 to August 2007, will result in an estimated 51 percent reduction in combined hydrocarbon and NOx emissions by 2010, and a 59 percent reduction of these emissions by 2020.

Additional Phase 2 requirements were published by EPA in April2000 (65 FR 24268). These standards affected handheld sparkignition engines at or below 19 kW, principally those used in lawn and garden equipment such as trimmers, leaf blowers and chainsaws. An estimated 70 percent reduction of combined hydrocarbon and NOx emissions ar e expected by 2010. The standards apply to Class III, IV, and V engines, and were phased in

between 2002 and 2007.

MACT

Under Section 112 of the 1990 CAA Amendments, HAPs are required to be controlled by technology determined to be MACT.

Otherwise known as NESHAP standar ds, the Department has been10-35 adopting these control requirem ents as they have been developed by EPA and has therefore been realizing the reductions resulting from the MACT program. Many of these standards affect emissions of PM or its precur sors. Notable sources of NOx reductions include the MACT standards relating to combustion, such as the standards for Stationary Combustion Turbines, Combustion Sources at Kraft, Soda, and Sulfite Pulp & Paper Mills, and Reciprocating Internal Combustion Engines.

10.3.4 Area Sources Controls Expect ed by 2018 Due to Ongoing Air Pollution Control Programs

For area sources within MANE-VU, New York relied on MANE-VU
= s Version 3.0 Emissions Inventory for 2002. In general, the 2018 inventory for area sources was developed by MANE-VU applying growth and control

factors to the 2002 Version 3.0 invent ory. Area source control factors were developed for the following national or regional control measures:

• OTC VOC Model Rules

• Federal On-board Vapor Recovery

• New Jersey Post-2002 Area Source Controls

• Residential Woodstove NSPS

The following additional control measures were included in the 2018 analysis to reduce VOC emissions for the following area source categories for some states (as identified below):

• VOC measures: adhesives and sealants (controls added in all MANEVU states except VT),

• Emulsified and cutback asphalt paving (controls added in all MANE-VU states except DE, ME, and VT),

• Consumer products (controls added in all MANE-VU states except VT),

and

• Portable fuel containers (controls added in all MANE-VU states except VT)

After release of Version 3.0 of the MANE-VU 2002 inventory, Massachusetts revised their inventory of area source heating oil emissions due to two changes: (1) The sulfur percent used to derive the emissions factors was adjusted from 1.0 to 0.3; and (2) use of the latest DOE-EIA 2002 fuel use data instead of the prev iously used 2001 version. These two changes significantly altered the 2002 SO 2 emissions for area source heating oil combustion. Massachusetts provided revised 2002 PE and EM tables, which MACTEC used in preparing the 2009/2012/2018 projection

inventories.10-36 The District of Columbia discovered a gross error in the 2002 residential, non-residential and roadway constructi on emissions. It requested that the following values be used for the 2002 base year as the basis for the 2009/2012/2018 projections:

Table 10-3 - Corrected Construction Emissions from the District of

Columbia

Source

Classification

Code Pollutant

Code 2002 Annual Emissions(tpy)

2311010000 PM 10 -PRI 8.2933

Residential

Construction PM 25 -PRI 1.6587

2311020000 PM 10 -PRI 486.1951

Indust/Comm/Inst

Const PM 25 -PRI 97.239

2311030000 PM 10 -PRI 289.8579

Road

Construction PM 25 -PRI 57.9716

As noted above, the inventory information used for other regions was obtained from those regions
= RPOs.10-37 10.3.5 MANE-VU Consideration of C ontrols on Non-road Sources Expected by 2018 due to Ongoing Air Pollution Control Programs

MANE-VU used Version 3.0 of the MANE-VU 2002 Emissions Inventory. Non-road source controls incorpor ated into the modeling include the following:

Nonroad Diesel Rule . This rule sets standards that will reduce emissions by more than 90 percent from nonroad diesel equipment, and reduce sulfur levels by 99 percent from cu rrent levels in nonroad diesel fuel starting in 2007. This step will apply to most nonroad diesel fuel in 2010

and to fuel used in locomotives and marine vessels in 2012. (http://www/epa/gov/nonroaddiesel/ )

In its June 1994 rule (59 FR 31306) , EPA noted that nonroad engines are significant contributors of PM and its pr ecursors, which cause or contribute to air pollution which may have negative health consequences. In this rule, EPA set the first phase of emission standards for nonroad diesel engines rated 37 kW (50 hp) and above.

The final rule published in October 2006, A Control of Emissions of Air Pollution from Nonroad Diesel Engines @ (63 FR 56968) extended the previous finding to nonroad diesel engines rated below 37 kW. The rule finalizes a new set of emission standards for all nonroad diesel engines, except for locomotive engines, underground mining equipment engines, and marine engines rated at or above 37 kW. EPA finalized a set of emission standards for PM, carbon monoxide, and combined nonmethane hydrocarbons and NOx, that vary in level and implementation date depending on the rated power of the engine and other factors. These build upon the Tier 1 standards presented in the 1994 rule. The various emission limits and their implementati on dates are shown in the table

below.10-38 Table 10-4 Nonroad Diesel Emission Standards

Engine Power Tier Model Year NMHC+NOx* PM*

kW < 8 Tier 1 2000 10.5 (7.8) 1.0 (0.75)

(hp < 11) Tier 2 2005 7.5 (5.6) 0.80 (0.60)

8 < kW < 19 Tier 1 2000 9.5 (7.1) 0.80 (0.60)

(11 < hp < 25) Tier 2 2005 7.5 (5.6) 0.80 (0.60)

19 < kW < 37 Tier 1 1999 9.5 (7.1) 0.80 (0.60)

(25 < hp < 50) Tier 2 2004 7.5 (5.6) 0.60 (0.45)

37 < kW < 75 Tier 2 2004 7.5 (5.6) 0.40 (0.30)

(50 < hp < 100) Tier 3 2008 4.7 (3.5) -

75 < kW < 130 Tier 2 2003 6.6 (4.9) 0.30 (0.22)

(100 < hp < 175) Tier 3 2007 4.0 (3.0) -

130 < kW < 225 Tier 2 2003 6.6 (4.9) 0.20 (0.15)

(175 < hp < 300) Tier 3 2006 4.0 (3.0) -

225 < kW < 450 Tier 2 2001 6.4 (4.8) 0.20 (0.15)

(300 < hp < 600) Tier 3 2006 4.0 (3.0) -

450 < kW < 560 Tier 2 2002 6.4 (4.8) 0.20 (0.15)

(600 < hp < 750) Tier 3 2006 4.0 (3.0) -

kW > 560 (h 750) Tier 2 2006 6.4 (4.8) 0.20 (0.15)

*g/kW-hr (g/hp-hr)

As noted above, the inventory information used for other regions was obtained from those regions
= RPOs.

10.3.6 Mobile Source Controls Expec ted by 2018 due to Ongoing Air Pollution Control Programs

Mobile source controls incorporated into the MANE-VU modeling include the following:

Heavy Duty Diesel (2007) Engine Standard

EPA set a PM emissions standard for new heavy-duty engines of 0.01 grams per brake-horsepower-hour (g/bhp-hr), to take full effect for diesel engines in the 2007 model year. This rule also includes standards for NOx and non-methane hy drocarbons (NMHC) of 0.20 g/bhp-hr and 0.14 g/bhp-hr, res pectively. These NOx and NMHC standards will be phased in together between 2007 and 2010 for diesel engines. Sulfur in diesel fuel must be lowered to enable modern pollution-control technology to be effective on these trucks and buses. EPA will require a 97 perc ent reduction in the sulfur10-39 content of highway diesel fuel from its current level of 500 parts per million (low sulfur diesel, or LSD) to 15 parts per million (ultra-low sulfur diesel, or ULSD).

Tier 2 Motor Vehicle Standards

Tier 2 is a fleet averaging progr am, modeled after the California LEV II standards. Manufacturers can produce vehicles with emissions ranging from relatively dirty to zero, but the mix of vehicles a manufacturer sells each year must have average NOx emissions below a specified va lue. Tier 2 standards became effective in the 2005 model year and are included in the assumptions used for calculating mobile source emissions

inventories used for 2018.

Large Industrial Spark-Ignition E ngines Over 19kW and Recreational

Vehicle Rules

In 2002 EPA published a federal rule to control emissions of NOx, direct PM, hydrocarbons and car bon monoxide, titled “Control of Emissions from Nonroad Large Spark-Ignition Engines, and Recreational Engines (Marine and Land-Based)” (67 FR 68242). Subject to this rule are those large spark-ignition engines such as those found in forklifts and airport ground-service equipment, and recreational engines found in off-hi ghway motorcycles, all-terrain vehicles, and snowmobiles, as well recreational marine diesel engines. Companies that manufacture or introduce into commerce any of the subject engines or v ehicles are required to produce engines and equipment meeting the new standards.

EPA enacted a two-phase system cont rolling emissions from large spark-ignition engines. The first phase of the standards went into effect in 2004, for which a nearly 75 percent reduction in combined NOx and hydrocarbons, based on em ission measurements during steady-state operation, was expected. The second phase of requirements went into effect in 2007. These included optimization of existing technologies, and emission measurements based on a transient test cycle, which is more indicative of actual use. New requirements for evaporative emissions and engine diagnostics

were also included.

10.3.7 Summary of Timelines for Rulemaking

The table below summarizes the proposed schedule for the rulemaking required to achieve the goals of this SIP. The first two (Part 225: Fuel Composition and Use, and Part 249: Best Available Retrofit Technology ) are consistent with the A Asks @ from

the MANE-VU states with Class I areas.10-4010-41 Table 10-5 **B** Rulemaking Schedule Summary

6 NYCRR

Part Rule Name Proposal

Published in State Register Regulatory Package to

Environmental

Board* File Regulation with Secretary

of State Regulation

Effective

249 Best Available Retrofit Technology* 10/2009 02/2010 04/2010 05/2010

225 Fuel Composition and Use 07-01-11 10-01-11 11-14-11 12-31-11

231 New Source Review for New

and Modified Facilities 09-24-08 01-06-09 01-20-09 Amended filing

02-03-09 02-19-09

03-05-09

215 Open Fires 05-27-09 09-01-09 09-14-09 10-14-09

212.10 General Process Emission Sources (Hot Mix Asphalt (NOx)) 1/2010 05/2010 06/2010 07/2010

220-1 Portland Cement Plants 1/2010 05/2010 06/2010 07/2010

220-2 Glass Manufacturing 1/2010 05/2010 06/2010 07/2010

241 Asphalt Paving Production 1/2010 05/2010 06/2010 07/2010

227-2 HEDD, Boiler NOx RACT for

PM2.5 1/2010 05/2010 06/2010 07/2010

* Actual dates for Environmental Board Meetings are determined a few months

ahead of time

10.3.8 Additional Measures

Several other programs are in place for which emission reductions for PM2.5 and its precursors will be realized. These are measures to which the Department cannot commit since it does not have direct control. However, they are presented here as additional weight-of-evidence

measures.

Canadian Emission Reductions

Some portion of the particulate matter present in the air in the northern United States originates in Canada. T he sources of this contamination are the industrial and commercial operations, fossil fuel and woodburning andespecially the emissions of particulate matter and its precursors from coalfired power plants. A number of in itiatives have been put in place in Canada that will reduce emissions and have a positive effect in the air quality in the northeast United States.

The first of these are the Canada-Wi de Standards for Mercury Emissions

from Coal-Fired Electric Power Generation Plants. Under these provisions, a reduction of approximat ely 52 percent to 58 percent in10-42 mercury emissions is expected nationally by 2010. The Ontario Power Authority (OPA) has been directed to replace Ontario

= s coal-fired generation facilities by cleaner sources A in the earliest practical time frame that ensures adequate generati ng capacity and electricity system reliability in Ontario. @ The reduction in mercury emissions is expected to

have the co-benefit of the reduction of the emission of other pollutants as well, including particulate and its precursors (SO 2 and NOx), organics, metals and greenhouse gases. The replacement of coal-fired units in Ontario, which are most likely to affect New York

= s air quality, will have a significant effect on ambient particulate concentrations and haze.

The second initiative in Canada that will affect New York

= s air quality is the promulgation of air quality standards for PM2.5 and ozone at a level of 30ug/m3 on a 24-hour basis and 65 ppb on an 8-hour basis, respectively.

The intention is to meet these standar ds by 2010, the result of which will have a positive effect on New York
= s air quality as well. Quebec

= s fiveyear report on their reduction efforts to date discusses the measures taken

from 2001 to 2005. The control measur es instituted by Canada are aimed at reducing industrial emissions. S pecifically, regulations like Quebec's "Regulation respecting the quality of the atmosphere" 4 contain control measures for new and existing sources of VOC's similar to those in New York and other states, and set am bient air quality standards. VOC controls address surface coating processes, automotive painting operations, printing, dry cleaning, formaldehyde from panelboard mills, pulp and paper operations, styrene from composite material manufacturing (fiberglass and resins), and transportation. Particulate

emissions measures include the control of fugitive emissions from mining and sandblasting, granaries, mills, dist illeries, breweries, powder milk plants, fertilizer mixing plants, concrete plants, vitreous enamel operations, earthenware and ceramic products plant, polyvinyl chloride production or processing plant, wood processing plants, and aluminum manufacturing. Programs also cont rol particulate and NOx emissions from combustion operations (boilers, turbines, and internal combustion), as well as fuel sulfur content (2.0 percent by weight for "heavy oil," 1.0 percent by weight for "intermediate oil," 0.5 percent by weight for "light oil," and 2.0 percent in weight for coal). Many other categories are covered as well woodburning, smelting, charcoal kiln s, incinerators, refineries, storage tanks, metallic processing plants, as well as other industrial processes.

Additional measures are planned in the next five years to achieve their goals by 2010, including reducing emissions from residential wood heating, establishing and inspection and maintenance program for light vehicles, and implementing "other meas ures in the transportation, energy and climate change sectors."

4 http://www2.publicationsduquebec.gouv.qc.ca/dynamicSearch/telecharge.php?type=3&file=/Q_2/ Q2R20_A.htm10-43 The above measures are efforts by the Canadian or Provincial governments to improve air quality. T hey were not included in the present

attainment demonstration and will not be enforceable by New York or the federal government. However, give t he proximity to New York State, air quality improvements in Canada will ce rtainly impact New York and the

northeastern United States.

New York State

= s A 15 by 15" Initiative

New York State has initiated a clean energy plan with the goal of reducing New York's energy demand by 15 percent by 2015. The plan, known as the Energy Efficiency Portfolio Standard (or the "15 by 15 Initiative,") focuses on energy efficiency, conser vation, and investment in renewable energy sources as the keys to ac hieving economic and environmental goals. The specific goals and highlights of the plan include:

• Reduce electricity use by 15 percent from forecasted levels by the year 2015 through new energy efficiency programs in industry and government;

• Eliminate incentives in the market place that discourages utilities from conserving energy by requiring annual adjustments to rates to make utilities whole for lost revenues caused by energy efficiency programs;

and

• Establish new appliance efficiency standards and set more rigorous energy building codes.

The benefits of this plan for New York and for the environment include a reduction in the electricity that mu st be purchased, the creation of new jobs, and a reduction in emissions as a result of the need to produce less power and the substitution of clean power sources for those already in operation. The emission reductions for the A 15 by 15 Initiative" are also

estimated to result in an annual carbon dioxide reduction of about 12.8 million tons, which is the equivalent of removing 2.5 million cars from the road. The Department is not committing to the inclusion of any of these measures as part of the SIP at this time. The Department will evaluate each measure resulting from this initiati ve individually to determine if it is appropriate to be included in the SIP. The Department will need to consider among other things whet her the measure is quantifiable, enforceable, and include emissions reduc tions that are additional to other adopted SIP measures.10-44 NYSERDA Programs

The New York State Energy Res earch and Development Authority (NYSERDA) was established in 1975 and is primarily funded by state rate payers through the System Benefits Char ge (SBC). The SBC has recently been extended through June 30, 2011. NYSERDA has introduced a number of programs and services to promote energy efficiency amongst the industrial, commercial, municipal , and residential sectors throughout the state, for which they provi de technical and financial assistance.

One initiative that has seen success is the New York Energy $mart Program. NYSERDA has allocated funding towards energy efficiency programs, low-income energy affo rdability programs, and research and development projects with focuses on renewable resources, distributed generation, and combined heat and power installations. In the last five years, the New York Energy $mar t Program has created a wealth of

economic and environmental benefits:

• Approximately $198 million in annual energy savings

• 1,400 Gwh saved per year

• 860 MW in reduced demand

• Fuel savings of 3.3 Tbtu

• Annual carbon dioxide reduction equivalent to 200,000 fewer cars

• Significant annual greenhouse gas emission reductions:

- Nitrogen Oxides - 1,280 tons - Sulfur Dioxides - 2,320 tons - Carbon Dioxide - 1,000,000 tons

In addition to Energy $mart, there are m any other programs which result in

reductions of emissions of PM and its precursors. For example, the PeakLoad Reduction Program offers incentives to offset costs to companies that implement either short-te rm demand response measures, or longterm permanent demand reduction, for days in which electric demand is very high. The Enhanced Commercia l/Industrial Performance Program

contains three tiers of incentives for the installation of energy-efficient equipment resulting in reduced electrical demand and cost. A wide range of businesses, schools, universitie s, state and local governments, and other institutions are eligible fo r these incentives. And, NYSERDA

= s Alternative-Fuel Vehicle Program aims to encourage fleets to purchase vehicles powered by natural gas, propane, biofuels, and electricity, and to encourage the use of emission reduc tion technologies and anti-idling technologies for diesel vehicles.10-45 10.3.9 Source Retirement and Replacement Schedules

40 CFR Section 51.308(d)(3)(v)(D) requires states to consider source retirement and replacement schedules in developing reasonable progress goals. Source retirement and replac ement were considered in developing the 2018 emissions inventory described in Development of Emissions Projections for 2009, 2012, and 2018 for Non-EGU Point, Area, and Nonroad Sources in the MANE-VU Region (MACTEC, February 2007) (Appendix E). Retirement and replacement will be managed in accordance with existing SIP require ments pertaining to PSD and New Source Review. New York State has negotiated consent decrees with certain electric utility companies that require retirement of specific air pollution sources. Table 10-1 at the end of this section lists expected

shutdowns in the MANE-VU areas.

10.4 Additional Reasonable Strategies

40 CFR Section 51.308(d)(1)(i)(a) requires states to consider the following

four factors to determine which additi onal emission control measures are needed to make reasonable progress in im proving visibility: 1) costs of compliance, 2) time necessary for compliance, 3) energy and non-air quality environmental impacts of compli ance, 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.

10.4.1 MANE-VU Statement of June 20, 2007

The reasonable progress goals adopted by the MANE-VU Class I States represent implementation of the regional course of action set forth by MANE-VU on June 20, 2007 and entitled, A Statement of the MidAtlantic/Northeast Visibility union (MA NE-VU) Concerning a Course of Action within MANE-VU toward Assuring Reasonable Progress. @ These actions, consisting of control and ot her measures intended to reduce the emissions of visibility impairing po llutants and their precursors, are

referred to in the SIP as the A Ask. @ As such, these reasonable progress goals are intended to reflect the pursuit by MANE-VU States of a course of action including pursuing the adoption and implementation of the following

A emission management @ strategies, as appropriate and necessary:

• Timely implementation of BART requirements;

• A low sulfur fuel oil strategy in the inner zone states (New Jersey, New York, Delaware, and Pennsylvania, or portions thereof) to reduce the

sulfur content of:10-46 o Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later than 2012,

o #4 residual oil to 0.25 percent sulfur by weight by no later than
2012,

o #6 residual oil to 0.3 B 0.5 percent sulfur by weight by no later
than 2012,

o Further reduce the sulfur content of distillate oil to 15 ppm by
2016;

• A low sulfur fuel oil strategy in the outer zone states (the remainder of the MANE-VU region) to reduc e the sulfur content of:

o Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later than 2014,

o #4 residual oil to 0.25 percent-0. 50 percent sulfur by weight by no later than 2018,

o #6 residual oil to no greater than 0. 5 percent sulfur by weight by no later than 2018,

• Further reduce the sulfur content of distillate oil to 15 ppm by 2018 depending on supply and availability;

• A 90 percent or greater reduc tion in sulfur dioxide (SO 2 ) emissions from each of the electric generating unit (EGU) stacks identified by MANE-VU (Appendix P) List of Top 167 Sources , dated June 20, 2007) as reasonably anticipated to caus e or contribute to impairment of visibility in each mandatory Class I Federal area in the MANE-VU region. If it is infeasible to achiev e that level of reduction from a unit,

alternative measures will be pursued in such State; and

• Continued evaluation of other c ontrol measures including energy efficiency, alternative clean fuels, and other measures to reduce SO 2 and nitrogen oxide (NO
x ) emissions from all coal-burning facilities by 2018 and new source performance standards for wood combustion.

As stated above, this long-term strat egy to reduce and prevent regional haze will allow states up to 10 years to pursue adoption and implementation of reas onable and cost-effective NO
x and SO 2 control measures as appropriate and necessary. The schedules by which it is expected that these measures will be adopted in New York State are presented in Section 9.4.

10.4.2 Analysis of the Four Statutory Factors

MANE-VU agreed on the above additional reasonable strategies after consideration of an analysis of the f our factors that the Clean Air Act requires be considered in determining whether controls are reasonable.10-47 New York relied on analysis developed for MANE-VU in applying the four factors to a series of emission control measures. This analysis is

described in detail in the Statement of the Mid-Atl antic/Northeast Visibility Union (MANE-VU) Concerning a Cour se of Action Within MANE-VU Toward Assuring Reasonable Progress , (Appendix K) also known as the Reasonable Progress Report. The Reasonable Progress Report

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. Table 10-6 presents a summary of the four factor analysis for the source categories analyzed in the Reasonable Progress Report 5

.

5 Assessment of Reasonable Progress for Regiona l Haze in MANE-VU Class I Areas by MACTEC10-48Table 10-6 - Summary of Results from the Four Factor AnalysisSourceCategoryPrimaryRegionalHazePollutantControl Measure(s)Average Cost in2006 dollars (perton of pollutantreduction)ComplianceTimeframeEnergy and Non-AirQualityEnvironmentalImpactsRemainingUseful LifeElectricGeneratingUnitsSO2Switch to a low sulfur coal (generally<1% sulfur), switch to natural gas(virtually 0% sulfur), coal cleaning,Flue Gas Desulfurization (FGD)-Wet, -Spray Dry, or -Dry.IPM7* v.2.1.9predicts $775-$1,690. $170-$5,700 based onavailableliterature2-3 years followingSIP submittalFuel supply issues,potential permittingissues, reduction inelectricity productioncapacity, wastewaterissues50 years ormoreIndustrial,Commercial,InstitutionalBoilersSO2Switch to a low sulfur coal (generally<1% sulfur), switch to natural gas(virtually 0% sulfur), switch to a lowersulfur oil, coal cleaning, combustioncontrol, Flue Gas Desulfurization(FGD)- Wet, -Spray Dry, or -Dry.$130-$11,000based onavailableliterature.Depends on size.2-3 years followingSIP submittalFuel supply issues,potential permittingissues, control deviceenergy requirements,wastewater issues10-30 yearsCement andLime KilnsSO2Fuel switching, Dry Flue GasDesulfurization-Spray DryerAbsorption (FGD), Wet Flue GasDesulfurization (FGD), Advanced FlueGas Desulfurization (FGD).$1,900-$73,000based onavailableliterature.Depends on size.2-3 years followingSIP submittalControl device energyrequirements,wastewater issues10-30 yearsHeating Oil SO2Lower the sulfur content in the fuel.Depends on the state.$550-$750 basedon availableliterature. Thereis a highuncertaintyassociated withthis cost estimate.Currently feasible.Capacity issues mayinfluence timeframefor implementation ofnew fuel standardsIncreases infurnace/boilerefficiency, Decreasedfurnace/boilermaintenancerequirements18-25 yearsResidentialWoodCombustionPMState implementation of NSPS, Ban onresale of uncertified devices, installertraining certification or inspectionprogram, pellet stoves, EPA Phase IIcertified RWC devices, retrofitrequirement, accelerated changeoverrequirement, accelerated changeoverinducement.$0-$10,000 basedon availableliteratureSeveral years -dependent onmechanism foremission reductionReduce greenhousegas emissions,increase efficiency ofcombustion device10-15 years10-49 Guided by this analysis, MANE-VU arrived at a suite of suggested control

measures that the MANE-VU states agreed to pursue as a region. The corollary was that the MANE-VU Class I states (Maine, New Hampshire, Vermont, and New Jersey) also asked states outside of MANE-VU that also contribute to visibility impairment to pursue similar strategies for reducing sulfate emissions from sour ce sectors, or equivalent sulfate

reductions if not from the source se ctors that MANE-VU has identified for

its own sulfate reductions.

10.4.3 Best Available Retrofit Technology

BART controls are among the “reasonable” strategies included in this SIP.

BART control measures in New York are discussed in detail in Section 8 of this SIP. The schedule by which it is expected that a state BART rule will be adopted in New York State is pr esented in Section 8.4. To assess the impacts of MANE-VU states
= implementation of the BART provisions of the Regional Haze Rule for non-EGUs, NESCAUM included estimated reductions anticipated for BART-eligible facilities in the MANE-VU region in the final 2018 CMAQ modeling analysis.

Two of the facilities that have been ident ified are located in New York, as

referenced in Table 10-7. Both of t hese facilities have preliminarily been identified as candidates for BART control. However, New York is in the process of promulgating a state BART rule. After this has been completed, these facilities are expec ted to be required to prepare a BART analysis unless it is determined that t hey do not fit into the category of sources to which BART applies (i.e., they were constructed outside of the 15-year window applicability between 1962 and 1977, will be shut down, will cap out, emissions of visibility- impairing pollutants do not exceed 250 tons per year, or do not cause or c ontribute to visibility improvement in Class I areas).

Additional visibility benefits are likely to re sult from installation of controls at other non-CAIR0 BART-eligible fa cilities located in adjacent RPOs. These benefits were not accounted for in the MANE-VU modeling, since

information about final BART determinations was not available.10-50Table 10-7 - Estimated Emissions from Non-EGU BART-EligibleFacilities Located in New York Used in Final ModelingStateFacility NameUnitNameSCCCodePlant ID (from theMANE-VUInventory)Point ID (from theMANE-VUInventory)Facility Type2002Emissions(tons)2018Emissions(tons)NYKODAK PARKDIVISIONU00015102002038261400205U00015ChemicalManufacturer2379814216NYLAFARGE BUILDINGMATERIALS INC41000305007064012400001041000Portland Cement14800444010-51 10.4.4 Low-Sulfur Oil Strategy

The assumption underlying the low-sulfur fuel oil strategy is that refiners can, by 2018, produce home heating and f uel oils that contain 50 percent less sulfur for the heavier grades (#4 and #6 residual), and a minimum of 75 percent and maximum of 99.25 percent less sulfur in #2 fuel oil (also known as home heating oil, distillate, or diesel fuel) at an acceptably small increase in price to the end user. As mu ch as 75 percent of the total sulfur reductions achieved by this strategy 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 appear reasonable in comparison to cost s of controlling other sectors as

documented in the MANE-VU Reasonabl e Progress Report, estimated at $550 to $750 per ton. The MANE-VU st ates agreed that a low-sulfur oil strategy is reasonable to pursue by 2018 as appropriate and necessary. New York agrees with this assessment.

New York
= s specific measures by which this strategy will be implemented

are described in detail in Section 9.4.1.

10.4.5 EGU Strategy

MANE-VU 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 areas.

MANE-VU
= s agreed regional approach for this source sector is to pursue a 90 percent control level on SO2 em issions from these 167 stacks by 2018 as appropriate and necessary. MANE-VU has concluded that pursuing this level of sulfur reduction is both reasonable and costeffective. Even though current wet scrubber technology can achieve sulfur reductions greater than 95 percen t, historically a 90 percent sulfur reduction level includes lower average reductions from dry scrubbing technology. The cost for SO2 emissions reductions will vary by unit, and the MANE-VU Reasonable Progress report summarizes the various control methods and costs available, ranging from $170 to $5,700 per ton, with site-specific factors such as size and type of unit, fuels, etc. influencing the cost.

Nine facilities in New York contain 19 of the sources and are shown in

Table 9-4 of this document. Sect ion 9.4.1 describes the specific measures that New York commits to pursue to reduce emissions in

accordance with the overall MAVE-VU strategy.

10.4.6 Changes to Emissions by 201810-52 The emission inventory for New York projects changes to point, area and mobile source inventories by the end of the first implementation period resulting from population growth; indus trial, energy and natural resources development; land management; and air pollution control. A summary of these changes is given in Table 10-10 for emissions of sulfur dioxide. More detail is provided in:

• Development of Emissions Projections for 2009, 2012, and 2018 for NonEGU Point, Area, and Non-road Sources in the MANE-VU Region (MACTEC, February 2007) (Appendix E), and

• Documentation of 2018 Emissions fr om Electric Generation Units in

the Eastern United States for MANE-VU

= s Regional Haze Modeling (Alpine Geophysics, March 2008) (Appendix W).

Table 10-8 - Emissions from Point, Area and Mobile Sources in MANE-VU (SO 2 tpy)

Baseline 2002 2018 (with additional measures for RPG)

Area 286,921 129,656

Non-EGU 264,377 91,438

EGU Point 1,643,257 368,717

On-Road 40,091 8,757

Non-Road 57,257 8,643

Table 10-9 - Emissions from Point, Area and Mobile Sources in New York (SO 2 tpy)

Baseline 2002 2018 (with additional measures for RPG)

Area 130,409 141,408

Non-EGU 58,197 46.038

EGU Point 236,719 72,898

On-Road 10,229 1,794

Non-Road 13,288 1,686

Source:
ftp://ftp.marama.org/2018%20Best%20and%20Final %20Modeling%20Files/Summaries/10.4.5
Emissions Tables_032408.xls

10.5 Additional Measures Considered

10.5.1 Measures to Mitigate the Impacts of Construction Activities

40 CFR Section 51.308(d)(3)(v)(B) requires New York to consider measures to mitigate the impacts of construction activities. A description

of MANE-VU
= s consideration of measures to mitigate the impacts of

construction can be found in the MANE -VU Construction TSD entitled, Technical Support Document on Measures to Mitigate the Visibility10-53 Impacts of Construction Activities in the MANE-VU Region in Appendix G.

Under the ozone NAAQS, states in nonattainment of the ozone standard are required to consider construction emissions as part of the general conformity rule (only VOC and NOx em issions are reviewed). Mitigation under general conformity should be considered as a supplement to any mitigation activities performed under the regional haze rule.

10.5.2 Agricultural and Forestry Smoke Management

40 CFR Section 51.308(d)(3)(v)(E) requires states to consider smoke management techniques for the purposes of agricultural and forestry management in developing reasonable pr ogress goals. A description of

MANE-VU
= s analysis of smoke management in the context of regional haze SIPs can be found in the MANE-VU Smoke Management TSD entitled, Technical Support Document on Agricultural and Forestry Smoke Management in the MANE-VU Region in Appendix I.

In New York, prescribed fires have not been shown to significantly contribute to visibility impairment in mandatory Class I Federal areas.

Prescribed burns are those that ar e less than 10 acres in size. The regulation of prescribed burns is dealt with under 6 NYCRR Part 194. However, New York has adopted a smoke management program (SMP) outlining elective prescribed guidelines for prescribed burns that consider the possible impacts in Class I areas. These measures are described

below.

New York State has a process for author izing or granting approval to allow

certain fires. The Division of Fo rest Protection and Fire Management at the Department manages prescribed fires. A total of 23 prescribed fires treating 273 acres were conducted in New York State by the Department on Department-owned land in Regions 1, 3, 7, and 8 by the Albany Pine Bush Preserve Commission and the Long Island Nature Conservancy in 2005. During 2005, there were 208 wildfires which burned 669 acres. In 2006, there were 30 prescribed fires which treated 330 acres at the same locations listed above, and there were 231 wildfires which totaled 2,323 acres burned. The prescribed fires are conducted for wildlife and habitat management, and rare and endangered species management purposes. The prescribed burns in the Long Island Pine Barrens area also provide for hazardous fuels reduction, which minimizes wildfire risk.

New York State has encouraged wildl and owners/managers to consider alternatives to burning, which include mowing techniques, and herbicide

use for cost effective removal.

New York State has documented the steps taken prior to the burn and actions taken during and after the burn to reduce air pollutant emissions. Steps are taken to ensure that air quality impacts are minimized during burning, and the prescribed burn plans for an area of 10 acres or more10-54 must go through a State Environmental Quality Review and Department review process (USDA Forest Service lands and Department of Defense lands are exempt from the review process for all prescribed burns).

The smoke management components of burn plans are as follows:

• Actions to minimize fire emissions which include measures that will be taken to reduce residual smoke, such as rapid and complete mop-ups and mop-ups of certain fuels;

• Evaluate smoke dispersion conditions prior to authorizing fires. Burn plans should evaluate potential smoke impacts at sensitive receptors and time fires to minimize exposure of sensitive populations and avoid visibility impacts in mandatory Class I Federal areas. The plan should identify the distance and direction from the burn site to local sensitive receptor areas and to regional/interst ate areas where appropriate. Fire prescriptions submitted prior to t he day of the fire must specify minimum requirements for the atmospheric capacity for smoke dispersal such as minimum surface and upper level wind speeds, desired wind direction, minimum mixing height, and dispersion index.

• The plan should identify actions that will be taken to notify populations and authorities (e.g., local air quality managers) at sensitive receptors, including those in adjacent jurisdictions, prior to the fire. New York State has a public notification proc ess and exposure reduction process in place to reduce the impacts of burning. The plan should also identify contingency actions that will be taken during a fire to reduce the exposure of people at sensitive rec eptors if smoke intrusions occur. Appropriate short-term (less than 24-hour) contingency actions may, among other things, include:

- Notifying the affected public (especially sensitive populations) of elevated pollutant concentrations, - Suggesting actions to be taken by sensitive persons to minimize their exposure (e.g., remain indoors, avoid vigorous activity, avoid exposure to tobacco smoke and ot her respiratory irritants), - Providing clean-air facilities for sensitive persons, - Halting ignitions of any new open burning that could impact the

same area, - Analyzing the fire situation and identifying alternative management responses upon becoming aware that a fire is out of air quality prescription with regard to the air quality criteria, - Consulting State air quality m anagers regarding appropriate shortterm fire management response to abate verified impacts, - Implementing management responses that will mitigate the adverse impacts to public health, - Reporting the steps taken to mitigate adverse impacts to the public and appropriate State agencies after they have been completed.10-55 In addition, New York State has a process to evaluate potential smoke impacts at sensitive receptors and schedule fires to minimize exposure of sensitive populations and avoid visibilit y impacts in Class I areas. There are several ways to reduce emissions from a single fire. The approaches fall into four categories and their applicability varies by fuel type:

- Minimize the area burned - Reduce the fuel loading in the area to be burned - Reduce the amount of fuel to be consumed by the fire - Minimize emissions per ton of fuel consumed

New York State has a monitoring process in place to determine how fires affect visibility in Class I areas. New York

= s SMPs identify how the effects of the fire on air quality at sensitive receptors, and visibility in mandatory Federal Class I areas will be m onitored. The extent of the monitoring plan should match the size of the fire. For small fires, visual monitoring of the direction of t he smoke plume and monitoring nuisance complaints by the public may be suffi cient. Other monitoring techniques include posting personnel on vulnerable roadways to look for visibility impairment and initiate safety measur es for motorists, posting personnel at other sensitive receptors to look for smoke intrusions, using aircraft to track the progress of smoke pl umes, and continued tracking of meteorological conditions during the fire . For large fires expected to last more than one day, locating real-time PM monitors at sensitive receptors may be warranted to facilitate timely response to smoke impacts.

New York State has established a policy to issue health advisories when necessary. Air Quality Health Advisories help provide increased notice for at-risk individuals to reduce exposure to ozone and PM2.5 by taking the recommended preventative measures. The Department and the New York State Department of Health will issue Air Quality Health Advisories when Department meteorologists predict levels of pollution, either ozone or fine particulate matter (PM2.5), are expec ted to exceed an Air Quality Index (AQI) value for 100. The AQI was created by the EPA as an easy way to correlate levels of different pollut ants to one scale, with a higher AQI value leading to a greater health concern. Air Quality Health Advisories are issued with an effective date and time for locations in one of more of eight air quality regions.

Pursuant to the EPA
= s interim guidance (cited above), New York State has adopted a program that they belie ve will prevent NAAQS violations and addresses visibility impairment due to fires. This program established basic parameters: wind speed, dire ction, location, and distance to sensitive receptors.

Public education and awareness pr ograms have been implemented to explain the use and importance of fi re for ecosystem management, the implications to public health and safety, and the goals of the SMP.10-56 Wildland and air quality managers should work with the press to announce pre-fire health advisories, and post-fire results including such things as the management objectives met; smoke intrusions observed, and/or successful minimization of air quality impacts.

New York State has a program in which owners/managers must get prior authorization and a permit prior to im plementing fire plans. There must also be an approved burn plan in place, approved by the Natural Resource Supervisor in the Department region affected.

6 NYCRR Part 215 has been revised and has been published in the New York State Register. The new version will become effective October 14, 2009. More than 850 towns in New York have fewer than 20,000 people, and burning household rubbish is common practice in most of those towns. The revised regulation will ban the burning of all household rubbish. However, the revision will allow (in any town with a total population less than 20,000) for the burning of downed limbs and branches (including branches with attached leaves or needles) less than six inches in diameter and eight feet in length between May 15 th and the following March 15 th

.

10.6 Estimated Impacts of New York
= s Long Term Strategy on Visibility

40 CFR Section 51.308(d)(3)(v)(G) requi res states to address the net effect on visibility resulting from changes projected in point, area and mobile source emissions by 2018.

The emission inventory for New York State, discussed in Section 7, projects changes to point, area and mob ile source inventories by the end of the first implementation period resulting from population growth; industrial, energy and natural res ources development; land management; and air pollution control. The net effect of these emission reductions on visibility in Class I areas was discussed in the weight-of-evidence demonstration provided in Contributions to Regional Haze in the Northeast

and Mid-Atlantic United States , Appendix A, and in the Reasonable Progress Goal discussion in Section 9. 0. These reductions will allow the visibility in Class I areas to meet the reasonable progress goals through the initial time period to 2018, as well as out to 2064.

NESCAUM has conducted modeling for MANE-VU to document the impacts of the long term strategy on vi sibility at affected Class I areas. (See 2018 Visibility Projections, NESCAUM, March 2008,) Appendix V. The Class I states affected by emissions from within New York have or will have established reasonable progress goals for each of their Class I areas for 2018. The control measures included in this SIP represent the

reasonable contribution of New York toward achieving those reasonable progress goals by 2018.

The starting point for indicating progress achieved by measures included10-57 in this SIP and other MANE-VU-mem ber SIPs is the 2000-2004 baseline visibility at affected Class I areas. To calculate the baseline visibility for affected Class I areas, using 2000-2004 IMPROVE monitoring data, the deciview value for the 20 percent best days in each year were averaged together, producing a single average dec iview value for the best days. Similarly, the deciview values for the 20 percent worst days in each year were averaged together, producing a single average deciview value for the worst days.

Initial modeling to assess the impact of potential control measures is

documented in MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Control

Measure Benefits , (NESCAUM, February 2008, Appendix R). Results of the reasonable progress modeling showed that sulfate aerosol B the

dominant contributor to visib ility impairment in the Northeast
= s Class I areas on the 20 percent worst visibility days B has significant contributions from states throughout the eastern U.S. that are projected to continue in future years from all three of the eastern regional planning organizations (RPOs). An assessment of potential c ontrol measures identified a number of promising strategies that would yield significant visibility benefits beyond the uniform rate of progress and, in fa ct, significantly beyond the projected visibility conditions that would result from A on the books/on the way @ air quality protection programs. These additional measures include the adoption of low sulfur heating oil, implem entation of Best Available Retrofit Technology (BART) requirements, and additional electric generating unit (EGU) controls on select sources.

Final modeling was conducted after consultation with states in and outside of MANE-VU. Final modeling is documented in 2018 Visibility Projections (NESCAUM, March 2008, Appendix V). Emissions inventory adjustments were made for this modeling in order to better represent the likely outcome of efforts to pursue the BART, low su lfur fuel, and EGU control measures included in the MANE-VU June 20, 2007 statements and described above in Section 10.4.1, above.

Figures 10-13a through 10-13e illustra te the predicted visibility improvement by 2018 resulting from the implementation of the MANE-VU regional long term strategy by New York State as well as others. The

results for each area indicate that vi sibility improvement will occur over the period of the initial SIP (i.e., out to 2018). This improvement is compared to the Uniform Rate of Progress for affected Class I areas. All MANE-VU sites are projected to meet or exc eed the uniform rate of progress goal for 2018. In addition, no site anticipates increases in best day visibility

relative to the baseline.10-58 Figure 10-13a - Projected Visibility Impr ovement at Acadia National Park Based On 2009 and 2018 Best and Final Projections

0 5 10 15 20 25 3019851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed

20% Best Observed

20% Worst Baseline

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

20% Best 'Natural'

Figure 10-13b - Projected Visibility Im provement at Brigantine National Wildlife Refuge Based On Best and Final Modeling

0 5 10 15 20 25 30 3519851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed

20% Best Observed

20% Worst Baseline

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

20% Best 'Natural'10-59 Figure 10-13c - Projected Visibility Impr ovement at Great Gulf Wilderness Area Based on Best and Final Modeling 6

0 5 10 15 20 25 3019851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed

20% Best Observed

20% Worst Baseline

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

20% Best 'Natural'

Figure 10-13d - Projected Visibility Im provement at Lye Brook Wilderness Area Based on Best and Final Modeling

0 5 10 15 20 25 3019851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed

20% Best Observed

20% Worst Baseline

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

20% Best 'Natural'

6 The estimate for Great Gulf Wilderness Area also serves to provide an estimate for the Presidential Range/Dry

River Wilderness Area10-60 Figure 10-13e - Projected Visibility Im provement at Moosehorn National Wildlife Refuge Based on Best and Final Modeling 7

0 5 10 15 20 2519851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed

20% Best Observed

20% Worst Baseline

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

20% Best 'Natural'

10.7 New York
= s Share of Emission Reductions

40 CFR Section 51.308(d)(3)(ii) requires states to demonstrate that their implementation plans include all measur es necessary to obtain their fair

share of emission reductions needed to meet reasonable progress goals.

The emission reduction measures proposed in New York's Regional Haze SIP are anticipated to improve visib ility at MANE-VU’s Class I areas with the implementation in New York of the controls described in this

document. These measures meet the requirement of Reasonable Progress Goals under the haze program for these Class I areas, and New York commits to instituting these emission reductions through the regulatory programs described in this SIP and the other elements of Class I area states' "Ask." New York will, t herefore, meet its "fair share" of emission reductions needed to meet the applicable reasonable progress goals, satisfying its responsibilities under the Regional Haze Program and

the Act.

The modeling analysis referenced in Section 10.6, above, demonstrated

that New York
= s long-term strategy, when coordinated with other

State/Tribes

= strategies, is sufficient to meet reasonable progress goals. Additionally, applicable measures reflected in the modeling analysis have been incorporated into New York
= s long-term strategy. All other measures agreed to will be implement ed within 10 years as appropriate and necessary as consistent with the MANE-VU June 20, 2007 statement.

7 The estimate for Moosehorn National Wildlife Ref uge also serves to provide an estimate for Roosevelt/Campobello International Park.10-61 10.8 Enforceability of Emission Limitations and Control Measures

40 CFR Section 51.308(d)(3)(v)(F) requires states, including New York, to

ensure that emission limitations and control measures used to meet reasonable progress goals are enforceable. New York
= s operating permit program requires major source Title V permits to include all applicable requirements. CAA Section 110(a)(2 )(C) requires States to include a program providing for enforcement of all SIP measures and the regulation

of construction of new or modified stationary sources to meet PSD and nonattainment new source review (NNS R) requirements. New York’s SIP currently includes NNSR requirements. In addition, there is a federal implementation plan in effect for PSD requirements, which EPA currently implements in New York State.

Environmental Conservation Law (ECL) Section 19-0305 and Article 71

Sections 71-2103 and 71-2105 authoriz es the commissioner of the Department to enforce the codes, rule s and regulations of the Department

established in accordance with Article 19. The SIP is a compilation of rules and regulations that have been duly promulgated by the Department in accordance with its statutory aut hority and consistent with the State

Administrative Procedures Act. T herefore, the Department has the authority to enforce all SIP measures.

10.9 Consultation on the Long Term Strategy

40 CFR Section 51.308(d)(3)(i) requires st ates to consult with other states to develop coordinated emission strategi es. This requirement applies both

where emissions from the state are reasonably anticipated to contribute to visibility impairment in Class I areas outside the state and when emissions from other states are reasonably antic ipated to contribute to visibility impairment in Class I areas within the state.

New York has consulted with other stat es and the FLMs by participation in the MANE-VU and inter-RPO processes that developed technical information necessary for development of coordinated strategies. New York also coordinated with MANE-VU and other RPOs to develop a weight-of-evidence analysis, described below, that was used to develop

New York
= s long-term strategy. Strategy development considered the impacts of New York
= s emissions on Class I areas outside the state, since New York State does not contain any Class I areas.

A list of the consultation events, including telephone conferences and meetings, appears in Summary of Consultation Meetings and Conferences, Appendix F of this document.

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

Consultation Framework. That document set forth the following principles:10-62 1. All State (including New York), Tribal, RPO, and Federal participants are committed to continuing dialogue and information sharing in order to create understandi ng of the respective concerns and needs of the parties.

2. Continuous documentation of all communications is necessary to develop a record for inclusion in SIP submittals to EPA.

3. States alone have the authority to undertake specific measures under their SIP. This inter-RPO framework is designed solely to facilitate needed communication, coordination and cooperation among jurisdictions but does not establish binding obligation on the part of participating agencies aside from consultation.

4. There are two areas which require State-to-State and/or State-toTribal consultations ( A formal @ consultations): (i) development of the reasonable progress goal for a Class I area, and (ii) development of long-term strategies. While it is anticipated that the formal consultation will cover the technical components that make up each of these policy decision areas, there may be a need for the RPOs,

in coordination with their Stat e and Tribal members, to have

informal consultations on these technical considerations.

5. During both the formal and informal inter-RPO consultations, it is anticipated that the States and Tr ibes will work collectively to facilitate the consultation process through their respective RPOs,

when feasible.

6. Technical analyses will be transparent, when possible, and will reflect the most up-to-date info rmation and best scientific methods

for the decision needed within the resources available.

7. The State with the Class I ar ea retains the responsibility to establish reasonable progress goals. The RPOs will make

reasonable efforts to facilitate the development of a consensus

between the State with a Class I ar ea and other States affecting

that area. In instances where the State with the Class I area can not agree with such other States that the goal provides for reasonable progress, actions tak en to resolve the disagreement

must be included in the State

= s regional haze implementation plan (or plan revisions) submitted to the EPA Administrator as required under 40 CFR Section 51.308(d)(1)(iv).

8. All States such as New York, whose emissions are reasonably anticipated to contribute to visib ility impairment in a Class I area, must provide the Federal Land Manager ( A FLM @ ) agency for that Class I area with an opportunity for consultation, in person, on their10-63 regional haze implementation plans . The States/Tribes will pursue the development of a memorandum of understanding to expedite

the submission and consideration of the FLM
= s comments on the reasonable progress goals and relat ed implementation plans. As required under 40 CFR Section 51. 308(i)(3), the plan or plan revision must include a description of how the State addressed any

FLM comments.

9. New York will consult with the affected FLMs to protect the air

resources of Class I areas in a ccordance with the FLM coordination requirements specified in 40 CFR Section 51.308(i) and other consultation procedures developed by consensus.

10. The consultation process is designed to share information, define and document issues, develop a r ange of options, solicit feedback on options, develop consensus advice if possible, and facilitate informed decisions by the Class I States.

11. The collaborators, including Stat es, Tribes and affected FLMs, will promptly respond to other RPO

= s/States

= /Tribes

= requests for

comments.

The document also describes a process primarily applicable to formal

consultation with states in other RPOs concerning regional haze SIP elements. Although other RPOs did not formally adopt the same process, in general, the process was followed and provided significant opportunities

for consultation with other states conc erning the long term strategy as well as reasonable progress goals.

MANE-VU consultation meetings and conference calls included those held on the following dates:

• MANE-VU Intra-Regional Consultation, March 1, 2007

At this meeting, MANE-VU members reviewed the requirements for regional haze plans, preliminary modeling results, the work being done to prepare the MANE-VU report on reasonable progress factors, and control strategy options

under review.

• MANE-VU Intra-State Consultation, June 7, 2007

At this meeting the MANE-VU Class I states adopted a statement of principles, and all MANE-VU members

discussed draft statements c oncerning reasonable controls within and outside of MANE-VU. Federal Land Managers also attended the meeting, wh ich was open to stakeholders.

• MANE-VU Conference Call, June 20, 200710-64 On this call, the MANE-VU states concluded discussions of statements concerning reas onable controls within and outside MANE-VU and agreed on the statements called the

MANE-VU A Ask, @ including a statement concerning controls
within MANE-VU, a statement concerning controls outside MANE-VU, and a statement requesting a course of action by

the U.S. EPA. Federal Land M anagers also participated in the call. Upon approval, all statements as well as the statement of principles adopted on June 7 were posted and publicly available on the MANE-VU web site.

• MANE-VU Class I States

= Consultation Open Technical Call, July
19, 2007

On this call, the MANE-VU A Ask @ was presented to states in other RPOs RPO staff, and Federal Land Managers, and an opportunity was provided to request further information. This call was intended to provide information to facilitate informed discussion at follow-up meetings.

• MANE-VU Consultation Meeting with MRPO, August 6, 2007

This meeting was held at LADCO offices in Chicago, Illinois and was attended by representatives of both MANE-VU and MRPO states as well as staff. The meeting provided an opportunity to formally present the MANE-VU A Ask @ to MRPO states and to consult with them regarding the reasonableness of the requested controls. Federal Land Manager agencies also attended the meeting.

• MANE-VU Consultation Meeting with VISTAS, August 20, 2007

This meeting was held at State of Georgia offices in Atlanta and was attended by representatives of both MANE-VU and VISTAS states as well as staff. The meeting provided an opportunity to formally present the MANE-VU A Ask @ to

VISTAS states and to consul t with them regarding the reasonableness of the requested controls. Federal Land Manager agencies also attended the meeting.

• MANE-VU B Midwest RPO Consultation Conference Call, September 13, 2007

This call was a follow-up to the meeting held on August 6 in Chicago and provided an opportunity to further clarify what was being asked of the MRPO states. The flexibility in the Ask was explained. Both MRPO and MANE-VU staff agreed10-65 to work together to facilitate discussion of further controls on

ICI boilers and EGUs.

• MANE-VU Air Directors
= Consultation Conference Call, September
26, 2007

This call allowed MANE-VU members to clarify their understanding of the A Ask @ and to provide direction to modeling staff as to how to interpret the A Ask @ for purposes of estimating visibility impacts of the requested controls.

• MANE-VU Air Directors
= Conference Call, March 31, 2008

On this call, NESCAUM presented the results of the final 2018 modeling and described the methods used to represent the impacts of the measures agreed to by the Class I States. Federal Land Manager agencies also attended this call.

New York State

= s coordination with FLMs on long-term strategy development is described in Section 4 of this SIP.

10.10 Emission Limitations and Schedules of Compliance

40 CFR Section 51.308(d)(3)(v)(C) require s states to identify additional measures to meet reasonable pr ogress goals when ongoing programs alone are not sufficient to meet the goals. Facilities located in New York State that are subject to state and f ederal applicable air regulations either have, or will have, limitations plac ed on their operations and emissions pursuant to New York
= s air program, as well as schedules by which compliance will be achieved. Likewise, when the additional emission reduction measures to which New York has committed (See Section 9.0) have been taken, the regulations will in clude the necessary provisions to ensure they are effectively im plemented and included in applicable permits.