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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 Class I Federal area located outside the 

states which may be affected by emissions from within the states. The long-term 

strategy must include enforceable emissions limitations, compliance schedules 

and other measures necessary to achieve reasonable progress goals established 

by the states where the Class I areas are located. 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 programs to be implemented in New York 

meet reasonable control levels to address progress. 

This long term strategy addresses visibility impairment for each of the following 

Class I areas: Acadia National Park, Brigantine Wilderness, Great Gulf 

Wilderness, Lye Brook Wilderness, Presidential 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, compliance 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 consideration 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 Model7 (called the CAIR + Report [Final Draft Report]), 

(prepared by MARAMA 5/30/07), 
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- Assessment of Reasonable Progress for Regional Haze in MANE-VU 

Class I Areas (called the Reasonable 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 process 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 Identifying Potential Strategies

MANE-VU reviewed a wide range of potential 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 the 2018 milestone started in late 2005 in 

conjunction with efforts to identify measures 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 Amaster list@ of some 900 potential control measures, based on 

experience and previous state implementation plan work. With the help of an 

internal OTC control measure workgroup, the contractor 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+) sulfate reductions from electricity 

generating units (EGUs), low-sulfur heating 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 control measure selection process was to 

further refine the interim list. The CAIR+ Report mentioned above documents the 

analysis of the cost of additional SO2 and NOx controls at EGUs in the Eastern 

U.S. The Reasonable Progress Report documents the assessment of control 

measures for EGUs and the other source categories selected for analysis. 

Further analysis is provided in the NESCAUM document entitled, AAssessment 

of Control Technology Options for BART-Eligible Sources: Steam Electric Boilers, 

Industrial Boilers, Cement Plants 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 strategy gained traction after a NESCAUM-
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initiated conference with refiners and fuel-oil suppliers concluded that such a 

strategy could realistically be implemented in the 2014 timeframe. Thus the lowsulfur heating oil and the oil-fired ICI boiler sector control measures merged into 

an overall low-sulfur oil strategy for #2, #4, and #6 residual oils for both the 

residential and commercial heating and oil-fired ICI boiler source sectors. 

During MANE-VU=s internal consultation meeting in March 2007, member states 

reviewed the interim list of control measures to make further refinements. States 

determined, for example, that there may be too few coal-fired ICI boilers in the 

MANE-VU states for that to be considered as a Aregional@ strategy, but could be 

a sector pursued by individual states. They also determined that lime and cement 

kilns, of which there are few in the MANE-VU region, would likely be handled via 

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 impacts may be of concern even though 

emissions from these sources are primarily 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 states/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 emission 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 ConditionsCConsiderations 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 Description (NESCAUM, November 2006), 

Appendix M 

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

States (NESCAUM, August 2006) (called the Contribution Assessment), 
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(Appendix A) 

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

Model7 (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 Options for BART-Eligible Sources: 

Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp 

Facilities (NESCAUM, March 2005), (Appendix U) 

- 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). In 

addition, New York relied on analysis conducted by neighboring RPOs, 

including the following documents, which 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/documents/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 states to document the technical basis for 

the apportionment of emission reductions necessary 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 visibility 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 visibility impairing pollutants. A weight-of-
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evidence assessment is intended to support analytical 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 Eulerian (grid-based) source models and 

Lagrangian (air pollution-based) source dispersion models. Additionally, other data 

analysis techniques were applied, such as source apportionment models, back 

trajectory calculations, and the use of monitoring and inventory data. The modeling 

efforts provided a definitive basis for a weight-of-evidence assessment of state 

contributions. The weight-of-evidence analysis 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 reasonable progress goals relies on the analysis 

of monitored and modeled data in a weight 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 concentrations respond to emission reduction 

measures. Data analysis is used to identify 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 predicted component concentrations of PM2.5 and 

coarse particulate matter at the end of the first implementation period. The 

difference between present visibility and future 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 agencies; temporal, speciation, and spatial 

allocation profiles; wildfires, prescribed burning, 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 compounds (VOC), carbon monoxide (CO), 

ammonia (NH3), and particulates, primary 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 development of projected 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. 
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10.2.1 Visibility Impairing Pollutants

40 CFR Section 51.308(d)(3)(iv) requires states 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 process begins with the identification of key 

pollutants and source categories that contribute to visibility impairment at the Class I 

area(s) affected by emissions from the state. Finalized in August 2006, the MANEVU Contribution Assessment reflects a conceptual 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 result of the dominant role of sulfate in the 

formation of regional haze in the Northeast 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 PM2.5 Extinction at Seven Class I Sites 
10-7

10.2.2 Contributing States and Regions

The MANE-VU Contribution Assessment used various modeling techniques, air 

quality data analysis, and emissions inventory analysis to identify source categories 

and states that contribute to visibility impairment in MANE-VU Class I areas. With 

respect to sulfate, based on estimates from four different techniques, the 

Contribution Assessment estimated emissions from within MANE-VU in 2002 were 

responsible for about 25-30 percent of the sulfate at MANE-VU and nearby Class I 

areas. (See Chapter 8 of the Contribution 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 outside the MANE-VU region. Note that 

percentage contributions differ between methods. 

Table 10-1 - Percent of Modeled Sulfate Due to Emissions from Listed States1

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 calculating 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.
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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 northern and southern Class I areas in or near 

MANE-VU. The first figure covers the four 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 the 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 used to identify contributing states and 

regions, please see the Contribution Assessment document, Appendix A. 

Figure 10-2 - Ranked state percent sulfate contributions to Northeast Class I 

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

prevailing winds 
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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

0.70

OHPAWVNCCanadaMDINVAKYGANYILTNMIALNJTXFLDESCMOWIMAMSKSMNOKIALACTNHARNEMEDCRIVT

Annual 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 Contribution Assessment to determine which 

states should be consulted in developing the long term strategy for improving 

visibility in MANE-VU Class I areas. Because sulfate was the primary pollutant of 

concern and the REMSAD model results quantified sulfate impacts, three methods 

of evaluating states= impacts using REMSAD results were considered: 

1. States/regions that contributed 0.1 ug/m3 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 the 20 percent worst visibility days in 2002.

Each of the following seven figures shows on the left side the IMPROVE monitored 

PM2.5 mass data by species for 2000-2004 (the baseline years). The yellow, bottom 

portion of the bar chart is the measured sulfate concentration. The second part of 

each figure, in the center, shows the REMSAD sulfate modeling results for 2002. 

The middle bar chart indicates contributions of states and regions to the total 
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modeled sulfate concentrations. Finally, on the right, are three maps indicating 

which states met the criteria identified above as the three potential methods for 

identifying states with the greatest contribution to sulfates in MANE-VU Class I areas 

in 2002. The top map shows states contributing at least 0.1 ug/m3 of sulfate. The 

middle map shows states contributing at least 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 visibility days in the base year, contributed 

at least 2 percent of total sulfate observed on 20 percent worst visibility days in 

2002, or to have been one of the top 10 contributors in each of the Class I areas 

shown, including the Shenandoah and Dolly Sods areas. 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 IMPROVE 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. 
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Figure 10-4 - Modeled 2002 Contributions to Sulfate by State at Brigantine

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

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

Figure 10-9 - Modeled 2002 Contributions to Sulfate by State at Shenandoah
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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) requires 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 section of this SIP, Section 7.0. 
10-15

10.2.4 Modeling Techniques Used 

The following documents describe preliminary 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, August 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 International (ICF/SAI) with EPA support. 

 CMAQ provides one-atmosphere results for multiple pollutants while the 

REMSAD model was used primarily for attribution of sulfate species in the 

Eastern US via the species-tagging 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 tagging features that allow for the 

tracking of individual source regions or measures. 

A significant feature of the REMSAD work used to evaluate regional 

contributions is that NESCAUM reprocessed the SO2 emission data from 

each state to take advantage of REMSAD=s tagging capabilities. Thus, all 
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SO2 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 from elevated point sources in each 

state to simulated sulfate concentrations at eastern receptor sites. Using 

identical emission and meteorological inputs to those prepared for the 

Integrated SIP (CMAQ) platform, REMSAD was used to simulate the 

annual average impact of each state=s SO2 emission sources on the 

sulfate fraction of PM2.5 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 with tagging, NESCAUM and its modeling 

partners at the University of Maryland 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 northeastern, 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 contribution of various states, regions, and 

source categories to visibility impairment 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 the 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 apportionment 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 impairment 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 Assessment (Appendix A). Together, 

these studies identify the major source categories affecting Class I areas 

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

10.2.6.1 Sources of SO2 Emissions

For the reasons described above in Section 10.2.1, the emphasis in 

developing this SIP revision was placed on sources of SO2. 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 SO2 source 

categories analyzed include oil-fired installations at residential, 

commercial, institutional, or industrial facilities; industrial, commercial, and 

institutional (ICI) boilers; and cement and lime kilns. Roughly 70 percent of 

the 2.3 million tons of SO2 emission in the 2002 MANE-VU emissions 

inventory Version 3.0 were from EGUs, making them the largest SO2

source category in terms of visibility impairing emissions. MANE-VU 

found through modeling analysis documented in the Contribution 

Assessment, Appendix A, that emissions from specific EGUs were 

important contributors to visibility impairment 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 list of these sources is found in the 

Emissions Inventory section of this document, Section 7.
10-18

Figure 10-11 - 167 EGU Stacks Affecting 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) also 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, with contributions typically higher in 

rural areas than urban areas, winter peaks in northern areas from 

residential wood burning, and occasional large summer impacts at all sites 

from wildfires. Woodsmoke impacting MANE-VU Class I areas is more 

local in origin than sources of SO2, except for major transport events. The 

figure below is from Appendix B of the MANE-VU Contribution 

Assessment and represents the results of source apportionment and 

trajectory analyses. It illustrates that the impacts of woodsmoke on 

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

MANE-VU and Canada. The highlighted section of the map shows the 

woodsmoke source region for several MANE-VU Class I areas 

represented by the stars within the sections. (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 majority 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 the 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, commercial and institutional boilers;

• Cement kilns;

• Lime kilns;

• The use of heating oil; and

• Residential wood combustion and open burning.

New York worked with other members of the Ozone Transport 

Commission and MANE-VU as described in Section 10.1 above to 

consider a wide variety of potential emission reduction strategies covering 

a wide range of sources of SO2 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 pollution 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 programs were considered as discussed 

below. Further discussion regarding programs in New York State can be 

found in Section 9, Reasonable Progress Goals. 

MANE-VU=s 2018 Abeyond 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 Abeyond 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 SIPs 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 from 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 Expected by 2018 Due to Ongoing Air Pollution

 Control Programs
10-21

Clean Air Interstate Rule (CAIR) The IPM7 model was used to predict 

future emissions from EGUs after implementation of CAIR.2 Modifications 

to the output of IPM7 made to better represent anticipated controls are 

described in the report Documentation of 2018 Emissions from Electric 

Generation Units in the Eastern United 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 District 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 effect, 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 CAIR. 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 Controls 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: 

• NOx SIP Call Phase I (NOx Budget Trading Program)

• NOx SIP Call Phase II 

• NOx RACT in 1-hour Ozone SIPs

• NOx RACT in 8-hour Ozone SIPs

 

2 Although the IPM7 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 SO2 emissions from electric generating units (EGUs) used in the air quality modeling, which were 

based on SO2 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

• NOx 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 MACT3 

• EPA=s Refinery Enforcement Initiative 

• Acid Deposition Reduction SO2 Budget Trading Program

In addition, states provided specific control measure information about 

specific sources or regulatory programs 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 pollutants and non-EGU point source 

categories due to strategies developed for purposes of reducing ozone in 

the Ozone Transport Region (OTR): 

• NOx 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 implementing controls on industrial, 

commercial and institutional boilers, distributed generation sources, 

high electricity demand day (HEDD) operations. 

These measures were included in the ABeyond 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 Aprovide for the implementation of 

all reasonably available control measures 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 SO2 and 40 percent for PM.
10-23

Reasonably Available Control Technology (RACT) to mean Athe 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 compoundsCboth major constituents of 

particulate matterCover 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 are not required to be addressed in 

this SIP, the reduction in their emissions 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 regulations are being instituted to update 

the current RACT requirements. Additionally, the Department determined 

that source-specific RACT provisions presently in place also meet RACT 

requirements for all applicable EPA source 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 concentrations 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 Requirements 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 diameter and eight feet in length 

between May 15th and the following March 15th. 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 forest 
10-24

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 engines 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 diesel PM2.5 emissions and 20 

percent of mobile source NOx emissions. To dramatically reduce 

emissions from these engines, EPA is issuing its rule, AControl 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)Bas soon 

as certified remanufacture systems 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 requirements will ultimately result in 

estimated PM reductions of 90 percent and NOx reductions of 80 

percent. In addition to PM and NOx reductions, the standards will 

effectively reduce nonmethane hydrocarbons, 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, AStationary Combustion Installations.@ Sources with 

potential direct PM2.5 emissions greater 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 the NOx RACT requirements of Part 

227. The addition of this requirement would affect nearly 10 sources 

within New York State. 
10-25
10-26

Existing State Sulfur Measures

Part 225: Fuel Consumption and Use 

6 NYCRR Part 225, AFuel Consumption and Use,@ contains 

methods by which to reduce sulfur associated with different types of 

fuel use. Subpart 225-1 places restrictions 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 are 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 fuel distribution system downstream 

from refineries and import facilities except retail outlets and 

wholesale purchaser-consumer facilities, 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 the 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 SO2 by 10 million tons from 

1980 emissions levels within the continental U.S. EPA proposed to 

meet these goals through two phases of SO2 requirements. In CAA 

Section 403, EPA established an SO2 allowance allocation and 

trading system. 

 The Phase I SO2 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 

SO2 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, AEmissions 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 the corporate average requirement. 

CARB=s average requirement declines through the 2008 model 

year. 

Part 217: Motor Vehicle Emissions 

Included in 6 NYCRR Part 217, AMotor Vehicle Emissions,@

effective October 30, 2002, are provisions 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 vehicles registered or primarily 
10-28

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 the 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 required 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 roadside or random inspection along public 

highways and quasi-public locations. 

Part 218: Emission Standards for Motor Vehicles 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 for 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 (ULEV), super-ultra low-emission 

vehicle (SULEV), and zero-emission vehicle (ZEV). The different 

standards are intended to provide flexibility 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 (NMOG) standard for that year. 

These requirements are progressively 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 source 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 sources 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 temperatures amid the presence 

of nitrogen and oxygen result in NOx formation. These NOx 

emissions reductions can efficiently be realized through the 

implementation of low-NOx burners and flue gas recirculation. 

Because smaller burners are incompatible with these controls, the 

Department will use annual burner tune-ups as the suggested 

control strategy. 

NOx emissions from large burners can be reduced by 25-40 

percent with low-NOx 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 calculated by the Department. The annual 

burner tune-up requirement for smaller burners is expected to 

decrease NOx emissions by approximately 10 percent. 

Subpart 220-1: Portland Cement Plants 

The Department will target the reduction of NOx emissions with 

updates made to 6 NYCRR Part 220, "Portland Cement Plants." 

NOx is created during fuel combustion 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 concerning 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 Portland Cement plants in New York 

State (three long wet kilns, and one dry kiln). Upon the introduction 

of NOx RACT in 1995, the Department promulgated revisions to 

Part 220 that required owners of these 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 implement a new regulation to limit 

the emissions of NOx formed by the 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 plants within the state will be subject 

to certain restrictions. New York State currently does not contain 

specific emission limitation requirements, 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 firing, oxygen-enriched air staging), 

process modifications (fuel switching, batch preheat, electric boost), 

and post-combustion modifications (fuel reburn, selective catalytic 

reduction, selective non-catalytic reduction). Oxy-firing has proved 

to be the most effective control measure by reducing NOx 

emissions up to 85 percent, as well as reducing energy 

consumption, increasing production 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 source 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, AStationary Combustion Installations@ is 

undergoing a number of revisions. These include stricter 

requirements for NOx-emitting sources, 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 sources that contain natural gas 

and/or oil-fired Industrial/Commercial/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 presumptive 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 ANew 

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 Significant 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 

AEmission Unit@ basis to an AEmission Source@ basis, 

incorporates various federal requirements, provides clarification of 

existing requirements, and requires 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 years. All facilities (no separate 

baseline period for electric utility steam generating units) will be 

required to determine their baseline actual emissions using this 

method. 

 

The Department has retained existing Subpart 231-1 

ARequirements for emission sources subject to the regulation prior 

to November 15, 1992@ and Subpart 231-2, ARequirements 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 retaining 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 modification that would be constructed in 

an area that is designated attainment or unclassified must provide 

for written notification of all affected 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 the consideration of any analysis 

performed by the Federal Land Manager. 

Additionally, reviews must be required of any new major stationary 

source or major modification that may have an impact on any 

mandatory Class I area if it is identified 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 national 
10-33

visibility goal, accounting for the costs of compliance, the time 

necessary for compliance, the energy and non-air quality 

environmental impacts of compliance, 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 attainment of the PM NAAQS. 

Existing Federal NOx Measures

Federal Diesel Fuel 

EPA=s motor vehicle diesel fuel regulations 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 brake 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 percent compliance in the 2008 model 

year and 100 percent compliance in the 2009 model year. 

Flexibility provisions to assist the transition to the new standards 

are included that will provide an incentive 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) on 
10-34

July 15, 2006, and at retail locations and wholesale purchaserconsumer facilities on October 15, 2006. 

Table 10-2 - Recreational Marine Diesel Emission Standards 

Subcategory 

HC+NOx 

(g/kW-hr)

PM 

(g/kWImplementation Date 

disp* < 0.9 7.5 0.40 2007 

0.9 < disp < 1.2 7.2 0.30 2006 

1.2 < disp < 2.5 7.2 0.20 2006 

disp > 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 March 

1999 (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 April 

2000 (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 are 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 standards, the Department has been 
10-35

adopting these control requirements 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 precursors. 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 Expected 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 inventory. 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 previously used 2001 version. These 

two changes significantly altered the 2002 SO2 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 construction 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 PM10-PRI 8.2933 

Residential 

Construction PM25-PRI 1.6587 

2311020000 PM10-PRI 486.1951 

Indust/Comm/Inst 

Const PM25-PRI 97.239 

2311030000 PM10-PRI 289.8579 

Road 

Construction PM25-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 Controls 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 incorporated 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 current 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 precursors, 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, AControl 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 implementation 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 Expected 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 hydrocarbons (NMHC) of 0.20 

g/bhp-hr and 0.14 g/bhp-hr, respectively. These NOx and NMHC 

standards will be phased in together between 2007 and 2010 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 percent reduction in the sulfur 
10-39

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 program, modeled after the California 

LEV II standards. Manufacturers can produce vehicles with 

emissions ranging from relatively dirty to zero, but the mix of 

vehicles a manufacturer sells each year must have average NOx 

emissions below a specified value. 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 Engines Over 19kW and Recreational 

Vehicle Rules

In 2002 EPA published a federal rule to control emissions of NOx, 

direct PM, hydrocarbons and carbon 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-highway 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 vehicles are required to produce 

engines and equipment meeting the new standards. 

EPA enacted a two-phase system controlling 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 emission 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 AAsks@ from 

the MANE-VU states with Class I areas. 
10-40
10-41

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. The sources of this contamination are 

the industrial and commercial operations, fossil fuel and woodburning and 

especially the emissions of particulate matter and its precursors from coalfired power plants. A number of initiatives 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-Wide Standards for Mercury Emissions 

from Coal-Fired Electric Power Generation Plants. Under these 

provisions, a reduction of approximately 52 percent to 58 percent in 
10-42

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 Ain the earliest practical time 

frame that ensures adequate generating 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 (SO2 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 standards 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 measures instituted by Canada are aimed 

at reducing industrial emissions. Specifically, 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 ambient 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, distilleries, 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 control 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 kilns, 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 measures 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.htm
10-43

The above measures are efforts by the Canadian or Provincial 

governments to improve air quality. They were not included in the present 

attainment demonstration and will not be enforceable by New York or the 

federal government. However, give the proximity to New York State, air 

quality improvements in Canada will certainly impact New York and the 

northeastern United States. 

New York State=s A15 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, conservation, and investment in renewable 

energy sources as the keys to achieving 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 marketplace 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 must 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 A15 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 initiative individually to determine if it is 

appropriate to be included in the SIP. The Department will need to 

consider among other things whether the measure is quantifiable, 

enforceable, and include emissions reductions that are additional to other 

adopted SIP measures. 
10-44

NYSERDA Programs

The New York State Energy Research and Development Authority 

(NYSERDA) was established in 1975 and is primarily funded by state rate 

payers through the System Benefits Charge (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 provide 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 affordability 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 $mart 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 many 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-term demand response measures, or longterm permanent demand reduction, for days in which electric demand is 

very high. The Enhanced Commercial/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, universities, state and local governments, and 

other institutions are eligible for 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 reduction 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 replacement 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 requirements 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 additional emission control measures are 

needed to make reasonable progress in improving visibility: 1) costs of 

compliance, 2) time necessary for compliance, 3) energy and non-air 

quality environmental impacts of compliance, and 4) remaining useful life 

of any existing source subject to such requirements. The plan must 

include reasonable measures and identify the visibility improvement that 

will result from those measures.

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, AStatement of the MidAtlantic/Northeast Visibility union (MANE-VU) Concerning a Course of 

Action within MANE-VU toward Assuring Reasonable Progress.@ These 

actions, consisting of control and other measures intended to reduce the 

emissions of visibility impairing pollutants and their precursors, are 

referred to in the SIP as the AAsk.@ 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 

Aemission 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 reduce 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 reduction in sulfur dioxide (SO2) 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 cause or contribute to impairment 

of visibility in each mandatory Class I Federal area in the MANE-VU 

region. If it is infeasible to achieve that level of reduction from a unit, 

alternative measures will be pursued in such State; and

• Continued evaluation of other control measures including energy 

efficiency, alternative clean fuels, and other measures to reduce SO2

and nitrogen oxide (NOx) emissions from all coal-burning facilities by 

2018 and new source performance standards for wood combustion. 

As stated above, this long-term strategy to reduce and prevent regional 

haze will allow states up to 10 years to pursue adoption and 

implementation of reasonable and cost-effective NOx and SO2 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 four 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-Atlantic/Northeast Visibility 

Union (MANE-VU) Concerning a Course 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 Report5. 

 5 Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas by MACTEC
10-48

Table 10-6 - Summary of Results from the Four Factor Analysis 

Source 

Category 

Primary 

Regional 

Haze 

Pollutant 

Control Measure(s) 

Average Cost in 

2006 dollars (per 

ton of pollutant 

reduction) 

Compliance 

Timeframe 

Energy and 

Quali

Environm

Impac

Electric 

Generating 

Units 

SO2

Switch to a low sulfur coal (generally 

<1% sulfur), switch to natural gas 

(virtually 0% sulfur), coal cleaning, 

Flue Gas Desulfurization (FGD)-Wet, -

Spray Dry, or -Dry. 

IPM7* v.2.1.9 

predicts $775-

$1,690. $170-

$5,700 based on 

available 

literature 

2-3 years following 

SIP submittal 

Fuel supply 

potential pe

issues, redu

electricity pr

capacity, wa

issue

Industrial, 

Commercial

, 

Institutional 

Boilers 

SO2

Switch to a low sulfur coal (generally 

<1% sulfur), switch to natural gas 

(virtually 0% sulfur), switch to a lower 

sulfur oil, coal cleaning, combustion 

control, Flue Gas Desulfurization 

(FGD)- Wet, -Spray Dry, or -Dry. 

$130-$11,000 

based on 

available 

literature. 

Depends on size. 

2-3 years following 

SIP submittal 

Fuel supply 

potential pe

issues, contr

energy requi

wastewater 

Cement and 

Lime Kilns SO2

Fuel switching, Dry Flue Gas 

Desulfurization-Spray Dryer 

Absorption (FGD), Wet Flue Gas 

Desulfurization (FGD), Advanced Flue 

Gas Desulfurization (FGD). 

$1,900-$73,000 

based on 

available 

literature. 

Depends on size. 

2-3 years following 

SIP submittal 

Control devic

requirem

wastewater 

Heating Oil SO2 Lower the sulfur content in the fuel. Depends on the state. 

$550-$750 based 

on available 

literature. There 

is a high 

uncertainty 

associated with 

this cost estimate.

Currently feasible. 

Capacity issues may 

influence timeframe 

for implementation of 

new fuel standards 

Increase

furnace/b

efficiency, De

furnace/b

maintena

requirem

Residential 

Wood 

Combustion 

PM 

State implementation of NSPS, Ban on 

resale of uncertified devices, installer 

training certification or inspection 

program, pellet stoves, EPA Phase II 

certified RWC devices, retrofit 

requirement, accelerated changeover requirement, accelerated changeover 

inducement. 

$0-$10,000 based 

on available 

literature 

Several years -

dependent on 

mechanism for 

emission reduction 

Reduce gree

gas emiss

increase effic

combustion 
10-49

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 source sectors, or equivalent sulfate 

reductions if not from the source sectors 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 presented 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 identified are located in New York, as 

referenced in Table 10-7. Both of these 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 expected to be required to prepare a BART 

analysis unless it is determined that they 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 contribute to visibility improvement in 

Class I areas). 

Additional visibility benefits are likely to result from installation of controls 

at other non-CAIR0 BART-eligible facilities located in adjacent RPOs. 

These benefits were not accounted for in the MANE-VU modeling, since 

information about final BART determinations was not available. 
10-50

Table 10-7 - Estimated Emissions from Non-EGU BART-Eligible Facilities Located in New Yo

State Facility Name Unit Name SCC Code Plant ID (from the MANE-VU Inventory) Point ID (from the MANE-VU Inventory) Facility T

NY KODAK PARK DIVISION U00015 10200203 8261400205 U00015 Chemic

Manufac

NY LAFARGE BUILDING MATERIALS INC 41000 30500706 4012400001 041000 Portland C
10-51

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 fuel 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 much 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 costs of controlling other sectors as 

documented in the MANE-VU Reasonable Progress Report, estimated at 

$550 to $750 per ton. The MANE-VU states 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 emissions 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 percent, 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. Section 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 2018
10-52

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; industrial, 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 from 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 

(SO2 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 

(SO2 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 Visibility 
10-53

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 emissions 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 progress 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 are 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 authorizing or granting approval to allow 

certain fires. The Division of Forest 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 wildland 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 more 
10-54

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/interstate areas where appropriate. Fire 

prescriptions submitted prior to the 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 process 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 receptors 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 other 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 managers 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 visibility 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 monitored. The extent of the 

monitoring plan should match the size of the fire. For small fires, visual 

monitoring of the direction of the smoke plume and monitoring nuisance 

complaints by the public may be sufficient. Other monitoring techniques 

include posting personnel on vulnerable roadways to look for visibility 

impairment and initiate safety measures for motorists, posting personnel 

at other sensitive receptors to look for smoke intrusions, using aircraft to 

track the progress of smoke plumes, 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 expected 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 pollutants 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 believe will prevent NAAQS violations 

and addresses visibility impairment due to fires. This program established 

basic parameters: wind speed, direction, location, and distance to 

sensitive receptors. 

Public education and awareness programs have been implemented to 

explain the use and importance of fire 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 implementing 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 15th and the 

following March 15th. 

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

40 CFR Section 51.308(d)(3)(v)(G) requires 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 mobile source inventories by the end 

of the first implementation period resulting from population growth; 

industrial, energy and natural resources 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 visibility 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 included 
10-57

in this SIP and other MANE-VU-member 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 deciview 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 visibility 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 control measures identified a number 

of promising strategies that would yield significant visibility benefits beyond 

the uniform rate of progress and, in fact, significantly beyond the projected 

visibility conditions that would result from Aon the books/on the way@ air 

quality protection programs. These additional measures include the 

adoption of low sulfur heating oil, implementation 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 sulfur 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 illustrate 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 visibility 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 exceed 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 Improvement at Acadia National Park 

Based On 2009 and 2018 Best and Final Projections 

0

5

10

15

20

25

30

19851990199520002005201020152020202520302035204020452050205520602065

Year

Decivews

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 Improvement at Brigantine National 

Wildlife Refuge Based On Best and Final Modeling 

0

5

10

15

20

25

30

35

19851990199520002005201020152020202520302035204020452050205520602065

Year

Decivews

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 Improvement at Great Gulf Wilderness 

Area Based on Best and Final Modeling6

0

5

10

15

20

25

30

19851990199520002005201020152020202520302035204020452050205520602065

Year

Decivews

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 Improvement at Lye Brook Wilderness 

Area Based on Best and Final Modeling 

0

5

10

15

20

25

30

19851990199520002005201020152020202520302035204020452050205520602065

Year

Decivews

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 Area
10-60

Figure 10-13e - Projected Visibility Improvement at Moosehorn National 

Wildlife Refuge Based on Best and Final Modeling 7

0

5

10

15

20

25

19851990199520002005201020152020202520302035204020452050205520602065

Year

Decivews

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 measures 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 visibility 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, therefore, 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 implemented within 10 years as appropriate 

and necessary as consistent with the MANE-VU June 20, 2007 statement. 

 

7 The estimate for Moosehorn National Wildlife Refuge 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 (NNSR) 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 authorizes the commissioner of the 

Department to enforce the codes, rules 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 authority and consistent with the State 

Administrative Procedures Act. Therefore, 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 states to consult with other states 

to develop coordinated emission strategies. 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 anticipated to contribute to visibility 

impairment in Class I areas within the state. 

New York has consulted with other states 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 understanding of the respective concerns 

and needs of the parties. 

2. Continuous documentation of all communications is necessary to 

develop a record for inclusion in 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 (Aformal@ consultations): (i) development of the 

reasonable progress goal for a Class I area, and (ii) development of 

long-term strategies. While it is anticipated that the formal 

consultation will cover the technical components that make up each 

of these policy decision areas, there may be a need for the RPOs, 

in coordination with their State and Tribal members, to have 

informal consultations on these technical considerations. 

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

anticipated that the States and Tribes will work collectively to 

facilitate the consultation process through their respective RPOs, 

when feasible. 

6. Technical analyses will be transparent, when possible, and will 

reflect the most up-to-date information and best scientific methods 

for the decision needed within the resources available. 

7. The State with the Class I area retains the responsibility to 

establish reasonable progress goals. The RPOs will make 

reasonable efforts to facilitate the development of a consensus 

between the State with a Class I area and other States affecting 

that area. In instances where the State with the Class I area can 

not agree with such other States that the goal provides for 

reasonable progress, actions taken to resolve the disagreement 

must be included in the State=s regional haze implementation plan 

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

under 40 CFR Section 51.308(d)(1)(iv). 

8. All States such as New York, whose emissions are reasonably 

anticipated to contribute to visibility impairment in a Class I area, 

must provide the Federal Land Manager (AFLM@) agency for that 

Class I area with an opportunity for consultation, in person, on their 
10-63

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 related 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 accordance 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 range of options, solicit feedback 

on options, develop consensus advice if possible, and facilitate 

informed decisions by the Class I States. 

11. The collaborators, including States, Tribes and affected FLMs, will 

promptly respond to other 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 concerning 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 concerning reasonable controls 

within and outside of MANE-VU. Federal Land Managers 

also attended the meeting, which was open to stakeholders. 

• MANE-VU Conference Call, June 20, 2007 
10-64

On this call, the MANE-VU states concluded discussions of 

statements concerning reasonable controls within and 

outside MANE-VU and agreed on the statements called the 

MANE-VU AAsk,@ 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 Managers 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 AAsk@ 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 AAsk@ 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 AAsk@ to 

VISTAS states and to consult 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 agreed 
10-65

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 AAsk@ and to provide direction to 

modeling staff as to how to interpret the AAsk@ 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) requires states to identify additional 

measures to meet reasonable progress goals when ongoing programs 

alone are not sufficient to meet the goals. Facilities located in New York 

State that are subject to state and federal applicable air regulations either 

have, or will have, limitations placed 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 include the necessary provisions to 

ensure they are effectively implemented and included in applicable

permits.