# Massachusetts **Regional Haze**

**State Implementation Plan December**  **30 , 2011** Page ii 

# Executive Summary The federal Clean Air Act, in sections 169A and 169B, contains requirements for the protection of visibility in 156 national parks, forests and wilderness areas that have been federally designated as Class I areas and include some of our nation’s most treasured public lands. Unfortunately , enjoy ment of the scenic vistas in these pristine areas is significantl y impaired by regional haze. In th e eastern U.S., the average visual range has decreased from 1 0 6 miles (under natural conditions) to 24 - 44 miles today. In 1999, the U.S. Environmental Protection Agency (EPA) issued regulations known as the Regional Haze Rule, which requires states to develop State Implementation Plans to reduce haze - causing pollution to improve visibility in Class I areas. The overall goal of the regional haze program is to restore natural visibility

conditions at Class Iareas by 2064. Regional haze is caused by fine particle pollution that impairs visibility over a large region by

scattering or absorbing light. Fine particle pollution also adversel y impacts human health, especially for children, the elderl y, and people with heart or respiratory conditions. The Massachusetts Department of Environmental Protection (MassDEP) has prepared this final State Implementation Plan (SI P) to address Massachusetts sources that contribute to regional haze. On January

11, 2011, MassDEP proposed its draft SIP for public comment and held two public hearings . The public comment period closed on February 21, 2011 ( comments submitted and MassDEP’s response s are in Appendix D ) . Certain sections of the draft SIP relied on emissions reductions in Massachusetts proposed in EPA’s draf t Transport Rule. However, EPA did not include Massachusetts in its final Transport Rule ( “Cross State Air Pollution Rule ,” 76 FR 48208 , August 8, 2011), which has necessitated revisions to this SI P. MassDEP intends to propose revisions to this SI P in Fe bruary 2012, as described below , and to submit final revisions to this SI P in June 2012 . Class I Areas Although Massachusetts has no Class Iareas, e missions from Massachusetts sources contribute to visibility degradation in Class Iareas in several othe r states. These include Ly e Brook Wilderness Area (Vermont), Great Gulf Wilderness Area (New Hampshire), Presidential Range - Dry River Wilderness Area (New Hampshire), Acadia National Park (Maine), Moosehorn Wildlife Refuge (Maine), and Roosevelt Campobell o International Park (Maine/Canada). In the first round of SI Ps, states with Class Iareas must set reasonable progress goals for 2018 for improving visibility

in their Class I areas. States affecting Class I areas (including Massachusetts) must submit S IP s with long - term strategies for meeting the 2018 reasonable progress goals. SI Ps also must include control measures for certain existing sources placed into operation between 1962 and 1977 (known as Best Available Retrofit Technology or BART) . States must update their SI Ps in 2018 and every 10 y ears thereafter and must evaluate progress every 5 y ears. Regional Planning Efforts EPA established five regional planning organizations across the nation to coordinate regional haze efforts. Massachusetts i s a member of one of these regional organizations, the Mid - Atlantic NortheastPage iii

Visibility Union (MANE - VU) , comprised of Mid - Atlantic and Northeast states, tribes, and federal agencies . Massachusetts developed this SIP by participating in a regional plannin g process coordinated by MANE - VU. Together, the MANE - VU members established baseline and natural visibility conditions, determined the primary contributors to regional haze, identified reasonable progress goals and long - term strategies, and facilitated a consultation process with states, other regional planning organizations, and federal land managers. As a MANE - VU member state, Massachusetts adopted the “ Statement of MANE- VU Concerning a Request for a Course of Action by States W ithin MANE- VU Toward As suring Reasonable Progress ” at the MANE - VU Board meeting on June 7, 2007. This Statement outlines a strategy for reducing regional haze at MANE - VU Class Iareas for the first ten - year planning period and forms the basis for the actions Massachusetts has i ncluded in this SIP. Elements of Massachusetts’ SIP for Regional Haze In accordance with 40 CFR 51.308(b), Massachusetts submits this SI P to meet the requirements of EPA’s Regional Haze Rule . This SIP addresses the core requirements of 40 CFR 51.308( d). These actions include: Best Available Retrofit Technology - EPA’s Regional Haze Rule requires the control of emissions from certain stationary

sources placed into operation between 1962 and 1977 through the implementation of Best Available Retrofit Technology (BART) or an alternative to BART that achieves greater emission reductions. Massachusetts identified 5 electric generating unit (EGU) facilities, 1 municipal waste combustor, and 1 industrial boiler as BART - eligible facilities whose 2002 emiss ions (the baseline year for this SI P) contributed significantl y to visibility impairment. MassDEP originall y proposed to rel y on EPA’s draft Transport Rule as an Alternative to BART for EGUs. However, because Massachusetts is not included in EPA’s final Cross - State Air Pollution Rule, MassDEP still must address BART requirements. For the EGUs, Massachusetts intends to propose BART determinations or an alternative to BART in earl y 2012 . For the municipal waste combustor, Massachusetts has made a source - s pecific BART determination and will finalize a permit with that determination in early 2012 . For the industrial boiler, no BART determination is needed since the facilit y has accept ed an emissions cap that make s it no longer BART - eligible. Targeted EGU strategy - MANE - VU identified 167 EGU stacks at power plants whose sulfur dioxide (SO 2 ) emissions significantly impaired visibility

at one or more MANE - VU Class Iareas, including stacks at 5 Massachusetts power plants. Massachusetts agreed to reduce SO 2 emissions from these specific power plants stacks by 90 percent from 2002 levels by 2018, or to pursue equivalent, alternative measures. Each of these EGUs alread y has reduced SO 2 emissions due to Massachusetts air quality regulations . MassDEP originall y proposed to rel y on EPA’s draft Transport Rule to meet the EGU strategy . However, because Massachusetts is not included in EPA’s final Cross - State Air Pollution Rule, MassDEP still must address this commitment. Therefore, MassDEP intends to propose a r evised Targeted EGU Strategy

in earl y 2012. Sulfur in Fuel Oil - MANE - VU determined that states could cost - effectively achieve significant reductions in SO 2 emissions by requiring lower sulfur content fuel oils, including #2 distillate oil (home heating o il) and #4 and #6 residual oil s (used in power plants and industrial and commercial boilers) . Refineries alread y have made significant capital investments to produce low and ultra - low sulfur diesel,Page iv

which is the same product as #2 distillate oil, and lowe r sulfur residual oils also are readil y available. MassDEP intends to implement the regional MANE - VU low sulfur fuel oil strategy by proposing regulations in earl y 2012 to lower allowable sulfur content in fuel oils, ultimately achieving 15 parts per mill ion sulfur for #2 oil and 0.5 percent sulfur b y weight for #4 and #6 residual oil s by 2018. The regulatory

and technical basis for this proposed SIP is found in Sections 1

– 7. The prescriptive elements of this proposed SI P

– BART, reasonable progress goals, and long - term strategy

– are found in Sections 8

– 10.Page v 

# Table of Contents Executive Summary ................................ ................................ ................................ .................... ii Table of Contents ................................ ................................ ................................ ........................ v List of Figures ................................ ................................ ................................ .......................... viii List of Tables ................................ ................................ ................................ .............................. x List of Appendices ................................ ................................ ................................ ..................... xi Acron ym s and Abbreviations ................................ ................................ ................................ .. xiii **1. BACKGROUND AND OVERV**  **IEW OF THE FEDERAL R EG**  **IONAL HAZE REGULATION**  **................................ ................................**  **................................ ................................**  **......... 1**  1.2. The Basics of Haze ................................ ................................ ................................ ............. 1 1.3. Regulatory

Framework ................................ ................................ ................................ ....... 1 History of Federal Regional Haze Rule ................................ ................................ .............................. 3 State Implementation Plan ................................ ................................ ................................ .................. 4 **2. REGIONAL PLANNING AN**  **D STATE/TRIBE AND FE DERAL LAND MANAGER**  **COORDINATION ................................**  **................................ ................................**  **................................ ....**  **6** 2.2. Regional Planning ................................ ................................ ................................ ............... 6 2.3. Mid - Atlantic/Northeast Visibility Union (MANE - VU) ................................ ..................... 6 2.4. Class IArea s Within MANE - VU ................................ ................................ ....................... 7 2.5. Area of Influence for MANE - VU Class I Areas ................................ ................................ 8 2.6. Massachusetts Impact on MANE - VU Class I Areas ................................ .......................... 9 2.7. Regional Haze Planning after the Remand of CAIR ................................ ........................ 10 2.8. Regional Consultation and the “Ask” ................................ ................................ ............... 11 2.9. Meeting the “Ask”

– MANE - VU States ................................ ................................ ........... 14 2.10. Meeting the “Ask”

– Massachusetts ................................ ................................ ................. 15 2.11. Meeti ng the “Ask”

– States Outside of MANE - VU ................................ ......................... 15 2.12. Technical Ramifications of Differing Approaches ................................ ........................... 16 2.13. Federal Land Manager Coordination ................................ ................................ ................ 16 **3. ASSESSMENT OF BASELI**  **NE AND NATURAL CONDI TIONS**  **................................ ..........**  **18** 3.2. Calculation Methodology ................................ ................................ ................................ .. 18 3.3. MANE - VU Baseline and Natural Visibility ................................ ................................ ..... 20 **4. MONITORING STRATEGY**  **................................ ................................**  **................................ .......**  **21** 4.2. IMPROVE Progr am Objectives ................................ ................................ ........................ 21 4.3. Monitoring Information for Massachusetts ................................ ................................ ...... 21 4.4. Monitoring Information for MANE - VU Class I Areas Impacted by Emissions from Massachusetts ................................ ................................ ................................ ................... 22 Acadia National Park, Maine ................................ ................................ ................................ ............ 22 Great Gulf Wilderness Area, New Hampshire ................................ ................................ ................. 24 Presidential Range - Dry

River Wilderness, New Hampshire ................................ ............................ 25 Lye Brook Wilderness, Vermont ................................ ................................ ................................ ...... 25 Moosehorn Wilderness Area, Maine ................................ ................................ ................................ 27 Roosevelt/Campobello International Park, New Brunswick, Canada ................................ .............. 28Page vi

**5. MODELING**  **................................ ................................**  **................................ ................................**  **... 30**  5.2. Meteorology ................................ ................................ ................................ ...................... 31 5.3. Emissions Data Preparations ................................ ................................ ............................. 32 5.4. M odel Platforms ................................ ................................ ................................ ................ 34 CMAQ ................................ ................................ ................................ ................................ ............... 34 REMSAD ................................ ................................ ................................ ................................ .......... 34 CAL GRID ................................ ................................ ................................ ................................ ......... 34 CAL PUFF ................................ ................................ ................................ ................................ ......... 35 **6. EMISSIONS INVENTORY**  **................................ ................................**  **................................ ..........**  **36** 6.2. Baseline and Future Year Emission Inventories for Modeling ................................ ......... 36 MANE - VU Regional Baseline Inventory ................................ ................................ ......................... 36 Massachusetts Baseline Inventory ................................ ................................ ................................ .... 37 Future Year Emission Control Inventories ................................ ................................ ....................... 38 6.3. Emission Processor Selection and Configuration ................................ ............................. 39 6.4. Inventories for Specific Source Ty pes ................................ ................................ .............. 39 Stationary

Point Sources ................................ ................................ ................................ ................... 40 6.5. Electric Generating Units ................................ ................................ ................................ .. 40 6.6. Non - EGU Point Sources ................................ ................................ ................................ ... 41 Stationary

Area Sources ................................ ................................ ................................ .................... 41 Non - Road Mobile Source s ................................ ................................ ................................ ................ 41 On - Road Mobile Sources ................................ ................................ ................................ .................. 42 Biogenic Emission Sources ................................ ................................ ................................ ............... 42 6.7. Summary

of MANE - VU 2002 and 2018 Emissions Inventory ................................ ........ 43 6.8. Summary

of Massachusetts 2002 Base and 2018 Projected Emissions and Reductions .. 44 **7. UNDERSTANDING THE SO**  **URCES OF VISIBILITY -**  **IMPAIRING POLLUTANTS .......**  **46** 7.2. Visibility- Impairing Pollutants ................................ ................................ ......................... 46 Contr ibuting States and Regions ................................ ................................ ................................ ....... 47 7.3. Emissions Sources and Characteristics ................................ ................................ ............. 54 Sulfur Dioxide (SO 2 ) ................................ ................................ ................................ ......................... 54 Volatile Organic Compounds (VOCs) ................................ ................................ .............................. 56 Oxides of Nitrogen (NO X ) ................................ ................................ ................................ ................ 58 Primary P article Matter (PM 10 and PM 2.5 ) ................................ ................................ ........................ 60 Ammonia Emissions (NH 3 ) ................................ ................................ ................................ .............. 65 **8. BEST AVAILABLE RETRO**  **FIT TECHNOLOGY ................................**  **................................ ..**  **68** 8.2. BART Overview ................................ ................................ ................................ ............... 68 8.3. BART - Eligible Sources in Massachusetts ................................ ................................ ........ 69 8.4. Determination of which BART - eligi ble sources are subject to BART ............................ 70 8.5. Pollutants Covered by BART ................................ ................................ ........................... 70 8.6. Modeling of BART Visibility I mpacts ................................ ................................ ............. 71 8.7. Visibility

I mpacts of Massachusetts BART - Eligible Sources ................................ .......... 71 8.8. Overview of Massachusetts BART - Eligible Sources ................................ ....................... 72 “Cap Out” Source ................................ ................................ ................................ ............................. 72 Sources that Contribute to Visibility I mpairment ................................ ................................ ............. 74 8.9. BART De termination for Wheelabrator - Saugus ................................ ............................ 75Page vii

8.10. BART or Alternative to BART for Remaining Sources [Reserved] ................................ 77 8.11. Reasonabl y Attributable Visibility I mpairment ................................ ................................ 77 **9. REASONABLE PROGRESS**  **GOALS ................................**  **................................ ........................**  **78 10.**  **LONG -**  **TERM STRATEGY ................................**  **................................ ................................**  **......... 81**  10.2. Overview of the Long - Term Strategy Development Process ................................ ........... 81 10.3. Technical Basis for Strategy Development ................................ ................................ ....... 82 10.4. 2018 Emission Reductions Due to Ongoing Air Pollution Controls ................................ 84 EGU Emissions Controls Expected by 2018 ................................ ................................ .................... 84 Non - EGU Point Source Controls Expected by 2018 ................................ ................................ ........ 88 Area Source Controls Expected b y 2018 ................................ ................................ .......................... 88 Onroad Mobile Source Controls Ex pected by 2018 ................................ ................................ ......... 89 Nonroad Sources Controls Expected by 2018 ................................ ................................ .................. 90 Additional Controls Analyzed as Part of Ozone SIPs ................................ ................................ ...... 90 10.5. Additional Reasonable Strategies ................................ ................................ ..................... 91 Rationale for Determining Reasonable Controls ................................ ................................ .............. 91 MANE - VU Statement of June 20, 2007 ................................ ................................ ........................... 94 Best Available Retrofit Technology ................................ ................................ ................................ . 95 Low - Sulfur Fuel Oil Strategy ................................ ................................ ................................ ........... 95 Targeted EGU Strategy ................................ ................................ ................................ ..................... 98 10.6. Source Retirement and Replacement Schedules ................................ ............................. 102 10.7. Measures to Mitigate the Impacts of Construction Activities ................................ ........ 102 10.8. Agricultural and Forestry Smoke Management ................................ .............................. 102 Regulation of Outdoor Hy dronic Heaters ................................ ................................ ....................... 103 10.9. Estimated Impacts of Long - Term Strategy on Visibility ................................ ................ 103 Additional Meas ures Included in Best and Final Modeling ................................ ........................... 103 Visibility I mpacts of Additional Reasonable Controls from Best and Final Modeling .................. 104 10.10. Massachusetts’ Share of Emissions Reduction ................................ ............................... 107 10.11. Emission L imitations and Compliance Schedules ................................ .......................... 107 10.12. Enforc eability

of Emission L imitations and Control Measures ................................ ...... 108 10.13. Prevention of Significant Deterioration ................................ ................................ .......... 1 08Page viii 

# List of Figures Figure 1: Locations of Federall y Protected Mandatory Class I Areas ................................ ........................ 3 Figure 2: US EPA Designated Regional Planning Organizations ................................ .............................. 6 Figure 3: Class I Areas within MANE - VU ................................ ................................ ................................ . 8 Figure 4: Map of CAI R States ................................ ................................ ................................ .................. 10 Figure 5: MANE - VU Princip les for Regional Haze Planning ................................ ................................ .. 12 Figure 7: Acadia National Park on Clear and Hazy Day s ................................ ................................ ........ 23 Figure 6: Map of Acadia National Park Showing ................................ ................................ ..................... 23 Figure 8: Map of Great Gulf and Presidential Range - Dry River Wilderness Areas Showing IMPROVE M onitor L ocation ................................ ................................ ................................ ................................ ...... 24 Figure 9: Great Gulf Wilderness Area on Clear and Hazy Day s ................................ .............................. 24 Figure 10: Location of Lye Brook Wilderness Mo nitor ................................ ................................ ........... 26 Figure 11: Lye Brook Wilderness Area on Clear and Hazy Day s ................................ ............................ 26 Figure 12: Map of the Baring and Edmunds Divisions of th e Moosehorn National Wildlife Refuge Showing the IMPROVE Monitor L ocation ................................ ................................ .............................. 27 Figure 13: Moosehorn Wilderness Area on a Clear and a Haz y Da y ................................ ....................... 28 Figure 14: Map of Roosevelt/Campobello International Park ................................ ................................ .. 28 Figure 15: Roosevelt/Campobello International Park on Clear and Haz y Days ................................ ...... 29 Figure 16: Modeling domains used in MANE - VU air quality modeling studies with CMAQ. ............... 32 Figure 17: Examples of processed model - read y em issions: a) SO2 from Point, b) NO 2 from Area, c) NO2 from On - road, d) NO2 from Non - road, e) I SOP from Biogenic, f) SO2 from all source categories

................................ ................................ ................................ ................................ ................................ ... 33 Figure 18: Contributions to PM **2.5** Ex tinction at Seven Class ISites ................................ ........................ 46 Figure 19: Ranked state percent sulfate contributions to Northeast Class I receptors based on emissions divided by

distance (Q/d) results ................................ ................................ ................................ .............. 48 Figure 20: Ranked state percent sulfate contributions to Mid - Atlantic Class Ireceptors based on emissions divided by

distance (Q/d) results ................................ ................................ .............................. 49 Figure 21: Modeled 2002 Contributions to Sulfate by State at Brigantine ................................ ............... 50 Figure 22: Modeled 2002 Contributions to Sulfate by State at Lye Brook ................................ .............. 51 Figure 23: Modeled 2002 Contributions to Sulfate by State at Great Gulf and Presidential Range/Dry River Wilderness ................................ ................................ ................................ ................................ ....... 51 Figure 24: Modeled 2002 Contributions to Sulfate by State at Acadia ................................ .................... 52 Figure 25: Modeled 2002 Contributions to Sulfate by State at Moosehorn and Roosevelt Campobello International Park ................................ ................................ ................................ ................................ ...... 52 Figure 26: Modeled 2002 Contrib utions to Sulfate by State at Shenandoah ................................ ............ 53 Figure 27: Modeled 2002 Contributions to Sulfate by State at Doll y Sods ................................ .............. 53 Figure 28 : Trends in Annual Sulfur Dioxide Emissions by State ................................ ............................. 55 Figure 29: 2002 Sulfur Dioxide Emissions (SO **2** ) by State ................................ ................................ ....... 56 Figure 30: 20 02 Volatile Organic Carbon (VOC) Emissions by State ................................ ..................... 57 Figure 31: Trends in Annual Nitrogen Oxide (NO **x** ) Emissions by State ................................ ................. 59 Fi gure 32: 2002 Nitrogen Oxide (NO **x** ) Emissions by State ................................ ................................ ..... 60 Figure 33: Trends in Primary Coarse Particle (PM 10 ) Emissions by State ................................ ............... 61 Figure 34: Trends in Primary Fine Particle (PM 2.5 ) Emissions by State ................................ .................. 61 Figure 35: Wood Smoke Source Regional Aggregations ................................ ................................ ......... 63 Figure 36: 2002 Primary

PM 10 Emissions by

State ................................ ................................ ................... 64Page ix

Figure 37: 2002 Primary

PM 2.5 Emissions by

State ................................ ................................ .................. 65 Figure 38: Trends in Ammonia Emissions by State ................................ ................................ ................. 67 Figure 39: 2002 NH 3 Emissions by State ................................ ................................ ................................ . 67 Figure 40: Average Change in 24 - hr PM 2.5 Due to Low Sulfur Fuel Strategies Relative to OTB/OTW (  g/m 3 ) ................................ ................................ ................................ ................................ ...................... 98 Figure 41: 167 Targeted EGU Stacks Affecting MANE - VU Class I Areas ................................ ............. 99 Figure 42: Average Change in 24 - hr PM 2.5 due to 90 Percent Reduction in SO 2 Emissions from 167 EGU Stacks Affecting MANE - VU ................................ ................................ ................................ ......... 100 Figure 43: Projected Visibility I mprovement at Acadia National Park Based on 2018 Visibility Projections ................................ ................................ ................................ ................................ ............... 105 Figure 44: Projected Visibility I mprovement at Great Gulf Wilderness Area Based on 2018 Visibility Modeling ................................ ................................ ................................ ................................ ................. 106 Figure 45: Projecte d Visibility I mprovement at Lye Brook Wilderness Area Based on 2018 Visibility Modeling ................................ ................................ ................................ ................................ ................. 106 Figure 46: Projected Visibility I mprovement at Moosehorn Wilderness Area Based on 2018 Visibility Mo deling ................................ ................................ ................................ ................................ ................ 107Page x 

# List of Tables Table 1: MANE - VU Members ................................ ................................ ................................ ................... 7 Table 2: States that Contribute to Visibility I mp airment at One or More of the MANE - VU Class I Areas of Acadia, Moosehorn, Roosevelt - Campobello, Great Gulf, Presidential Range - Dry River, Lye Brook, and Brigantine ................................ ................................ ................................ ................................ ............. 9 Table 3: Class IFederal Areas Affected b y Emissions from Massachusetts ................................ ............ 10 Table 4: IMPROVE Monitors for MANE - VU Class IAreas ................................ ................................ ... 18 Table 5: Summary

of Base line Visibility

and Natural Visibility

Conditions for the 20 Percent Best and 20 Percent Worst Visibility Day s at MANE - VU Class I Areas ................................ ............................... 20 Table 6: MANE - VU 2002 Emissions Inventory Summary

(to ns) ................................ ........................... 43 Table 7: MANE - VU 2018 Emissions Inventory Summary

(in tons) ................................ ....................... 44 Table 8: Massachusetts 2002 Base Year and 2018 Projected E missions and Reductions (in tons) ......... 44 Table 9: Percent of Annual Average Modeled Sulfate Due to Emissions from L isted States .................. 47 T able 10: BART - Eligible Facilities in Massachusetts ................................ ................................ .............. 70 Table 11: CALPUFF Visibility Modeling Results using MM5 Platform ................................ ................. 72 Table 12: CAL PUFF Visibility Modeling Results using NWS Platform ................................ ................. 72 Table 13: Massachusetts Sources with De Minimis Visibility I mpact ................................ ..................... 73 Table 14: Overview of BART - Eligible EGUs & MWCs ................................ ................................ ......... 74 Table 15: Uniform Rate of Progress Calculation (all values in deciviews) ................................ .............. 79 Table 16: Reasonable Progress Goals - 20% Worst Day s (all values in deciviews) ................................ 79 Table 17: Reasonable Progress Goals - 20% Best Day s (all values in deciviews) ................................ ... 80 Table 18: Summary

of Results from the Four - Factor Anal ys is ................................ ................................ 93Page xi 

# List of Appendices A. Contributions to Regional Haze in the Northeast and Mid - Atlantic United States: Mid Atlantic/Northeast Vi sibility Union (MANE - VU) Contribution Assessment. NESCAUM, August 2006. B. Final Interim Principles for Regional Planning. MANE - VU, June 2006. C. Statement(s) of the Mid - Atlantic/Northeast Visibility Union (MANE - VU) Concerning a Request for a Course of Action by States/EPA Within/Outside MANE - VU Toward Assuring Reasonable Progress. June 7, 2006. D. Federal Land Manager and EPA Comments and State Responses on Pre - Public Hearing Draft Massachusetts Regional Haze SIP (Appendices D - 1

– D 5) , and Public Comments and S tate Response s on Public Hearing Draft SI P (Ap p endices D6

– D 1 5 ). E. Baseline and Natural Background Visibility Conditions: Considerations and Proposed Approach to the Calculation of Baseline and Natural Background Visibility Conditions at MANE - VU Class I A reas. NESCAUM, December 2006. F. MANE - VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Control Measure Benefits. NESCAUM, February 2008. G. 2018 Visibility

Projections. NESCAUM, March 2008. H. Meteorological Modeling Using Penn State/NCAR 5 th Generation Mesoscale Model (MM5). NYSDEC TSD - 1a. February 2006. I. Emissions Processing for the Revised 2002 OTC Regional and Urban 12 km Base Case Simulations. NYSDEC TSD - 1c, September 2006. J. CMAQ Model Performance and A ssessment, 8 - Hr OTC Ozone Modeling. NYSDEC TSD - 1e, February 2006. K. Eight Hour Ozone Modeling using the SMOKE/CMAQ sy stem. NYSDEC TSD - 1d, February 2006. L. Modeling Protocol for the OTC CALGRID Screening - Level Modeling Platform for the Evaluation of Ozone. NHDES, May 2007. M. Technical Support Document for 2002 MANE - VU SI P Modeling Inventories, Version 3. E.H. Pechan & Associates for MANE - VU, November 2006. N. Development of Emissions Projections for 2009, 2012, 2018 for Non - EGU Point, Area, and Nonroad Source s in the MANE - VU Region. MACTEC, February 2007. O. Development of MANE - VU Mobile Source Projection Inventorie s for SMOKE/MOBILE6 Application. NESCAUM, June 2006 . P. Regional Haze and Visibility in the Northeast and Mid - Atlantic States. NESCAUM, January 2001. Q. Technical Support Document on Agricultural and Forestry Smoke Management in the MANE VU Region. MANE - VU, September 2006. R. Five Factor Anal ys is of BART Eligible Sources: Survey of Options for Conducting BART Determinations. NESCAUM, June 2007. R - 1. CalP uff BART Modeling Results (MM5) R - 2. CalPuff BART Modeling Results (NWS)Page xii

S. Comparison of CAI R and CAI R Plus Proposal using the Integrated Planning Model®. ICF, May 2007. T. Assessment of Reasonable Progress for Regional Haze in MANE - VU Class IAreas. MACTEC , July 2007. T - 1. Addendum for Residual Oil . MANE - VU, April 2011. U. Assessment of Control Technology Options for BART - Eligible Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp Facilities. NESCAUM, March 2005. V. The Nature of the Fine Particle and Regional Haze Air Quality Problems in the MANE - VU Region: A Conceptual Description. NESCAUM, November 2006. W. Documentation of 2018 Emissions from Electric Generating Units in the Eastern U.S. for MANE - VU’s Regional Haze Mod eling. Alpine Geoph ys ics, April 2008. X. Technical Support Document on Measures to Mitigate the Visibility I mpacts of Construction Activities in the MANE - VU Region . MANE - VU, October 2006. Y. Lo w Sulfur Heating Oil in the Northeast States: An Overview of Ben efits, Costs, and Implementation I ssues. NESCAUM, December 2005. Z. SNCR Optimization Report, Wheelabrator Saugus Inc., WTE Units 1 & 2, Two 750 TPD MSW Combustors. Fuel Tech, January 2010. AA. Public Health Benefits of Reducing Ground - level Ozone and Fine Particle matter in the Northeast U.S.

– A Benefits Mapping and Anal ys is Program (BenMA P) Study . NESCAUM, January 2008. BB. Approval of General Electric Aviation NO x Reasonabl y Available Control Technology (RACT) Modified Emission Control Plan. Mas sDEP, March 2011. CC. 310 CMR 7.26(50) through (54): Outdoor Hy dronic Heaters. MassDEP, December 2008.Page xiii 

# Acronyms and Abbreviations ACAD1 Acadia National Park IMPROVE monitor BART Best Available Retrofit Technology BEIS - 3 Biogenic Emission Invento ry Sy stem (3 version 0.9) BOTW Beyond on the Way (controls) BTU British Thermal Unit CAA Clean Air Act CAIR Clean Air Interstate Rule CALGRID California Grid Model CEED Center for Energy and Economic Development CENRAP Central Regional Air Plannin g Association CERR Consolidated Emission Reporting Rule CFR Code of Federal Regulations CMAQ Community Multi - scale Air Quality Modeling System CO Carbon Monoxide dv Deciview EGU Electric Generating Unit EPA Environmental Protection Agency FLM Federal Land Manager GCVTC Grand Canyon Visibility Transport Commission GRGU1 Great Gulf Wilderness Area IMPROVE monitor; also monitors Presidential Range/Dry River Wilderness

Area HAP Hazardous Air Pollutant ICI Industrial/Commercial/Institutional I MPROVE Interagency Monitoring of Protected Visual Environments IPM Integrated Planning Model LADCO Lake Michigan Air Directors Consortium LYBR1 Lye Brook Wilderness Area IMPROVE monitor MassDEP Massachusetts Department of Environmental Protection MANE - V U Mid - Atlantic/Northeast Visibility Union MARAMA Mid - Atlantic Regional Air Management Association MM5 Mesoscale Meteorological Model MMBtu Million British Thermal Units MOOS1 Moosehorn Wilderness Area IMPROVE monitor; also monitors Roosevelt/Campobel lo International Park MOBILE6.2 EPA’s On - Road Mobile Source Emissions Estimation Model MRPO Midw est Regional Planning Organization MW Megawatt MWh Megawatt Hour MWC Municipal Waste Combustor N/A Not Applicable NAAQS National Ambient Air Quality St andards NCAR National Center for Atmospheric Research NEI National Emissions Inventory NET National Emissions Trend NESCAUM Northeast States for Coordinated Air Use Management NH 3 Ammonia NO x Oxides of Nitrogen NONROAD EPA’s Non - Road Emissions Estim ation Model 2005 Version NSPS New

Source Performance Standards NTI National Toxics Inventory NYSDEC New

York State Department of Environmental Conservation NWS National Weather Service OC Organic Carbon OTC Ozone Transport CommissionPage xiv

OTB/W On the Books/On the Way (controls) PM 2.5 Fine Particulate Matter; particles with an aerodynamic diameter less than or equal to a nominal 2.5

micrometers PM 10 Particles with an aerodynamic diameter less than or equal to a nominal 10 microm eters QA Quality Assurance RACT Reasonably Available Control Technology REMSAD Regional Modeling System for Aerosols and Deposition RFP Reasonable Further Progress RH Regional Haze RPO Regional Planning Organization SIP State Implementation Plan SLAMS/ State & Local Air Monitoring System and NAMS National Air Monitoring System SCC Source Category Code SMOKE Sparse Matrix Operator Kernel Emissions SMP Sm oke Management Plan SOA Secondary Organic Aerosol SO 2 Sulfur Dioxide TPY Tons per year TSC Technical Support Co mmittee (of MANE - VU) TSD Technical Support Document USEPA United States Environmental Protection Agency UMD University of Maryland VIEWS Visibility Information Exchange Web System VISTAS Visibility Improvement State and Tribal Association of the South east VOC Volatile Organic Compound WRAP Western Regional Air PartnershipPage 1 

# 1. **BACKGROUND AND OVERV IEW OF THE**  **FEDERAL REGIONAL HAZ E REGULATION**  **1.2.** 

### The Basics of Haze Regional haze is visibility impairment caused by

the cumulative emission of air pollutants from numerous sources over a wide geographic area. The primary cause of regional haze is the scattering and absorption of light b y fine particles. Fine particle air pollution also a dv ersely impacts human health, especiall y the respiratory and cardiovascular sy stems of people at increased risk, including children, the elderl y, and people with heart or respiratory conditions. Regional haze obscures views in pristine areas such as national parks, forests and wilderness areas (156 of which have been designated Federal Class Iareas). In parks in the eastern U.S., the average visual range has decreased from 1 0 6 miles (under natural conditions) to 24 - 44 miles today . Visibility impairment can be quantified using three different, but mathematically related mea sures: visual range (i.e., how far one can see); light extinction per unit distance (e.g., Mm - 1 ) 1 ; and deciviews ( dv ), a useful metric for measuring increments of visibility change that are just perceptible to the human ey e. Each can be estimated from the ambient concentrations of individual particle constituents, taking into account their unique light - scattering (or absorbing) properties, and making appropriate adjustments for relative humidit y. Assuming natural conditions, visibility in the Northeast an d Mid - Atlantic is estimated to be about 106 miles, which corresponds to 23 Mm - 1 or 8 dv . Under current polluted conditions in the region, average visibility ranges from 24 miles in the south to 44 miles in the north; these values correspond to 103 Mm - 1 t o 55 Mm - 1 or 23 to 17 dv , respectively. On the worst 20 percent of day s, visibility

impairment in Northeast and Mid - Atlantic Class Iareas ranges from 2 1.7 to 29 dv (a visual range of about 30 to 14 miles). The fine particles that commonly cause hazy

cond itions in the e ast ern U.S. are primarily composed of sulfate, nitrate, organic carbon, elemental carbon (soot), and crustal material (e.g., soil dust, sea salt, etc.). Sulfate, nitrate, and organic carbon are secondary pollutants that form in the atmosphe re from precursor pollutants, primarily sulfur dioxide (SO 2 ), nitrogen oxides (NO x ), and volatile organic compounds (VOCs), respectivel y. Sulfate, formed from SO 2 emissions, is the dominant contributor to fine particle pollution throughout the eastern U.S . and therefore most eastern regional control efforts are directed at reducing SO 2 emissions. **1.3.** 

### Regulatory Framework In amendments to the Clean Air Act (CAA) in 1977, Congress added Section 169 (42 U.S.C. 7491) setting forth the following national visib ility goal: Congress hereby declares as a national goal the prevention of any future, and the remedying of any existing, impairment of visibility in mandatory Class I Federal areas which impairment results from man - made air pollution.

1 In units of inverse length. An inverse megameter (Mm- 1 ) is equal to one over one thousand kilometers.Page 2

The "Class I" designatio n was given to each of 158 areas in existence as of August 1977 that met the following criteria:  all national parks greater than 6000 acres ,  all national wilderness areas and national memorial parks greater than 5000 acres , and  one international park . In 1980, Bradwell Bay , Florida, and Rainbow Lake, Wisconsin, were excluded for purposes of visibility protection as federal Class Iareas. Today , 156 national park and wilderness areas remain as Class I visibility protection areas ( Figure 1 ). Over the following ye ars , modest steps were taken to address the visibility problems in Class Iareas. The control measures taken mainly addressed “plume blight” from specific pollution sources and did little to address regional haze issue s in the Eastern United States. When the C AA was amended in 1990, Congress added Section 169B (42 U.S.C. 7492), authorizing further research and regular assessments of the progress made. In 1993, the National Academ y of Sciences concluded that “current scientific knowledge is adequate and control technologies are available for taking regulatory

action to improve and protect visibility .” In addition to authorizing creation of visibility transport commissions and setting forth their duties, Section 169B( f) of the CAA mandated creation of the Grand Cany on Visibility Transport Commission (GCVTC) to make recommendations to the U.S. Environmental Protection Agency (EPA) for the region affecting the visibility

of the Grand Can yon National Park. The GCVTC subm itted its report to EPA in June 1996, following four y ears of research and policy development. This report, as well as the many research reports prepared by the Commission, contributed invaluable information to EPA in its development of regulations for vi sibility improvement.Page 3 **Figure 1**  **: Locations of Federally Protected Mandatory Class I Areas**

**History of Federal Regional Haze Rule** The federal requirements that states must meet to achieve national visibility goals are contained in Title 40: Protection of Environment, Part 51

– Requirements for Preparation, Adoption, and Submittal Of Implementation Plans, Subpart P

– Protection of Visibi lity (40 CFR 51.300 - 309). Known more simply as the Regional Haze Rule, these regulations were adopted on July 1, 1999, and went into effect on August 30, 1999. The rule seeks to address the combined visibility effects of various pollution sources over a large geographic region. This wide - reaching pollution net means that many states

– even those without Class IAreas

– are required to participate in haze reduction efforts. The specific requirements for States’ Regional Haze State Implementation Plans ( S IP s ) are set forth in 40 CFR 51.308, Regional Haze Program Requirements. In consultation with the states and tribes, EPA designated five Regional Planning Organizations (RPOs) 2 to assist with the coordination and cooperation needed to address the h aze is sue. The Mid - Atlantic /

2 A description of the RPOs is contained in the Regional Planning Section of this SIP.Page 4

Northeast states, including the District of Columbia, formed the Mid - Atlantic / Northeast Visibility Union (MANE - VU). 3 EPA’s adoption of the Regional Haze Rule was challenged b y the American Corn Growers Association. On May 24, 20 02, the U.S. Court of Appeals, D.C. District Court, ruled on the challenge and remanded to EPA the Best Available Retrofit Technology (BART) provisions of the rule, but denied industry ’s challenge to the haze rule’s goals of natural visibility and no degra dation requirements. On June 15, 2005, EPA finalized a rule addressing the court’s remand. On February

18, 2005, the Appeals Court issued another ruling vacating the Regional Haze Rule in part and sustaining it in part. For more information see Center for Energy and Economic Development v. EPA , # 03 - 1222, (D.C. Cir. Feb. 18, 2005; “ CEED v. EPA”). In this case, the c ourt granted a petition challenging provisions of the Regional Haze Rule governing the optional emissions trading program for certain Weste rn States and Tribes (the WRAP Annex Rule). EPA’s subsequent final rulemaking provided the following changes to the Regional Haze Regulations: 1. Revised the regulatory text in 40 CFR 51.308(e)(2)(i) in response to the CEED court’s remand to remove the re quirement that the determination of BART “benchmark” be based on cumulative visibility anal ys es, and to clarify

the process for making such determinations, including the application of BART presumptions for Electric Generating Units (EGUs) as contained in Appendix Y to 40 CFR 51. 2. Added new regulatory text in 40 CFR 51.308(e)(2)(vi) to provide minimum elements for cap and trade programs in lieu of BART. 3. Revised regulatory

text in 40 CFR 51.309 to reconcile the optional framework for certain Western States an d Tribes to implement the recommendations of the Grand Canyon Visibility Transport Commission with the CEED decision. **State Implementation Plan** In accordance with 40 CFR 51.308 (b) , Massachusetts submits this SI P to meet the requirements of EPA’s Regional H aze Rule . This SIP addresses the core requirements of 40 CFR 51.308(d) . Select Best Available Retrofit Technology (BART) requirement s of 40 CFR 5 1 .308(e) are reserved in this S IP and will be re - proposed in early

2012 . In addition, this SI P addresses requirements pertaining to regional planning and s tate/tribe and Federal Land Manager (FLM) coordination and consultation. Pursuant to 40 CFR 51.308(d)(4)(v), Massachusetts also commits to making periodic updates to the Massachusetts emissions inventory (Sec tion 6). Massachusetts proposes to complete these updates to coincide with the progress reports. 40 CFR 51.308(f) requires Massachusetts to submit revisions to its Regional Haze SIP every ten ye ars. The first milestone for reasonable progress is 2018. M assachusetts commits to submitting a revision to its Regional Haze SI P by July 31, 2018. 40 CFR 51.308(g) requires Massachusetts to submit a report to EPA every 5 ye ars that evaluates progress toward the reasonable progress goal for each Class I area located within the state and each

3 A description of MANE - VU and a full list of its members are described in the Regional Planning Section of this SIP.Page 5

mandatory

Class I area located outside the state that may be affected by emissions from within the state. Massachusetts commits to submitting the first progress report in 2013. Finally , pursuant to 40 CFR 51.308(h), Massachusetts will submit a determination of adequacy of its Regional Haze SIP whenever a progress report is submitted.Page 6 

# 2. **REGIONAL PLANNING AN D STATE/TRIBE AND**  **FEDERAL LAND MANAGER COORDINATION**  **2.2.** 

### Regional Planning In 1999, EPA and affected s tates/tribes agreed to cr eate five Regional Planning Organizations (RPOs) to facilitate interstate coordination on Regional Haze SIPs. Figure 2 shows a map of the five RPOs: MANE - VU (Mid - Atlantic/Northeast Visibility Union), VI STAS (Visib ility I mprovement State and Tribal Association of the Southeast), MRPO (Midwest Regional Planning Organization), CenRAP (Central Regional Air Planning Association), and WRAP (Western Regional Air Partnership). As part of regional planning, the RPOs and st ates and tribes within each RPO are required to consult on the development of emission management strategies.

**Figure 2**  **: US EPA Designated Regional Planning Organizations**

**2.3.** 

### Mid **- Atlantic/Northeast Visibility Union (MANE**  **- VU)**  MAN E - VU’s work is managed by the Ozone Transport Commission (OTC) and carried out by the OTC, the Mid - Atlantic Regional Air Management Association (MARAMA), and the Northeast States for Coordinated Air Qualit y Management (NESCAUM). Members of MANE

–VU are li sted in Table 1 . The states and tribes, along with federal agencies and professional staff from OTC, MARAMA andPage 7

NESCAUM, are members of the various committees and workgroups established by MANE - VU. Policy decisio ns are made by

the MANE - VU Board of Directors, composed of senior staff from each m ember s tate, tribe, or a gency . **Table 1**  **: MANE -**  **VU Members**

Connecticut Pennsylvania Delaware Penobscot Nation District of Columbia Rhode I sland Maine St. Regis Mohawk Tribe Maryland Vermont Massachusetts U.S. Environmental Protection Agency * New Hampshire U.S. National Park Service* New Jersey U.S. Fish and Wildlife Service* New York U.S. Forest Service* * Non - voting member Since i ts inception on July 24, 2001, MANE - VU established an active committee structure to address both technical and non - technical issues related to regional haze. One of the primary committees is the Technical Support Committee (TSC), charged with assessing th e nature and magnitude of the regional haze problem within MANE - VU, interpreting the results of technical work, and reporting on such work to the MANE - VU Board. Ithas three standing working groups, broken down by topic area: Emissions Inventory , Modeling , and Monitoring/Data Anal ys is Workgroups. The TSC has evolved to function as a valuable sounding board for all the technical projects and processes of MANE - VU and has established a process to ensure that important regional haze - related projects are compl eted in a timely fashion and members are kept informed of all MANE - VU tasks and duties. The second primary

committee is the Communications Committee, charged with developing approaches to inform the public about the regional haze problem in the region and making an y recommendations to the MANE - VU Board to facilitate that goal. It oversaw the development of MANE - VU’s newsletter and outreach tools, both for stakeholders and for the public, regarding regional issues within MANE VU. Policy decisions are ma de by

the MANE - VU Board. MANE - VU established a Policy A dv isory Group to provide a dv ice to decision - makers on policy questions. Federal Land Managers , EPA, s tates, and tribes are represented on the Policy A dv isory Group, which met on an as - needed basis. **2.4.** 

### C **lass I Areas Within MANE -**  **VU** MANE - VU contains seven Federal Class I areas in four states ( Figure 3 ). Massachusetts does not contain an y Class I areas.Page 8 **Figure 3**  **: Class I Areas within MANE -**  **VU**

**2.5.** 

### Area of Influence for MANE **- VU Cla**  **ss I Areas** 40 CFR 51.308( d )(3) of the Regional Haze Rule requires states to determine their respective contribution to visibility

impairment at Class Iareas. Through source apportionment modeling (more fully described in Section 7), MANE - VU has identifie d and evaluated the major contributors to regional haze at MANE - VU Class Iareas as well as Class I areas in nearby RPOs. The complete findings are contained in a report produced b y the Northeast States for Coordinated Air Quality Management (NESCAUM) ent itled, “ Contributions to Regional Haze in the Northeast and Mid - Atlantic United States ,” otherwise known as the Contribution Assessment ( Appendix A ). Based on that work, MANE VU concluded that it was appropriate to define an area of influence including all of the states participating in MANE - VU, plus other states that modeling indicated contributed at least 2 percent of the sulfate ion at MANE - VU Class Iareas in 2002. MANE - VU identified the s tates in Table 2 as causing or c ontributing to visibility impairment in one or more of the following Class I areas: Acadia National Park, Brigantine Wildlife Refuge, Great Gulf Wilderness Area, Ly e Brook Wilderness Area, Moosehorn Wildlife Refuge, Presidential Range - Dry River Wilderness Area, and Roosevelt Campobello International Park .Page 9

**Table 2**  **: States that Contribute to Visibility Impairment at One or More of**  **the MANE -**  **VU Class I Areas of Acadia, Moosehorn, Roosevelt**  **- Campobello, Great Gulf, Presidential Range**  **- Dry**  **River, Lye Brook, and Brigantine**  **State RPO**  Connecticut MANE - VU Delaware MANE - VU Maine MANE - VU Maryland MANE - VU Massachusetts MANE - VU New Hampshire MANE - VU New Jersey MANE - VU New York MANE - VU Pennsylvania MANE - VU Rhode I sland MANE - VU Vermont MA NE - VU Georgia VI STAS Kentuck y VI STAS North Carolina VI STAS South Carolina VI STAS Tennessee VI STAS Virginia VI STAS West Virginia VI STAS Illinois MRPO Indiana MRPO Michigan MRPO Ohio MRPO **2.6.** 

### Massachusetts Impact on MANE **- VU Class I Areas**  Emission sources within Massachusetts had measurable impacts on visibility at Class I areas within MANE - VU in the 2002 baseline y ear . The magnitude of these impacts is described in detail in Section 7 and MANE - VU’s Contribution Assessment (Appendix A ). Table 3 lists the Class Iareas a ffected by emissions sources in Massachusetts.Page 10

**Table 3**  **: Class I Federal Areas Affected by Emissions from Massachusetts Class I Federal Area**  **State** Acadia National P ark Maine Moosehorn Wildlife Refuge Maine Roosevelt Campobello International Park Maine/Canada Great Gulf Wilderness Area New Hampshire Presidential Range - Dry

River Wilderness Area New Hampshire Lye Brook Wilderness Area Vermont **2.7.** 

### Regional Haze Plannin **g after the Remand**  **of CAIR** On March 10, 2005, EPA issued the Clean Air Interstate Rule (CAIR). This important federal rule was designed to achieve major permanent reductions in SO 2 and NO x emissions in the eastern United States through a cap - and - trade sy s tem using emission allowances. CAI R would permanentl y cap emissions originating in 28 eastern states and the District of Columbia ( Figure 4 ). Although Massachusetts was only designated as a participating CAIR state for the ozone season , this program would have greatl y affect ed future air quality in the state. According to EPA’s CAIR website, SO 2 emissions in the affected states would be reduced b y more than 70 percent and NO x emissions by more than 60 percent from 2003 levels up on full implementation of CAI R (see http://www.epa.gov/cair/ ). **Figure 4**  **: Map of CAIR States**

http://www.epa.gov/cair/ O n July 11, 2008, the U.S. Court of Appeals for the District of Col umbia Circuit found that CAIR violated basic provisions of the Clean Air Act. The court vacated CAIR in its entirety and remanded itPage 11

to EPA in order to promulgate a new rule consistent with the court’s opinion. EPA appealed the decision amid widespread c oncern that, despite its flaws, some form of CAIR was preferable to the sudden regulatory

void created b y the Court’s decision. Upon reconsideration, on December 23, 2008, the Court stay ed the vacatur of CAI R but maintained the remand to EPA to promulgate a new rule consistent with the Court’s July 11, 2008, opinion. Because CAIR formed the regulatory underpinnings for most of the emission reductions that were to produce visibility

improvements in mandatory Class Iareas, the vacatur of CAIR would have re presented a major difficulty for the individual states in attempting to comply with the Regional Haze Rule. While all eastern states have depended in varying degree on CAIR in the preparation of their regional haze SIPs, some Southeast states have relied almost entirely on CAI R to demonstrate c ompliance with the rule. The vacatur of CAIR also called into question the validity of MANE - VU’s (and other RPOs’) emission inventories and air quality modeling studies already completed for the member states’ Regio nal Haze SI Ps. The CAIR Phase I requirements remained in place through 2011. On August 8, 2011, EPA published the Cross - State Air Pollution Rule (CSAPR) to replace CAIR. CSAPR requires 2 8 states in the eastern half of the United States to significantl y improve air quality b y reducing SO 2 and NO x emissions fr o m power plant emissions that cross state lines and contribute to ground - level ozone and fine particle pollution in other states. Massachusetts is not inc l uded in CSAPR. F uture emission controls under CSAPR are similar to those as CAI R originally would have obtained. Therefore, Massachusetts expects that future emissions and air quality levels are likel y to be not very different from values predicted by MANE - VU’s completed modeling, even though that modeling was based on implementation of CAI R as it was before CSAPR . Consequently , the long - term strategy developed for Massachusetts’ SI P represents a reasonable starting point from which to go forward with measures to improve visibility at MANE - VU’s Class I Areas. These measures will be reviewed at the mid - point review in 2013 in consultation with Class I states, who may

at that time reassess their reasonable progress goals. **2.8.** 

### Regional Consultation and the “Ask” 40 CFR Section 51.308(d)(3)(i) requir es Massachusetts to consult with other s tates /tribes to develop coordinated emission management strategies. Massachusetts consulted with other states and tribes through participation in the MANE - VU and inter - RPO processes that developed the technical info rmation necessary

for the development of coordinated strategies. On May 10, 2006, MANE - VU adopted the Inter - RPO State/Tribal and FLM Consultation Framework. A full cop y of MANE - VU’s Final Interim Principles for Regional Planning can be found in Appendix B . That document set s forth the principles listed inPage 12

Figure 5 . MANE - VU states and tribes applied these principles to the regional haze consultation and SI P development processes. Is sues addressed included regional haze baseline assessments, natural background levels, and development of reasonable progress goals

– described at length in later sections of this SI P.Page 13 **Figure 5**  **: MANE -**  **VU Principles for Regional Haz e Planning**  1) All State, Tribal, RPO, and Federal participants are committed to continuing dialogue and information sharing in order to cre ate understanding of the respective concerns and needs of the parties. 2) Continuous documentation of all communications i s necessary to develop a record for inclusion in the SIP submittal to EPA. 3) States alone have the authority to undertake specific measures under their SIP. This inter - RP O framework is designed solely to facilitate needed communication, coordination, and co operation among jurisdictions, but does not establish binding obligation on the part of participating agencies. 4) There are two areas which require State - to - State and/or State - to - Tribal consultations (“formal” consultations): (i) development of the reasonab le 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 th e 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 - RP O consultations, it is anticipated that the States and Tribes will work collectively to fac ilitate 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 reasona ble efforts to facilitate the development of a consensus between the State with a Class I area and other States affect ing that area. In instances where the State with the Class I area cannot agree with such other States that the goal provides for reasonable pro gress, actions taken to resolve the disagreement must be included in the State’s regional haze implementation pla n (or plan revisions) submitted to the EPA Administrator as required under 40 CFR §51.308(d)(1)(iv). 8) All States whose emissions are reasonably anticipated to contribute to visibility impairment in a Class I area must provide t he Federal Land Manager (“FLM ”) agency for that Class I area with an opportunity for consultation, in person, on their regional haze implementation plans. The States/Tribes will pursue the development of a memorandum of understanding to expedite the submission and consideration of the FLM’s comments on the reasonable progress goals and related implementation plans. As required under 40 CFR §51.308(i)(3), the plan or plan revision must include a description of how the State addressed any FLM comments. 9) States/Tribes will consult with th e affected FLMs to protect the air resources of the State/Tribe and Class I areas in accordance with the FLM coordination requirements specified in 40 CFR §51.308(i) and other consultation procedures developed by consensus. 10) The consultation process is des igned 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 following points highlight man y of the ways MANE - VU member states and tribes have cooperativel y addressed regional haze :  Budget Prioritization: MANE - VU devel oped a process to coordinate MARAMA, OTC, and NESCAUM staff in developing budget priorities, project rankings, and the eventual federal grant requests.  Issue Coordination: MANE - VU established a conference call and meeting schedule for each of its committ ees and workgroups. In addition, MANE - VU Air Directors regularly discussed pertinent issues.  SI P Policy

and Planning: MANE - VU states/tribes collaborated on the development of a SI P Template.  Capacity

Building: To educate its staff and members , MANE - VU i ncluded technical presentations on conference calls and organized workshops with nationally recognized experts. Presentations on data analy sis, BART work, inventory topics, modeling, control measures, etc., were an effective education and coordination too l.Page 14

 Routine Operations: MANE - VU staff at OTC, MARAMA, and NESCAUM established a coordinated approach to budgeting, grant deliverables/due - dates, workgroup meetings, inter RPO feedback, etc. In addition to having a set of guiding principles for consultatio n, MANE - VU needed a consistent technical basis for emission control strategies to reduce regional haze to meet the reasonable progress goals for 2018 . After much research and anal ys is, on June 20, 2007, MANE - VU adopted the following pair of documents, whi ch provide the technical basis for consultation among the interested parties and define the basic strategies for controlling pollutants that cause visibility impairment at Class I areas in the eastern United States. Together, these documents are known as the MANE - VU “ Ask ” (Appendix C ).

 “Statement of the Mid - Atlantic / Northeast Visibility Union (MANE - VU) Concerning a Course of Action within MANE - VU toward Assuring Reasonable Progress,” and  “Statement of the Mid - Atlantic / Northeast Visibility Union (MANE - VU) Concerning a Request for a Course of Action by States outside of MANE - VU toward Assuring Reasonable Progress. ” The consultations among MANE - VU states and other states/tribes and provinces occurred through m uch of 2007. Documentation of consultation meetings and calls between MANE - VU Class I States and s tates/tribes both within and outside MANE - VU can found on the MANE - VU website at www.ot cair.org/manevu/consultations.asp?fview=2 . A summary of the consultation process follows.

 MANE - VU Intra - Regional Consultation, March 1, 2007 o At this meeting, MANE - VU members reviewed requirements for regional haze plans, preliminary

modeling results, wo rk 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 o 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 o On this call, the MANE - VU states c oncluded discussions of statements concerning reasonable controls within and outside MANE - VU and agreed on the statements called the MANE - VU “Ask,” including a statement concerning controls within MANE - VU, a statement concerning controls outside MANE - VU, and a statement requesting a course of action by 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 o On this call, the MANE - VU / New Hampshire “Ask” was presented to states in other RPOs, RPO staff, and Federal Land Managers, and an opportunity was provided to request further informat ion. This call was intended to provide information to facilitate informed discussion at follow - up meetings.  MANE - VU Consultation Meeting with MRPO, August 6, 2007Page 15

o This meeting was held at LADCO offices in Chicago, Il linois and was attended by representati ves of MANE - VU and MRPO states, as well as staff. The meeting provided an opportunity

to formally

present the MANE - VU “Ask” to MRPO states and to consult with them regarding the reasonableness of the requested controls. Federal Land Manager agencies also attended the meeting.  MANE - VU Consultation Meeting with VI STAS, August 20, 2007 o This meeting was held at State of Georgia offices in Atlanta and was attended by representatives of MANE - VU and VI STAS states, as well as staff. The meeting provided an opportunity

to formally

present the MANE - VU “Ask” 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

– Midwest RPO Consultation Conference Call, Sep tember 13, 2007 o 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 , including explanation of the flexibility in the “Ask . ” Both MRPO and MANE - VU staff agreed to work together to facilitate discussion of further controls on I CIboilers and EGUs.  MANE - VU Air Directors’ Consultation Conference Call, September 26, 2007 o This call allowed MANE - VU members to clarify their understanding of the “Ask” and to prov ide direction to modeling staff as to how to interpret the “Ask” for purposes of estimating visibility

impacts of the requested controls.  MANE - VU Air Directors’ Conference Call, March 31, 2008 o On this call, NESCAUM presented the results of the final 2018 m odeling and described the methods used to represent the impacts of the measures agreed to by the Class IStates. Federal Land Manager agencies also participated in this call. **2.9.** 

### Meeting the “Ask” **– MANE**  **- VU States**  The member states of MANE - VU have stated the ir intention to meet the terms of the “Ask” in their SI Ps. The “Ask” for member states commits each state to pursue the adoption and implementation of the following emission management strategies, as appropriate and necessary:

 timely implementation of BA RT requirements; and

 a low sulfur fuel oil strategy in the inner zone States (New Jersey , New York, Delaware and Pennsylvania, or portions thereof) to reduce the sulfur content of: distillate oil to 0.05 percent sulfur by weight (500 ppm) by

no later than 2012, of #4 residual oil to 0.25 percent sulfur by weight b y no later than 2012, of #6 residual oil to 0.3

– 0.5 percent sulfur by weight by

no later than 2012, and to further reduce the sulfur content of distillate oil to 15 ppm by 2016; and

 a low sulfur fuel oil strategy in the outer zone States (the remainder of the MANE - VU region) to reduce the sulfur content of distillate oil to 0.05 percent sulfur b y weight (500 ppm) by no later than 2014, of #4 residual oil to 0.25

– 0.5 percent sulfur by weight by no later than 2018, and of #6 residual oil to no greater than 0.5 percent sulfur by weight by

no later than 2018, and to further reduce the sulfur content of distillate oil to 15 ppm by 2018, depending on suppl y availability ; andPage 16

 A 90 percent or greater reduction in sulfur dioxide (SO 2 ) emissions from each of the top 100 electric generating unit s (EGU s ) identified b y MANE - VU (comprising a total of 167 stacks) as reasonabl y anticipated to cause or contribute to impairment of visibility in each mandatory

C lass 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 , alternativ e clean fuels, and other measures to reduce SO 2 and nitrogen oxide (NOx) emissions from all coal burning facilities by

2018 and new source performance standards for wood combustion. These measures and other measures identified will be evaluated during th e consultation process to determine if they

are reasonable and cost - effective. Massachusetts supports the SI Ps of each of its fellow MANE - VU states provided that these SIPs incorporate these commitments. **2.10.** 

### Meeting the “Ask” **– Massachusetts**  As a MANE - VU memb er state, Massachusetts also adopted the “Ask” at the MANE - VU Board meeting on June 7, 2007. Massachusetts intends to meet the terms of this agreement by implementing BART or an alternative to BART as described in Section 8 , and by ensuring reductions in SO 2 emissions from the Massachusetts Targeted EGU stacks , pursuing the low - sulfur fuel oil strategy , and implementing controls on outdoor wood - fired boilers as described in Section 10 . Massachusetts also will pursue other reasonable and cost - effective measures as needed. **2.11.** 

### Meeting the “Ask” **– States Outside of MANE**  **- VU**  For consulting states outside the MANE - VU region, the MANE - VU “Ask” requests the pursuit of the adoptio n and implementation of the following control strategies, as appropriate and necessary :  timely implementation of BART requirements;

 A 90 percent or greater reduction in sulfur dioxide (SO 2 ) emissions from each of the top 100 electric generating units (co mprising a total of 167 stacks) impacting an y m andatory Class I Federal area in the MANE - VU region, or an equivalent SO 2 reduction within each State;

 the application of reasonable controls on non - EGU sources resulting in a 28 percent reduction in non - EGU SO 2 emissions, relative to on - the - books, on - the - way 2018 projections used in regional haze planning, b y 2018, which is equivalent to the projected reductions MANE - VU will achieve through its low sulfur fuel oil strategy ;  continued evaluation of other meas ures including measures to reduce SO 2 and nitrogen oxide (NO x ) emissions from all coal - burning facilities by 2018 and promulgation of new source performance standards for wood combustion. These measures and other measures identified will be evaluated throu gh consultation process es to determine if they are reasonable. Massachusetts recognizes that n on - MANE - VU states may choose not to adopt the MANE - VU “Ask” due to associated costs, conflicts, and relative lack of benefit within their jurisdictions. D uring consultations, some non - MANE - VU states were considering not pursu ing reductions bey ond CAIRPage 17

controls and other measures pertaining to BART. EPA’s CSAPR will provide reductions similar to CAI R and it is hoped that states in the mid - west and southeast RPOs will adopt other additional controls. Ultimately , the approvability of all states’ SI Ps will be determined by EPA. **2.12.** 

### Technical Ramifications of Differing Approaches MANE - VU states intended to develop a modeling platform that was common in terms of meteor ology and emissions with each of the other nearb y RPOs. The RPOs worked diligently to form a common set of emissions with similar developmental assumptions. Even with the best of intentions, it became difficult to keep up with each RPO’s updates and corr ections. Each rendition of emissions inventory improved its quality , but because each update made to one RPO’s emissions meant that the other RPOs needed to incorporate the updates into the full emission set for all the RPOs and then reprocess them, there was a continuous modeling effort where each one outdated the last. Because each rendition put previous modeling efforts out of date, and a single modeling run could take more than a month to complete, inventory

updates contributed to SIP delay s. The emi ssion inventory conflicts were excessively

time consuming and caused most states to miss the official SIP filing date of December 17, 2007. The RPOs also took differing perspectives on which version of the EGU dispatching model (Integrated Planning Model or IPM) to use. At the beginning of the process, I PM version 2.1.9 was available and EPA agreed to its use for emissions preparation. Since then, IPM version 3.0 became available and it became EPA’s preferred version since it had updated fuel costs. MRP O adopted I PM v3.0 for its use, but VI STAS stay ed with IPM v2.1.9. Rather than develop non - comparative datasets for its previous IPM analy ses, MANE - VU also stay ed with IPM v2.1.9. Therefore, of the three eastern RPOs, differing emissions assumptions eventually worked their way

into the final set of modeling assumptions. MANE - VU’s best and final modeling not onl y considers on - the - way /on - the - books emissions programs for 2018 (listed in Section 10), but also includes additional reasonable controls in its r egion, including those contained in the MANE - VU “Ask”. Itshould be noted that other RPOs may not have included such measures in their final modeling. In these cases, the modeling results of states in these RPOs will be inconsistent with meeting the term s of the MANE - VU “Ask”

– a situation that may not be adequately addressed in their SIPs. These inconsistencies will need to be resolved b y EPA. **2.13.** 

### Federal Land Manager Coordination Massachusetts will continue to coordinate and consult with the Federal Land Managers (FLMs) during the development of future progress reports and plan revisions, as well as during the implementation of programs having the potential to contribute to visibility impr ovement in the Class Iareas. Section 51.308 ( i) of the Regional Ha ze Rule requires coordination between s tates/tribes and the FLMs. Opportunities have been provided by MANE - VU for FLMs to review and comment on each of the technical documents developed by MANE - VU and included in this SIP. Massachusetts has provided agen cy contacts to the FLMs as required. In the development of this Plan, the FLMs were consulted in accordance with the provisions of 51.308(i)(2). Mass DEP provided previous drafts of this SI P , or portions thereof, to FLMs and EPA for review and comment on November 25, 2008 and July 31, 2009 , and published the draft SIP for public hearing and comment on January

11, 2011 . Mass DEP provide d the FLMs an opportunity for consultation, in person and at least 60 day s prior to holding a public hearing on the SIP. The comments submitted by the FLMsPage 18

were both general and specific. The reviewing agencies found Massachusetts’ draft Regional Haze SIP to be well written and comprehensive. The uncertainty surrounding CAI R and discrepancies in modeling (especiall y inclus ion of the MANE - VU Ask) between MANE - VU and other RPOs were identified as broad topics for further discussion through the consultation process. Comments of a specific nature were focused primarily on requesting additional informat ion in support of initial BART anal ys es. In accordance with 40 CFR 51.308(i)(3), MassDEP has addressed comments from FLMs regarding the SIP in Appendix D of this plan, as well as comments submitted by EPA. Section 51.308(i)(4) requi res procedures for continuing consultation between s tate s /tribe s and FLMs on the implementation of the visibility protection program s . In particular, consultations will be conducted with the designated visibility protection program coordinators for the National Park Service, the U. S. Fish and Wildlife Service, and the U.S. Forest Service. Mass DEP will consult periodically with the FLMs as necessary

on the status of the following implementation items: 1. Implementation of emissions strategies identified in the SIP as contributing to achieving improvement in the worst - day visibility . 2. Summary

of major new source permits issued. 3. Status of Massachusetts actions to meet commitments for completing any future assessments or rulemakings on sources identified as like ly contributors to visibility

impairment, but not directly addressed in the most recent SI P revision. 4. Any changes to the status of the monitoring strategy or monitoring stations that may affect tracking of reasonable progress. 5. Work underway

for preparing the 5 - ye ar review and / or 10 - ye ar revision. 6. Items for FL Ms to consider or provide support for in preparation for any visibility protection SIP revisions (based on the 5 - ye ar review or the 10 - ye ar revision schedule). 7. Summar ies of discussions (meetings, emails, other records) covered in ongoing communications between Mass DEP and FLMs regarding implementation of the visibility program.Page 19 

# 3. **ASSESSMENT OF BASELI NE AND NATURAL**  **CONDITIONS** Under the Clean Air Act, the Regional Haze SIPs must contain measures to make reasonable progress toward the goal of achieving natural visibility . Section 51.308(d)(2) of EPA’s Regional Haze Rule requires e ach state containing a Class I area to determine baseline and natural visibility conditions for their Class Iarea in cons ultation with FLMs and states identified as containing sources whose emissions contribute to visibility

impairment in Class Iareas. Comparing baseline conditions to natural visibility conditions determines the uniform rate of progress that must be consid ered as states set reasonable progress goals for each Class Iarea. The requirement to assess baseline and natural conditions within Class IAreas is a responsibility of the state containing those areas. Massachusetts does not contain an y Class I Areas; however, assessment of baseline and natural visibility conditions for MANE - VU Class I Areas is included here as reference. **3.2.** 

### Calculation Methodology The Interagency

Monitoring of Protected Visual Environments (IMPROVE) program was establish ed in 1985 to pro vide the data needed to assess current visibility conditions, track changes in visibility , and help determine the causes of visibility impairment in Class IAreas (see Section 4 for more detail ed information about IMPROVE) . IMPROVE data was used to calcul ate baseline and natural conditions for MANE - VU Class I areas. T he IMPROVE monitors listed in Table 4 provide data that are representative of Class I Areas in MANE - VU. As described in the Monitoring Section (Section 4) of this S IP , Massachusetts accepts IMPROVE designation of these sites as representative of Class Iareas in accordance with 40 CFR 51.308(d)(2)(i). **Table 4**  **: IMPROVE Monitors for MANE -**  **VU Class I Areas**

**Class I Area IMPROVE**  **Site Location** 

**(lat itude**  **and longitude)**  **State** Acadia National Park ACAD1 44.38, - 68.26 Maine Moosehorn Wilderness Area MOOS1 45.13, - 67.27 Maine Roosevelt/Campobello International Park MOOS1 45.13, - 67.27 Maine Great Gulf Wilderness Area GRGU1 44.31, - 71.22 New Hampshire Presidential Range/Dry River Wilderness GRGU1 44.31, - 71.22 New Hampshire Lye Brook Wilderness Area LYBR1 43.15, - 73.13 Vermont Brigantine Wilderness Area BRIG1 39.47, - 74.45 New Jersey

Source: VIEWS ( http://vista.cira.colostate.edu/views/ ), prepared on 7/06/06Page 20

In September 2003, EPA issued guidance for the calculation of natural background and baseline visibility conditions. The guidance provides a default method and describes certain refineme nts that states may

wish to evaluate to tailor these estimates to a specific Class I area if it is poorly represented by the default method. At that time, MANE - VU calculated natural visibility for each of the MANE - VU Class Iareas using the default method for the 20 percent best and worst visibility day s. MANE - VU also evaluated way s to refine the estimates. Potential refinements included: increasing the multiplier used to calculate impairment attributed to carbon, adjusting the formula used to calculate the 20 percent best and worst visibility

day s, and accounting for visibility impairment due to sea salt at coastal sites. However, MANE - VU found that these refinements did not significantly improve the accuracy

of the estimates, and MANE - VU states desired a consistent approach. Therefore, default estimates were used with the understanding that this would be reconsidered when better scientific knowledge warranted. Once the technical anal ysis was complete, MANE - VU provided an opportunity to comment to fed eral agencies and stakeholders. The proposed approach was posted on the MANE - VU website on March 17, 2004 and a stakeholder briefing was held on the same day . Comments were received from the Electric Power Research Institute, the Midwest Ozone Group, the Appalachian Mountain Club, the National Parks Conservation Association, the National Park Service, and the US Forest Service. Several comments supported the proposal and other comments addressed four main topics: the equation used to calculate visibility, the statistical technique used to estimate the 20 percent best and worst visibility day s, the inclusion of transboundary effects and fires, and the timing of when new information should be included. All comments were reviewed and summarized by MANE - VU. The MANE - VU Board was briefed on comments and proposed response options. The MANE - VU position on natural background conditions was issued in June 2004, and stated that, “Refinements to other aspects of the default method (e.g., refinements to the assume d distribution or treatment of Rayleigh extinction, inclusion of sea salt, and improved assumptions about the chemical composition of the organic fraction) may be warranted prior to submission of SI Ps depending on the degree to which scientific consensus i s formed around a specific approach...” In 2006, the IMPROVE Steering Committee adopted an alternative reconstructed extinction equation to revise certain aspects of the default method. The aspects revised were scientifically well understood, and the Committee determined that revisions improved the performance of the equation at reproducing observed visibility

at Class Isites. In 2006, NESCAUM conducted an assessment of the default and alternative approaches for calculation of baseline and natural backgro und conditions at MANE - VU Class I areas. (See the MANE - VU document, Baseline and Natural Background Visibility Conditions: Considerations and Proposed Approach to the Calculation of Baseline and Natural Background Visibility Conditions at MANE- VU Class I Areas , Appendix E . ) Corresponding visibility improvement targets for 2018 using each approach also were presented in the document (see Table 3 - 3 of Appendix E ). Res ults suggest that the alternative approach leads to very similar uniform rates of progress in New England with slightly greater visibility improvement required in the Mid - Atlantic region relative to the default approach. Based on that assessment, in December 2006, MANE - VU recommended adoption of the alternative reconstructed extinction equation fo r use in SIPs. MANE - VU will continue to participate in further research efforts on this topic and will reconsider the calculation methodology as scientific under standing evolves.Page 21

**3.3.** 

### MANE **- VU Baseline and Natural Visibility**  The IMPROVE program has calculated the 20 percent best and 20 percent worst baseline (2000 - 2004) and natural visibility

conditions using the EPA - approved alternative method described above for each MANE - VU Class I Area. The data are posted on the Visibility Information Exchange Web S ys tem (VIEWS) operated b y the regional planning organizations. The information can be accessed at http://vista.ci ra.colostate.edu/views/ and is summarized in Table 5 below. Units are expressed in deciviews, a log function of the light scattering and absorption extinction coefficient, as required by 40 CFR 51.308(d)(2). Gen erally , a one deciview change in the haze index is likely to be perceptible under ideal conditions regardless of background visibility conditions. Display ed are the five - ye ar average baseline visibility

values for the period 2000 - 2004, natural visibility levels, and the difference between baseline and natural visibility values for each of the MANE - VU Class I areas. The difference columns (best and worst) are of particular interest because they describe the magnitude of visibility impairment attributable t o manmade emissions, which are the focus of the Regional Haze Rule. The five - ye ar averages for 20 percent best and worst visibility were calculated in accordance with 40 CFR 51.308(d)(2), as detailed in NESCAUM’s Baseline and Natural Background document f ound in Appendix E . **Table 5**  **: Summary of Baseline Visibility and Natural Visibility Conditions for the 20 Percent Best** 

**and 20 Percent Worst Visibility Days at MANE -**  **VU Class I Areas Class**  **I Area(s) 2000**  **- 2004 Baseline**  **(deciviews) Natural Conditions** 

**(deciviews) Difference** 

**(deciviews) Best**  **20% Worst** 

**20% Best** 

**20% Worst** 

**20% Best** 

**20% Worst** 

**20%** Acadia National Park 8.8 22.9 4.7 12.4 4.1 10.5 Moosehorn Wilderness and Roosevelt Campobello International Park 9.2 21.7 5.0 12.0 4.1 9.7 Great Gulf Wilderness and Presidential Range - Dry

River Wilderness 4 7.7 22.8 3.7 12.0 3.9 10.8 Lye Brook Wilderness 6.4 24.5 2.8 11.7 3.6 12.7 Brigantine Wilderness 14.3 29.0 5.5 12.2 8.8 16.8 Source: VIEWS (

http://vista.circa.colostate.edu/views/ ), prepared on 6/22/2007

4 Based on 4 - year average for 2001 - 2004 (data collection in 2000 was for summer only).Page 22 

# 4. **MONITORING STRATEGY** Section 51.308(d)(4) of EPA’s Regional Haze Rule requires a monitoring strategy for measuring, characterizing, and reporting of regional haze visibility impairment that is representative of Class I areas within a state, and allows compliance with this requirement to be met through participation in the Interagency

Monitoring of Protected Visual Environments (IMPROVE) p rogram. In the mid - 1980’s, the IMPROVE program was established to measure visibility impairment in mandatory

Class I areas throughout the United States. The monitoring sites are operated and maintained through a formal cooperative relationship between EP A, National Park Service, U.S. Fish and Wildlife Service, Bureau of Land Management, and U.S. Forest Service. In 1991, several additional organizations joined the effort: State and Territorial Air Pollution Program Administrators, the Association of Local Air Pollution Control Officials (which now goes by The National Association of Clean Air Agencies) , Western States Air Resources Council, Mid - Atlantic Regional Air Management Association, and Northeast States for Coordinated Air Use Management. **4.2.** 

### IMPROVE Pr **ogram Objectives** The IMPROVE program provides scientific documentation of the visual air quality of America’s wilderness areas and national parks. Man y individuals and organizations

– land managers, industry planners, scientists ( including universit y rese archers ) , public interest groups, and air qualit y regulators

– use the data collected at IMPROVE sites to understand and protect the visual air quality resource s in Class Iareas. Major objectives of the IMPROVE program include:

 Establish current visibil ity and aerosol conditions in mandatory Class I areas,  Id entify

chemical species and emission sources responsible for existing anthropogenic visibility impairment,  Document long - term trends for assessing progress towards national visibility goals,  Provide regional haze monitoring representing all visibility- protected federal Class Iareas where practical, as required b y EPA’s Regional Haze Rule. **4.3.** 

### Monitoring Information for Massachusetts Section 51.308(d)(4)(iii) of the Regional Haze Rule requires for a stat e with no Class Iareas, such as Massachusetts, the inclusion of procedures by which monitoring data and other information are used in determining the contribution of emissions from within the s tate to regional haze visibility impairment at Class Iareas o utside the s tate. Massachusetts ’ contribution is documented in the contribution assessment anal ys is completed by NESCAUM entitled, Contributions to Regional Haze in the Northeast and Mid - Atlantic States ( Contribution Assessment) found in Appendix A . The NESCAUM study used various tools and techniques to assess the contributions of individual states and regions to visibility degradation in Class I areas within and outside MANE - VU. Massachusetts agrees that NESC AUM is providing qualit y technical information by using the IMPROVE program data and the V isibility Information E xchange W eb S ys tem (VIEWS) site. In formation about the use of the default and alternative approaches to the calculation of baseline and natura l background conditions can be found in Section 3 of this SI P.Page 23

Massachusetts does not contain any Class I Areas; therefore no monitoring plan is required under Section 51.308(d)(4) or Section 51.30 of the Regional Haze Rule. Massachusetts does, however, have three IMPROVE monitors that were used in the regional haze modeling: Cape Cod (CACO), Martha’s Viney ard (MAVI), and Quabbin summit (QURE). The CACO IMPROVE monitor is located at Cape Cod National Seashore in Truro and is operated and maintained by th e National Park Service. It is located near MassDEP’s monitoring site at latitude 41:58 and longitude - 70:01. The QURE IMPROVE monitor is located at the Quabbin Reservoir in Ware, at latitude 42:17 and longitude

– 72:20, and is operated and maintained by MassDEP. The MAVI IMPROVE monitor is located on Martha’s Viney ard and is operated by the Wampanoag Tribe of Gay Head (Aquinnah) . Massachusetts commits to continuing these monitoring programs and to working with the National Park Service , Wampanoag Tribe, and EPA towards this end. The following information is for monitoring within Class I areas determined to be impacted by Massachusetts sources by the Contribution Assessment contained in Appendix A . **4.4.** 

### Monitoring **Information for MANE -**  **VU Class I Areas Impacted by Emissions**  **from Massachusetts Acadia National Park, Maine**  The IMPROVE monitor for Acadia National Park (ACAD1) is located at park headquarters near Bar Harbor, Maine, at elevation 157 meters, latitude 44.38  ̊, and longitude - 68.26  ̊ (see Figure 6) . This monitor is operated and maintained by the National Park Service. Massachusetts considers the ACAD1 site as adequate for assessing reasonable progress toward visibility goals at Acadia National Park, and no ad ditional monitoring sites or equipment are necessary at this time.Page 24 

### Acadia National Park IM PROV E Site

Created by T om D owns, MEDEP 4/17/07 **IMPROV E MONI**  **TO R LOCAT**  **ION AC**  **AD IA NAT**  **IONAL PARK**  

### LEGEND

http://www.maine.gov/dep/air/meteorology/images/Acadia.jpg **Figure 6**  **: Map of Acadia National Park Showing Location of IMP**  **ROVE Monitor**

**Figure 7**  **: Acadia National Park on Clear and Hazy Days**

**http://www.hazecam.net/class1/acadia.html**Page 25 **IMPROVE MONITOR Great Gulf Wilderness Area, New Hampshire**  The IMPROVE monitor for the Great Gulf Wilderness (GRGU1) is located at Camp Dodge in the mid northern area of Greens Grant in the White Mountain National Forest . The m onitor site lies just east and south of where Route 16 crosses the Greens Grant / Martins L ocation boundary , south of Gorham, New Hampshire , at elevation 454 met ers, latitude 44.31  ̊, and longitude of - 71.22  ̊ (see Figure 8) . This monitor, which also represents the Presidential Range - Dry River Wilderness (see Figure 8) , is operated and maintained b y the U.S. Forest Service. Massachusetts considers the GRGU1 site as adequate for assessing reasonable progress toward visibility goals at the Great Gulf Wilderness , and no additional monitoring sites or equipment are necessary at this time. **Figure 8**  **: Map of Great Gulf and Presidential Range -**  **D ry River Wilderness Areas Showing**  **IMPROVE Monitor Location**

http://www.maine.gov/dep/air/meteorology/images/NHclass1.jpg **Figure 9**  **: Gr eat Gulf Wilderness Area on Clear and Hazy Days** 

**http://www.wilderness.net/**Page 26

**Presidential Range -**  **Dry River Wilderness, New Hampshire** The IMPROVE monitor for the Presidential Range - Dry River Wilderness is a lso the monitor for Great Gulf Wilderness (GRGU1), as described above. Massachusetts considers the GRGU1 site as adequate for assessing reasonable progress toward visibility goals at the Presidential Range - Dry River Wilderness, and no additional monitor ing sites or equipment are necessary at this time. **Presidential Range -**  **Dry River Wilderness in Autumn**

http://www.wilderness.net **Ly e Brook Wilderness, Vermont**  The IMPROVE monitor for the Lye Brook Wilderness (LYBR1) is located on Mount Equinox at the windmills in Manchester, Vermont, at elevation 1015 meters, latitude 4 3.15  ̊, and longitude of - 73.13  ̊ (see Figure 10) . The monitor does not lie within the wilderness area but is situated on a mountain peak across the valley

to the west of the wilderness area. The IMPROVE site and the Ly e Brook Wilderness are at similar ele vations. The monitor is operated and maintained by the U.S. Forest Service. Massachusetts considers the LYBR1 site as adequate for assessing reasonable progress toward visibility goals at the Lye Brook Wilderness, and no additional monitoring sites or eq uipment are necessary

at this time.Page 27 **Figure 10**  **: Location of Lye Brook Wilderness Monitor** 

http://www.wilderness.net/in dex.cfm?fuse=NWPS &s ec=stateView&state=NH& map=menhvt **Figure 11**  **: Lye Brook Wilderness Area**  **on Clear and Hazy Days**

http://www.hazecam.net/class1/lye.html **IMPROVE MONITOR SITE**Page 28

**Moosehorn Wilderness Area, Maine**  The IMPROVE monitor for the Moosehorn Wilderness (MOOS1) is located near McConvey Road, about one mile northeast of the National Wildlife Refuge Baring (ME) Unit Headquarters, at elevation 78 meters, latitude 45.13  ̊, and longitude - 67.27  ̊ (see Figure 12) . This monitor also represents the Roosevelt Campobello International Park in New Brunswick, Canada. The monitor is operated and maintained by

the U.S. Fish & Wildlife Service . Massachusetts considers the MOOS1 site as adequate for assessing reasonable progress toward visibility goals at the Moosehorn Wilderness, and no additional monitoring sites or equipment are necessary at this time. **Figure 12**  **: Map of the Baring and Edmunds Divisions of the Moosehorn Nati**  **onal Wildlife Refuge Showing the IMPROVE Monitor Location** 

source: The Refuge Manager at Moosehorn WildernessPage 29 **Figure 13**  **: Moosehorn Wilderness Area**  **on a Clear and a Hazy Day**

source: Martha Webster, Maine Department of Envi ronmental Protection

– Bureau of Air Quality **Roosevelt/Campobello International Park, New Brunswick, Canada** The IMPROVE monitor for Roosevelt Campobello International Park is also the monitor for the Moosehorn Wilderness (MOOS1), as described above . Mass achusetts considers the MOOS1 site as adequate for assessing reasonable progress toward visibility goals at Roosevelt Campobello International Park, and no additional monitoring sites or equipment are necessary at this time. **Figure 14**  **: Map of Roosevelt/Campobello International Park** 

http://www.maine.gov/dep/air/m eteorology/images/rcip.jpgPage 30

**Figure 15**  **: Roosevelt/Campobello International Park**  **on Clear and Hazy Days**

source: Chessie Johnson, Roosevelt Campobello International Park CommissionPage 31 

# 5. **MODELING** Section 51.308(d)(3)(iii) of the Regio nal Haze Rule requires states to document the technical basis, including modeling, monitoring and emissions information, on which the state is rel yi ng to determine its apportionment of emissions reduction obligations necessary for achieving reasonable progress in each Class Iarea it affects. Air quality

modeling to assess regional haze has been done cooperatively between Massachusetts and its regional planning organization, MANE - VU, with major modeling efforts being conducted b y NESCAUM 5 and screening mod eling being conducted by the New Hampshire Department of Environmental Services . 6 These modeling efforts include emissions processing, meteorological input anal ys is, and chemical transport modeling to conduct regional air quality simulations for calendar ye ar 2002 and several future periods, including the primary target period for this SI P, calendar ye ar 2018. Modeling was conducted in order to assess contribution from upwind areas, as well as Massachusetts’ contribution to Class Iareas in downwind state s. Further, the modeling evaluated visibility benefits of control measures being considered for achieving reasonable progress goals and establishing a long - term emissions management strategy for MANE - VU Class I areas. The modeling tools utilized for thes e anal ys es include the following:

 The Fifth - Generation Pennsylvania State University /National Center for Atmospheric Research (NCAR) Mesoscale Model (MM5) was used to derive the required meteorological inputs for the air quality simulations.  The Sparse Matrix Operator Kernel Emissions (SMOKE) emissions modeling s ys tem was used to process and format the emissions inventories for input into the air quality models.  The Community

Mesoscale Air Qualit y model (CMAQ) was used for the primary SI P modeling.  The Reg ional Model for Aerosols and Deposition (REMSAD) was used during contribution apportionment.  The California Grid Model (CALGRID) and its associated EMSPROC6 emissions processor were used to screen specific control strategies.  The California Puff Model (CALPUFF) was used to assess the contribution of individual states’ emissions to sulfate levels at selected Class I receptor sites. Each of these tools has been evaluated and found to perform adequatel y. The pertinent SIP modeling underwent full performance testing and the results were found to meet the specifications of EPA modeling guidance. For more details on the regional haze modeling, please refer to the NESCAUM report MANE- VU Modeling for Reasonable Progress Goals, Model Performance Evaluation, Pollut ion Apportionment, and Control Measure Benefits (Appendix F ). The detailed modeling approach for the best and final 2018 projected scenario can be found in the NESCAUM report 2018 Visibility Projections (Append ix G ).

5 Alo ng with the NYSDEC, NJDEP/Rutgers, VADEQ, and UMD. 6 Along with the VTDEP and MDEQ.Page 32

**5.2.** 

### Meteorology The meteorological inputs for the air quality simulations were developed b y the University of Maryland (UMD) using the MM5 meteorological modeling sy stem. Meteorological inputs were generated for 2002 to correspond with the baseline emissions inventory and analy sis y ear. The MM5 simulations were performed on a nested grid as illustrated in Figure 16 . As shown in the figure, the modeling domain is comprised of a 36 - km, 145 x 102 continental g rid and a nested 12 - km, 172 x 172 grid encompassing the eastern United States and parts of Canada. Incooperation with the New York State Department of Conservation (NYSDEC), an assessment was made to compare the MM5 predictions with observations from a v ariet y of data sources, including:  surface observations from the National Weather Service (NWS) and the Clean Air Status and Trends Network (CASTNet),  wind - profiler measurements from the Cooperative Agency Profilers (CAP) network,  satellite cloud image d ata from the UMD Department of Atmospheric and Oceanic Science, and  precipitation data from the Earth Observing Laboratory at NCAR. This assessment was performed for the period covering May through September 2002. Further details regarding the MM5 mete orological processing and the modeling domain can be found in Appendix H , NYSDEC’s Meteorological Modeling Using Penn State/NCAR 5 th Generation Mesoscale Model and Appendix F , NESCAUM’s MANE- VU Modeling for Reasonable Progress Goals.Page 33

**Figure 16**  **: Modeling domains used in MANE -**  **VU air quality modeling studies with CMAQ.** Outer (blue) domain grid is 36 km and inner (red) domain is 12 km grid. The gridlines are shown at 180 km intervals (5x5 for 36 km cells/15×15 for 12 km cells).

**5.3.** 

### Emissions Data Preparations Emissions data were prepared for input into the CMAQ and REMSAD air quality models using the SMOKE emissions modeling s ys tem. SMOKE supports point, area, mobile (both on - road and non road), and biogenic emissions. The SMOKE emissions modeling sy stem uses flexible processing to apply chemical speciation as well as temporal and spatial allocation to the emissions inventories. SMOKE incorporates the Biogenic Emission Inventory S ys tem (BEIS) and EPA’s MOBILE6 motor vehicle emission factor model to process biogenic and on - road mobile emissions, respectively . Vector matrix multiplication is used during the final processing step to merge the various emissions components into a single model - read y emissions file. Examples of processed emissions outputs are shown in Figure 17 . Further details on the SMOKE processing that was done in support of the air quality simulations is provided in Appendix H and Appendix I , NYSDEC’s Emission Processing for the Revised 2002 OTC Regional and Urban 12 km Base Case Simulations. Additiona l details on the emission inventory preparation can be found in Section 6 .Page 34

**Figure 17**  **: Examples of processed model -**  **ready emissions: a) SO 2**  **from Point, b) NO 2**  **from Area, c) NO**  **2 from On**  **- ro**  **ad, d) NO 2**  **from Non -**  **road, e) ISOP from Biogenic, f) SO 2**  **from all source categories** Page 35

**5.4.** 

### Model Platforms Two regional - scale air quality models, CMAQ and REMSAD, were used for the air qualit y simulations that directly

supported the Regional Haze SI P effort. C MAQ was developed by EPA and was used to perform the primary

SI P - related modeling. The CMAQ modeling simulations also were an important tool for the 8 - hour ozone SIP process. REMSAD was developed by I CF Consulting/Sy stems Applications International with support from EPA. REMSAD was used b y NESCAUM to perform a source apportionment analy sis. All of the air quality simulations that were used in the SI P efforts were performed on the 12 - km eastern modeling domain shown in Figure 16 above. NESCAUM performed a model performance evaluation for PM 2.5 species, aerosol extinction coefficient, and the haze index, which is provided in Appendix F . NYSDEC also performed a model performance anal ys is to evaluate CMAQ model predictions against observations of ozone, PM 2.5 , and other chemical species, which is contained in Appendix J , CMAQ Model Performance and Assessment, 8 -Hr OTC Ozone Modeling. **CMAQ** The CMAQ air qualit y simulati ons were performed cooperativel y between five modeling centers, including NYSDEC, the New Jersey Department of Environmental Protection (NJDEP) in association with Rutgers University , the Virginia Department of Environmental Quality (VADEQ), UMD, and NESCAUM. NYSDEC also performed an annual 2002 CMAQ simulation on the 36 - km domain shown in Figure 16 ; this simulation was used to derive the boundary conditions for the inner 12 - km eastern modeling domain. Boundary conditions for the 36 - km simulations were ob tained from a run of the GEOS - Chem (Goddard Earth Observing S ys tem) global chemistry transport model that was performed by researchers at Harvard University . The technical options that were used in performing the CMAQ simulations are described in detail i n Appendix K , NYSDEC’s Eight-Hour Ozone Modeling using the SMOKE/CMAQ system. Further technical details regarding the CMAQ model and its execution are also provided in Appendix F . **REMSAD** The REMSAD modeling simulations were used to satisfy the haze rule requirement that a pollution apportionment be performed to assess contribution to visibility improvement by

geographic region or source sector. REMSAD’s species taggin g capability makes it an important tool for this purpose. 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 SO 2 emission sources on the sulfate fraction of PM 2.5 over the northeastern United States using the same 1 2 - km eastern modeling domain as shown in Figure 16 . Appendix F further describes the REMSAD model and its application to the Regional Haze SIP efforts. **CALGRID** In addition to the SIP - quality modeling platforms described above, an additional modeling platform was developed for use as a screening tool to evaluate additional control strategies or to perform sensitivity anal ys es. The CALGR ID model was selected as the basis for this platform. CAL GRID is a grid - base d photochemical air quality model that is designed to be run in a Windows environment. Inorder to make the CAL GRID model the best possible tool to supplement the SIP - quality CMAQ and REMSADPage 36

modeling, the current version of the CAL GRID platform was set up to be run with the same set of inputs as the SI P - quality

models. The CALGRID air quality simulations were run on the same 12 - km eastern modeling domain that was used for CMAQ and REMSAD. This model’s performance was relative to the performance of the al read y evaluated CMAQ and REMSAD models and was thus determined to perform adequatel y. Conversion utilities were developed to re - format the meteorological inputs, the boundary conditions, and the emissions for use with the CAL GRID modeling platform. Pre - m erged SMOKE emissions files were obtained from the modeling centers and re - formatted for input into EMSPROC6, the emissions pre processor for the CALGRI D modeling s ys tem. EMSPROC6 allows the CALGRID user to adjust emissions temporally , geographicall y, and by emissions category

for control strategy

anal ys is. The pre merged SMOKE files that were obtained from the modeling centers were broken down into the biogenic, point, area, non - road, and on - road emissions categories. These files by component were then converted for use with EMSPROC6, thus giving CAL GRID users the flexibility to analyze a wide variet y of emissions control strategies. Additional information on the CALGRI D modeling platform can be found in Appendix L , NHDES’ Modeling Protocol for the OTC CALGRID Screening- Level Modeling Platform for the Evaluation of Ozone. **CALPUFF** CAL PUFF is a non - steady - state Lagrangian puff model that simulates the dispersion, transport, and chemical transformation of atmo spheric pollutants. Two parallel CALPUFF modeling platforms were developed b y the Vermont Department of Environmental Conservation (VTDEC) and the Maryland Department of the Environment (MDE). The VTDEC CAL PUFF modeling platform utilized meteorological ob servation data from the National Weather Service (NWS) to drive the CALMET meteorological model. The MDE platform utilized the same MM5 meteorological inputs that were used in the modeling done in support of the ozone and Regional Haze SIP s. These two pl atforms were run in parallel to evaluate individual states’ contributions to sulfate levels at Northeast and Mid - Atlantic Class I areas. The CALPUFF modeling effort is described in detail in Appendix A .Page 37 

# 6. **EMISSIO NS INVENTORY**  Section 51.308(d)(4)(v) of the Regional Haze Rule requires a statewide emission inventory of pollutants that are reasonabl y anticipated to cause or contribute to visibility impairment in any

mandatory

Class I area. The inventory

must include emissions for a baseline year, future (projected) ye ar, and the most recent ye ar for which data are available. Massachusetts’ baseline y ear is 2002. The pollutants inventoried by

Massachusetts for 2002 include volatile organic compounds (VOCs), nitrogen oxides (NO x ), carbon monoxide (CO), sulfur dioxide (SO 2 ), fine particles (PM 2.5 ), coarse particles (PM 10 ), and ammonia (NH 3 ). The emission inventory consists of the following source categories: stationary point, area, on - road mobile, off

- road mobile, and biogenics. These source categories are discussed further below and in Section 7. **6.2.** 

### Baseline and Future Year Emission Inventories for Modeling Section 51.308(d)(3)(iii) of EPA’s Regional Haze Rule requires Massachusetts to identify the baseline emission inv entory

on which strategies are based. The baseline inventory is used to assess progress in making emissions reductions. Based on EPA guidance entitled, 2002 Base Year Emission Inventory SIP Planning: 8 - hour Ozone, PM 2.5, and Regional Haze Programs, which identifies 2002 as the anticipated baseline emission inventory y ear for regional haze, MANE - VU and Massachusetts used 2002 as the baseline year. Future ye ar inventories were developed for the ye ars 2009 and 2018 based on the 2002 base year. These future ye ar emission inventories include emissions growth due to projected increases in economic activity , as well as the emissions reductions due to the implementation of control measures. In man y instances, states alread y have submitted their 2002 base ye ar S IP inventories to EPA due to their planning obligations under the ozone and/or PM programs. Massachusetts submitted its 2002 inventory to EPA on January

31, 2008. Emission inventories are not static documents, but are constantly revised and updated to re flect the input of better emission estimates as they become available. Therefore, even though the 2002 “SI P” inventories and the 2002 “modeling” inventories both represent emissions from 2002, they may contain slightly different emission estimates due to the different time frames they were made available, and the different purposes each serves. Accurate baseline and future emissions inventories are crucial to the anal ys es required for the Regional Haze SIP process. These emissions inventories were used to drive the air quality modeling simulations that were performed to assess the visibility improvement of potential control measures. Air quality modeling also was used to perform a pollution apportionment, which evaluates the contribution to visibility impairment by

geographic region and b y emission sector. In order to be used in the air quality modeling simulations, the baseline and future ye ar emissions inventories were processed with SMOKE emissions pre - processor for subsequent input into CMAQ and RE MSAD air quality models that were described in Section 5. **MANE -**  **VU Regional Baseline Inventory** The starting point for the 2002 baseline emissions inventory was the 2002 inventory

submittals that were made to EPA by

state and local agencies as part of the Co nsolidated Emissions Reporting Rule (CERR). With contractor assistance (E.H. Pechan & Associates), MANE - VU coordinated and qualit y assured the 2002 inventory

data, and prepared it for input into the SMOKE emissions model. The 2002 emissionsPage 38

from non - MANE - VU areas within the modeling domain were obtained from other Regional Planning Organizations for their corresponding areas. These RPOs included VI STAS, MWRPO, and CenRAP. The 2002 baseline inventory went through several iterations. Work on Version 1 of the 2002 MANE VU inventory

began in April 2004, and the final inventory and SMOKE input files were finalized during January 2005. Work on Version 2 (used from April through September 2005) involved incorporating revisions requested b y some MANE - VU state/ local agencies on the point, area, and on - road categories. Work on Version 3 (used from December 2005 through April 2006) included additional revisions to the point, area, and on - road categories as requested b y some states. Thus, the Version 3 inventory for point, area, and on - road sources was built upon Versions 1 and 2. This work also included development of the biogenic inventory . In Version 3, the non - road inventory was completely

redone because of changes that EPA made to the NONROAD2005 non - road m obile emissions model. Version 3 of the 2002 base y ear emissions inventory was used in the regional air quality modeling simulations. Further description of the data sources, methods, and results for this version of the 2002 baseline inventory

is presented in a technical support document, Appendix M . Emissions inventory data files are available on the MARAMA website at www.marama.org/visib ility/EI_Projects/index.html . After release of Version 3.0 of the MANE - VU 2002 inventory , Massachusetts revised its inventory of area source heating o il emissions due to two changes. First, the sulfur percent used to derive the emissions facto rs was ad

justed from 1.0 to 0.3 because the Massachusetts draft 2002 SO 2 emissions methodology

for commercial and residential distillate fuel used the EPA default sulfur content of 1% instead of the correct 0.3% value that was implemented in 2001 according M assachu setts regulation 310 CMR 7.05(1) and (2). Second, the latest DOE - EIA 2002 fuel use data was used instead of the previous version used in 2001. These two changes significantly altered the 2002 SO 2 emissions for area source heating oil combustion. Massachusetts provided revised 2002 PE and EM tables, which MACTEC used in preparing the 2009/2012/2018 projection inventories. **Massachusetts Baseline Inventory** Massachusetts submitted to EPA in January 2008 its comprehensive 2002 Base Year Emissions Inventory that serves as a baseline for its 8 - Hour Ozone, Carbon Monoxide (CO), and Regional Haze SI PS. The 2002 Inventory was estimated for a t yp ical summer day for the ozone precursors VOC, NO x and CO. CO also was estimated for a t ypical winter day for the CO SIP . Annual emissions were estimated for VOCs, NO x , CO, SO 2 , PM 2.5 , PM 10 , and NH 3 , as required as a baseline for this Regional Haze SIP. The complete MA 2002 Base Year I nventory is part of the Massachusetts 8 - Hour Ozone Attainment Demonstration SIP and is available on MassDEP ’s web site at: http://www.mass.gov/dep/air/priorities/sip.htm . It contains an extensive narrative explaining the methodology

for the development of the inventory and the extensive data files supporting the emission estimates. Massachusetts originall y submitted emission s inventory data electronicall y to the EPA National Emissions Inventory

(NEI) sy stem and subsequently made revisions as a result of Quality Assurance (QA ) procedures. The point source submittal included detailed facility level information, activity data down to the segment level, and annual VOCs, NO x , CO, SO 2 , PM 2.5 , PM 10 , and NH 3 emissions. Massachusetts also electronically submitted area source activity data, emission factors, temporal factors, control factors, annual emissions for all pollutants, and ty pical summer day

(VOC, NO x and CO) andPage 39

winter day

(CO onl y) emissions. Emissions data for point and area sources were submitted to EPA in its required NE I format. For o n - r oad and o ff

- road m obile emissions, Massachusetts estimated ty pical summer and winter day emissions in the 2002 Base Year Inventory . However, for annual emissions Massachusetts relied on MANE - VU contractors to perform the twelve monthl y model runs from EPA’S MOBILE6.2 for on - road emissions and the NONROAD model for off - road emissions. Inorder to estimate annual emissions from on - road mobile sources, Massachusetts submitted to the MANE - VU contractor the necessary MOBILE6.2 inputs such as monthly temperature and I/M scenarios together with other transportation parameters such as daily

vehicle miles travelled, vehicle registration data, and speeds by count y roadway class. Massachusetts also provided temperature and other inputs to MANE - VU contractors for running the NONROAD model in order to estimate annual emissions. The resulting on - road mobile and off - road mobile annual emissions generated b y the MANE - VU contractor were used in the 2002 Base Year Emissions Inventory . EPA estimated 20 02 Biogenic emissions for all counties in the US using its Biogenic Emissions Inventory Sy stem (BEI S - 3) and Massachusetts used these summer day and annual emissions in the 2002 Base Year Emission Inventory for VOC, NO x , and CO. The emissions data submitte d to EPA - NEIwas accessed, anal yz ed, and summarized by the MANE - VU contractors and modelers initially as part of the QA process and modeling for 8 - hour Ozone and Regional Haze. A summary

of the Massachusetts 2002 Base Year Emission Inventory is presented in Table 8 , which is contained in Section 6.5. The 2018 projected Massachusetts emissions in Table 8 were adapted from a MANE - VU summary

based on growth and control facto rs from 2002. **Future Year Emission Control Inventories** A technical support document for the future y ear inventories is included in Appendix N and explains the data sources, methods, and results for future year emission forecasts for three y ears, five emission sectors, three emission control scenarios, seven pollutants, and eleven states plus the District of Columbia. The following is a summary of the future y ear inventories that were developed:  **Projection yea rs**  **:** 2009, 2012, and 2018;  **Emission source sectors :**  point - source electric generating units (EGUs), point - source non electric generating units (non - EGUs), area sources, non - road mobile sources, and on - road mobile sources.  **Emission control scenarios :** 

- A comb ined on - the - books/on - the - way (OTB/OTW) control strategy accounting for emission control regulations already in place as of June 15, 2005, as well as some emission control regulations that were not y et finalized, but were expected to achieve additional emis sion reductions b y 2009; and

- A bey ond - on - the - way (BOTW) scenario to account for controls from potential new regulations that may

be necessary

to meet attainment and other regional air quality goals, mainly for ozone.Page 40

- An updated scenario (sometimes referred to as “best and final”) to account for additional potentially

reasonable control measures. For the MANE - VU region, these include: SO 2 reductions at a set of 167 EGU stacks that were identified as contributing to visibility impairment at northeast Class I areas; implementation of a low - sulfur fuel strategy for non - EGU sources; and implementation of a BART strategy for BART - eligible sources not controlled under other programs. (Note: Refer to Section 10, Long - Term Strategy , for detailed descriptions of spe cific control strategies, including the uncertaint y inherent in OTB and BOT W strategies)  **Pollutants :**  ammonia, carbon monoxide (CO), oxides of nitrogen (NO X ), sulfur dioxide (SO 2 ), volatile organic compounds (VOCs), fine particulate matter (PM 2.5 , sum of f ilterable and condensable components), and coarse particulate matter (PM 10 , sum of filterable and condensable components).  **States :**  Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey , New York, Penns yl vania, Rhode I sland, and Vermont, plus the District of Columbia (all members of the MANE - VU region). **6.3.** 

### Emission **Processor Selection and Configuration**  The SMOKE Processing Sy stem is principally an emissions processing s ys tem, as opposed to a true emissions inventory

preparation s ys te m, in which emissions estimates are simulated from “first principles.” This means that, with the exception of mobile and biogenic sources, its purpose is to provide an efficient, modern tool for converting emissions inventory data into the formatted emiss ions files required for a photochemical air quality model. (SMOKE does generate emissions for on - road mobile and biogenic emissions, however, b y driving the MOBILE6 and BEI S emissions models.) Inside the MANE - VU region, the modeling inventories were proce ssed b y NYSDEC and NESCUAM using the SMOKE (Version 2.1) processor to provide inputs for the CMAQ model. A detailed description of all SMOKE input files such as area, mobile, fire, point and biogenic emissions files, and the SMOKE model configuration are provided in Appendix K . **6.4.** 

### Inventories for Specific Source Types There are five emission source classifications in the emissions inventory :

 stationary

point  stationary

area  non - road mobile  on - road mobile  biogenic Stationary point sources are large sources that emit greater than a specified tonnage per ye ar. Stationary area sources are those whose emissions from individual sources are relatively small, but due to the large number of these sources the collective emissions could be significant (i.e., dry cleaners, service stations, agricultural sources, fire emissions, etc.). Non - road mobile sources are equipment that can move, but do not use the roadway s ( i.e., lawn mowers, construction equipment, railroad locomo tives, aircraft, etc. ) On - road mobile sources are automobiles, trucks, and motorcy cles that use the roadway s ys tem. The emissions from these sources are estimated b y vehicle ty pe and road ty

pe. Biogenic sources are naturalPage 41

sources like trees, crops, gra sses, and the natural decay of plants. For stationary point sources, emissions data is tracked at the facilit y level. For all other source t yp es, emissions are summed on the county level. All emissions were prepared for modeling in accordance with EPA guidance. **Stationary Point Sources** Point source emissions are emissions from large individual sources. Generally , point sources have permits to operate and their emissions are individually calculated based on source specific factors on a regular schedule. The largest point sources are inventoried annuall y. These are considered to be major sources having emissions of ≥ 50 to100 tons per year (tp y) of a criteria pollutant, ≥ 10 tpy of a single hazardous air pollutant (HAP) or ≥ 25 tpy of total HAPs. Emission s from smaller stationary point sources in Massachusetts also are calculated individually , but less frequently , on a triennial basis. Point sources are grouped into EGU sources and other non - EGU industrial point sources. **6.5.** 

### Electric **Generating Units**  The base ye ar inventory

for EGU sources used 2002 continuous emissions monitoring (CEM) data reported to EPA in compliance with the Acid Rain program or 2002 hourl y emission data provided by stakeholders. These data provide hourl y emissions profiles that can be u sed in the modeling of SO 2 and NO x emissions from these large sources. Emission profiles are used to estimate emissions of other pollutants (volatile organic compounds, carbon monoxide, ammonia, and fine particles) based on measured emissions of SO 2 and N O x . Future ye ar inventories of EGU emissions for 2009 and 2018 were developed using the IP M model to forecast growth in electric demand and replacement of older, less efficient and more polluting power plants with newer, more efficient and cleaner units. While the output of the IPM model predicts that a certain number of older plants will be replaced b y newer units to meet future electric ity growth and state - by - state NO x and SO 2 caps, Massachusetts did not directly rel y upon the closure of an y particular plant in establishing the 2018 inventory upon which the reasonable progress goals were set. The IPM model results are not the basis upon which to reliably predict plant closures. Preliminary modeling was thus performed with unchanged IPM 2.1.9 model resu lts. However, prior to the Best and Final Modeling (Appendix G ), future year E GU inventories were modified. First, IPM predictions were reviewed by MANE - VU permitting and enforcement staff. In man y cases, staff felt that the IPM shutdown predictions wer e unlikely to occur. In particular, IPM predicted that many oil - fired EGUs in urban areas would be shutdown. Similar source information was solicited from states in both VI STAS and MRPO. As a result of this model validation, the IPM modeling output was adjusted before the Best and Final modeling (Appendix G ) to reflect staff knowledge of specific plant status in MANE - VU, VISTAS, and MRPO states. Where EGU operating status was contrary to what was predicted b y IPM modeling, the future ye ar emissions inve ntory was adjusted to reflect the operation of those plants expected by state staff. Second, as a result of inter - and intra - RPO consultations, MANE - VU agreed to pursue certain control measures as described in the L ong - Term Strategy section. For EGUs, the agreed upon approach was to reduce emissions from 167 stacks located in MANE - VU, MRPO and VISTAS by 90 percent, as described further in the Long - Term Strategy .Page 42

**6.6.** 

### Non **- EGU Point Sources**  The primary

basis for the 2002 baseline non - EGU emissions were those th at were reported b y state and local agencies for the CERR. As described above, MANE - VU’s contractor, E.H. Pechan & Associates (Pechan) coordinated the QA of the inventory and prepared the necessary files for input into the SMOKE emissions model. Further information on the preparation of the MANE - VU 2002 baseline point source modeling emissions inventory can be found in Chapter II of the Technical Support Document for 2002 MANE- VU SIP Modeling Inventories ( Appendix M ) . Project ed non - EGU point source emissions were developed for the MANE - VU region b y MACTEC Federal Programs, Inc. under contract to MARAMA. The specific methodologies that were used are described in Appendix N , Developm ent of Emissions Projections For 2009, 2012, and 2018 For NonEGU Point, Area, and Nonroad Source In the MANE- VU Region . MACTEC used state - supplied growth factor data where available to project future y ear emissions. Where state - supplied data was not avai lable, MACTEC used EPA’s Economic Growth and Anal ys is Sy stem Version 5.0 (EGAS 5.0) to develop applicable growth factors for the non - EGU component. MACTEC also incorporated the applicable federal and state emissions control programs to account for the exp ected emissions reductions that will take place under the OTB/OTW and BOTW scenarios. **Stationary Area Sources** Stationary

area sources include sources whose individual emissions are relatively small but due to the large number of these sources, their collec tive emissions are significant. Some examples include dry cleaners, service stations, and the combustion of fuels for heating. Area source emissions are estimated by multiplying an emission factor by some known indicator of collective activity , such as f uel use, number of households, or population. The area source emissions inventory submittals made for the CERR became the basis for the area source portion of the 2002 baseline inventory . Similar to the point source category , Pechan, on behalf of MANE - VU , prepared the area source modeling inventory using the CERR submittals as a starting point. Pechan qualit y assured the inventory and augmented it with additional data, including MANE - VU sponsored inventories for categories such as residential wood combus tion and open burning. Detailed information on the preparation of the MANE - VU 2002 baseline area source modeling emissions inventory can be found in Chapter III of Appendix M . Similar to non - EGU point sources, future year are a source emissions were projected for the MANE - VU region by MACTEC. The specific methodologies used are described in Section 3 of Appendix N . MACTEC applied growth factors to the 2002 baseline area source inventory using stat e - supplied data where available or b y using the EGAS 5.0 growth factor model. MACTEC also accounted for the appropriate control strategies in the future ye ar projections. **Non -**  **Road Mobile Sources** Non - road mobile sources are equipment that can move but do n ot use the roadway s, such as construction equipment, aircraft, railroad locomotives, and lawn and garden equipment. For the majorit y of non - road mobile sources, emissions are estimated using the EPA’s NONROAD model. Aircraft, railroad locomotives, and co mmercial marine vessels are not included in the NONROAD model, and their emissions are estimated using applicable references and methodologies. Again, Pechan prepared thePage 43

2002 baseline modeling inventory using the state and local CERR submittals as a starting point. Details on the preparation of the 2002 baseline non - road inventory are described in Chapter IV of Appendix M . Future ye ar non - road mobile source emissions were projected for the MANE - VU region by MACTEC. The methodologies that were used are discussed in Section 4 of Appendix N . In summary , MACTEC used EPA’s NONROAD2005 non - road vehicle emissions model as contained in EPA’s National Mobile Inventory Model. Since calendar y ear is an e xplicit input into the NONROAD model, future y ear emissions for non - road vehicles could be calculated for the applicable projection y ears. For the non road vehicle t yp es that are not included in the NONROAD model (i.e. aircraft, locomotives, and commercia l marine vessels), MACTEC used the 2002 baseline inventory and the projected inventories that EPA developed for these categories for the C lean Air Interstate Rule (C AI R) to develop emission ratios and subsequent combined growth and control factors. Since the future y ears for the CAI R projections did not directly match those required for the purposes of ozone, particulate matter, and regional haze analy ses (i.e., 2009, 2012, and 2018), MACTEC used linear interpolation to develop factors for the required future y ears. **On -**  **Road Mobile Sources** T he on - road emissions source category is comprised of those vehicles that are meant to travel on public roadway s, including cars, trucks, buses, and motorcy cles. The basic methodology used for on - road mobile source calcul ations is to multiply vehicle - miles - traveled (VMT) data by emission factors developed using EPA’s MOBILE6 motor vehicle emission factors model. Unlike the other emissions source categories, the on - road mobile category requires that SMOKE model inputs be p repared, rather than emissions data in SMOKE/IDA format that the other categories require. Therefore, for the 2002 baseline inventory , Pechan prepared the necessary VMT and MOBILE6 inputs in SMOKE format. Projected on - road mobile source inventories were developed b y NESCAUM for the MANE - VU region for ozone, particulate matter, and Regional Haze SI P purposes. As with the other emissions source categories, projected on - road mobile inventories were developed for calendar y ears 2009, 2012, and 2018. As part of this effort, MANE - VU member states were asked to provide VMT data and MOBILE6 model inputs for the applicable calendar ye ars. Using the inputs supplied by the MANE - VU member states, NESCAUM compiled and generated the required SMOKE/MOBILE6 emissions m odel inputs. Further details regarding the on - road mobile source projection can be found in Appendix O , Development of MANE- VU Mobile Source Projection Inventories for SMOKE/MOBILE6 Application . **Biogenic Emission Sources** For the purposes of the 2002 baseline modeling emissions inventory , biogenic emissions were calculated for the modeling domain by the New York State Department of Environmental Conservation (NYSDEC). NYSDEC used the BEI S Version 3.12 as contained within the SM OKE emissions processing model. Biogenic emissions estimates were made for CO, nitrous oxide (NO) and VOC. Further details about the biogenic emissions processing can be found in NYSDEC’s Technical Support Document 1c, Emission Processing for the Revised 2002 OTC Regional and Urban 12 km Base Case Simulations, September 19, 2006 , and in Chapter VI ( Biogenic Sources ) of the Technical Support Document for 2002 MANE - VU SIP Modeling Inventories, Version 3, November 20, 2006. Biogenic emissions were assumed t o remain constant for the future anal ys is y ears.Page 44

**6.7.** 

### Summary of MANE **- VU 2002 and 2018 Emissions Inventory**  Table 6 and Table 7 summarize the emissions inventories for the MANE - VU region compiled for 2002 and projected f

or 2018. 7 The amount of pollutants (in tons per year) emitted from the various source categories is presented. This information was useful in setting r easonable p rogress g oals b y states containing Class I areas (Section 9) and in determining the l ong - t er m s trategy

(Section 10) to address the contribution of Massachusetts to regional haze in Class 1 areas.

**Table 6**  **: MANE -**  **VU 2002 Emissions Inventory Summary (**  **t ons)**  **VOC NO**  **x CO**  **PM 2.5**  **PM 10**  **NH 3**  **SO 2**  **Point** 97,300 673,660 367,645 55,447 89,150 6,194 1,907,634 **Area** 1,528,141 262,477 1,325,853 332,729 1,455,311 249,795 316,357 **On -**  **Road Mobile**  789,560 1,308,233 11,749,819 22,107 31,561 52,984 40,091 **Non**   ** Road** **Mobile** 572,751 431,631 4,553,124 36,084 40,114 287 57,257 **Biogenics** 2,575,232 2 8,396 274,451 - - - - **TOTAL** 5,562,984 2,704,397 18,260,892 446,367 1,616,136 309,260 2,321,339 Source: Pechan, 2006. " Technical Support Document for 2002 MANE- VU SIP Modeling Inventories, Version 3 ." November 20, 2006. Appendix M

7 Ta bles 6 - 8 are based upon the 2002 MANE - VU Regional Baseline Inventory, version 3. See Appendix M for details.Page 45 **Table 7**  **: MANE -**  **VU 2018 Emissions Inventory Summary (in tons)**  **VOC NO**  **x PM**  **2.5 PM**  **10 NH**  **3 SO**  **2 P**  **oint** 114,290 374,952 93,267 128,483 11,136 598,520 **Area** 1,334,038 263,031 243,321 720,462 341,746 129,656 **On -**  **Road M**  **obile** 269,981 303,955 9,189 9,852 66,476 8,757 **Non -**  **Road Mobile**  380,076 271,181 23,933 27,055 360 8,643 **Biogenics** 2,575,232 28,396 - - - - **TOTAL** 4,673,617 1,241,515 369,710 885,852 419,718 745,576 Source: MACTEC, 2007. " Development of Emission Projectio ns for 2009, 2012, and 2018 for non -EGU Point, Area, and Nonroad Sources in the MANE- VU Region ." February 28, 2007. Appendix N EGU Point Emissions: VISTAS_PC_1f IPM Run, Appendix W **6.8.** 

### Summary **of Massachusetts 2002 Base and 2018 Projected Emissions and**  **Reductions** Table 8 presents the Massachusetts inventories for the 2002 base ye ar 8 and for the 2018 projected emissions and exp ected reductions. The MANE - VU 2002 and 2018 emission summary and reductions, derived from Table 6 and Table 7 , also are presented for comparison. Table 8 shows that Massachusetts’ overall projected reduc tion of total regional haze pollutants between 2002 and 2018 is 38 percent. This is closely comparable to MANE - VU’s overall reduction of 36 percent for the same period. Thus, actions taken to reduce Massachusetts’ emissions are projected to meet the obje ctives of the MANE - VU Reasonable Progress Goals. **Table 8**  **: Massachusetts 2002 Base Year and 2018 Projected Emissions and Reductions (in tons)**  **VOC NO**  **x CO**  **SO 2**  **PM 10**  **PM 2.5**  **NH 3**  **RH TOT AL**  **9 MA 2002 BASE YEAR**  POINT > 1 TPY 1 5,647 45,590 21,403 101,049 5,852 4,161 1,526 AREA 2 159,753 34,371 137,278 25,585 191,369 43,203 16,786 ON - ROAD MOBILE 3 57,186 143,368 1,039,100 4,399 3,408 2,410 5,499 OFF - ROAD MOBILE 4 56,7 49 42,769 461,514 3,791 3,531 3,226 28 BIOGENICS 5 113,957 1,257 11,594 - - - - **MA 2002 ANTHROP OGENIC**  **279,335 266,098**  **1,659,295 134,824**  **204,160 53,000**  **23,839 MA 2002 WITH BIOGENICS**  **393,292 267,355**  **1,670,889 134,824**  **204,160 53,000**  **23,839 1,076470** 

8 Massachusetts 2002 Baseline Emission Inventory. Available online: http://www.mass.gov/dep/air/priorities/aqdata.htm 9 Excludes CO, which is not a regional haze pollutant.Page 46 **MA 2018 PROJECTED Y EAR**  POINT > 1 TPY 6 10,902 40,458 27,286 55,878 9,137 6,827 1,622 AREA 7 134,963 36,199 125,205 1,804 82,027 31,237 19,552 ON - ROAD MOBILE 8 17,056 22,813 515,460 1,937 893 840 5,817 OFF - ROAD MOBILE 9 36,306 27,040 546,373 442 2,246 2,052 36 BIOGENICS 10 113,958 1,257 11,594 - - - - **MA 2018 ANTHROPOGENIC 199,227**  **126,510 1,214,324**  **60,061 94,303**  **40,956 27,027**  **MA 2018 WITH BIOGENICS 313,185**  **127,767 1,225,918**  **60,061 94,303**  **40,956 27,027**  **663,299** MA 2002 - 2018 REDUCTION 80,107 139,588 444,971 74,763 109,857 12,044 (3,188) **413,171 MA 2002** **- 2018 REDUCTION %**  **20.4% 52.2%**  **26.6% 55.5%**  **53.8% 22.7%**  **- 13.4%**  **3 8**  **. 4**  **% MANEVU 2002 WITH BIOGENICS**  **11 5,562,984**  **2,704,397 18,260,892**  **2,321,339 1,616,136**  **446,367 309,260**  **12,960,483 MANEVU 2018 WITH BIOGENICS**  **11 4,673,617**  **1,241,515 13,728,087**  **745,576 885,852**  **369,710 419,718**  **8,335,988 MANEVU 2002**  **- 18 REDUCTION %**  **16.0% 54.1%**  **24.8% 67.9%**  **45.2% 17.2%**  **- 35.7%**  **35 .**  **7 %**  1. VOC & NOx Point emissions are from MA 2002 Base Year Inventory with cut - offs at > 10 TPY. Because CO, SO2, PM10, PM2.5 and NH3 Point emiss ions cut - off was 100 TPY for the MA 2002 Inventory, Massachusetts used MANE - VU's Point emissions that were counted dow n to 1 TPY. MANE - VU used EPA - NEI, in w hich EPA 'gap - filled' and augmented the Primary PM10 and PM2.5 emissions to include co ndensables (w hich most states do not report). This is explained in EPA's Point Source Inventory Documentation: http://www.epa.gov/ttn/chief/net/2002inventory.html (EI QA a nd Data Augmentation) 2. Area Source 2002 emissions from MA 2002 Base Year In ventory. MA original Area fuel SO2 was 54,924 TPY and was revised to 25,585 TPY. This revision was due to a change in the assumed sulfur content, but was not included in MANE - VU Version 3 inventory; hence the original value was modeled. 3. From P at Davis (MARAMA) April 25 2006 e - mail attachments 'V3 2002 MANEVU OnRoad Source filed in ks/MANEVU - Projections. 4. From MACTEC 2009 - 12 - 18 Projections, Tables 4.2a to 4.8c, Feb.07 http://marama.org/visibility/Inventory%20Summary/FutureEmissionsInventory.htm 5. 2002 emissions - MA 2002 Base Year Emission Inventory - Originally from Pat Davis 4/25/2006 e - mail attachment "V3 2002 MANE - VU Biogenic Sources" 6. Non - EGU from MACTEC 2009, 2012 & 2018 Projections Report Tables 5 - 6 to 5 - 12, Feb.2007 http://mar ama.org/visibility/inventory%20Summary/ Future/EmissionsInventory.htm. EGU projections from MACTEC FTP Website & http://marama.org/visibility/EI - Projects/index.html StateLevelSummarym02.xls Emissions 08/04/2005. 7. From MARAMA/MAC TEC 2009, 2012 & 2018 Projections Report Tables 5 - 17 to 5 - 23, Feb.2007. SO2 and other pollutants were adjusted for the effects of RPG Low

Sulfur %. Pat Davis 3/28/08 e - mail attachment: 2108 Best & Final - All - Pollutants - Emiss - 032808.xls. Julie McDill 3/17/2008 e - mail re RPG. 8. From Pat Davis e - mail Mar - 11 - 2008 NESCAUM 2018 MOBILE6.2 annual runs. File:ks/RH - SIP - Mobile - 2018 - sum - MV. 9. From MACTEC 2009 - 12 - 18 Projections, Tables 4.2a to 4.8c, Feb.07 http://marama.org/visibility/Inventory%20Summary/FutureEmissionsInventory.htm 10. From MA 2002 Base Year Emission Inventory - originally from Pat Davis 4/25/2006 e - mail attachment "V3 2002 MANE - VU Biogenic Sources" 11. From MANE - VU Draft SIP Inventory Template Section 7.6, October 2007. From MACTEC 2/07 "Development Emissions Projections 2009, 2012 & 2018 & Julie McDill's (MARAMA) 3/ 17/08 e - mail w ith revised 2018 SO2 emissions due to RPG low sulfur %.Page 47 

# 7. **UNDERSTANDING THE SO URCES OF VISIBILITY**  **** **IMPAIRING POLLUTANTS** This section explores th e origins, quantities, and roles of visibility- impairing pollutants emitted in the eastern United States and Canada that contribute significantl y to regional haze at MANE - VU’s mandatory Class Iareas. **7.2.** 

### Visibility **- Impairing Pollutants**  The pollutants primaril y responsible for fine particle formation, and thus contributing to regional haze, include SO 2 , NO x , VOCs, NH 3 , PM 10 , and PM 2.5 . The MANE - VU Contribution Assessment (Appendix A ), finalized in August 2006, refle cts a conceptual model in which sulfate emerges as the most important single constituent of haze - forming fine particle pollution and the principle cause of visibility impairment across the Northeast region. Sulfate alone accounts for an yw here from one - hal f to two thirds of total fine particle mass on the 20 percent haziest day s at MANE - VU Class Isites. This translates to about two - thirds to three - fourths of visibility extinction on those day s. Organic carbon was shown to be the second largest contributo r to haze. As a result of the dominant role of sulfate in the formation of regional haze in the Northeast and Mid - Atlantic Regions, MANE - VU concluded that an effective emissions management approach would rely heavil y on broad - based regional SO 2 control me asures in the eastern Unite d States. Visibility extinction is a measure of the ability of particles to scatter and absorb light. Extinction is expressed in units of inverse mega - meters (Mm - 1 ). Figure 18 shows the dominance of sulfate (bottom ye llow bar) in visibility

extinction calculated from 2000 - 2004 baseline data. **Figure 18**  **: Contributions to PM 2.5**  **Extinction at Seven Class I Sites**Page 48

**Contributing States and Regions** The MANE - VU Contribution Assessment used various modeling techniques, air qualit y data anal ys is, and emissions inventory

anal ys is to identify

source categories and states that contribute to visibility impairment in MANE - VU Class Iareas. With respect to sulfate, based on est imates from four different techniques, the Contribution Assessment estimated that 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. (Emissions from other regions, Canada, and outside the modeling domain also were important). Table 9 shows the results of one of the four methods of assessing state - by - 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 9**  **: Percent of Annual Average Modeled Sulfate Due to Emissions from Listed States 10** 

**Contributing States or**  **Areas Acadia,** 

**Maine (%)**  **Brigantine,**

**New Jersey**  **(%) Dolly** 

**Sods, West**  **Virginia (%)**  **Great Gulf**

**and Presidential**  **Range Dry River, New**  **Hampshire (%)**  **Lye**

**Brook, Vermont**  **(%) Moosehorn** 

**and Roosevelt**  **Campobello, Maine**  **(%) Shenandoah,** 

**Virginia (%)**  **Con necticut**  0.76 0.53 0.04 0.48 0.55 0.56 0.08 **Delaware** 0.96 3.20 0.30 0.63 0.93 0.71 0.61 **District of Columbia**  0.01 0.04 0.01 0.01 0.02 0.01 0.04 **Maine** 6.54 0.16 0.01 2.33 0.31 8.01 0.02 **Maryland** 2.20 4.98 2.39 1.92 2.66 1.60 4.84 **Massachusetts** 10.11 2. 73 0.18 3.11 2.45 6.78 0.35 **New Hampshire**  2.25 0.60 0.04 3.95 1.68 1.74 0.08 **New Jersey**  1.40 4.04 0.27 0.89 1.44 1.03 0.48 **New York**  4.74 5.57 1.32 5.68 9.00 3.83 2.03 **Pennsylvania** 6.81 12.84 10.23 8.30 11.72 5.53 12.05 **Rhode Island** 0.28 0.10 0.01 0.11 0.06 0.19 0.01 **Vermont** 0.13 0.06 0.00 0.41 0.95 0.09 0.01 **MANE -**  **VU** 36.17 34.83 14.81 27.83 31.78 30.08 20.59 **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 52.8 3 18.71 F igures 19 and 20 are from the Contribution Assessment and show another method used to identify and rank states’ contributions to sulfate at MANE - VU and nearb y Class I areas using 2002 data. This 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 source - receptor distance (d). This

10 Percentages based on 2002 annual average sulfate impact estimated with REMSAD model as described in MANE - VU Contribution Assessment Chapt er 4 and summarized on page 8 - 2 of the Contribution Assessment (Appendix A ).Page 49

Q/d ratio is then multiplied by a factor designed to account for the effects of prevailing w inds and to convert units. The use of this technique is explained in the Contribution Assessment. Based on the results of the Q/d technique, F igures 19 and 20 show the resulting rankings across a set of northern and southern Class I areas in or near MANE - VU. F igure 19 covers the four northern Class I areas in MANE - VU (Ly e Brook, Great Gulf, Acadia, and Moosehorn). F igure 20 covers one Class I area in the southern part of MANE - VU (Brigantine) as well as two neighboring Class I areas in the VI STAS region (Doll y Sods and Shenandoah). Massachusetts ranks tenth in annual average sulfate contributions to Northeast Class Iareas in Figure 19 and 23rd for the Mid - Atlantic Class Iareas in Figure 20 . For more details about the methods used to identify contribut ing states and regions, please see the Contribution Assessment. Note the importance of emissions from Canada and from various states outside of the MANE - VU region. **Figure 19**  **: Ranked state percent sulfate contributions to Northea st Class I receptors based on**  **emissions divided by distance (Q/d) results**

0.00 0.10 0.20 0.30 0.40 0.50 0.60 0.70CanadaPAOHINNYMIWVILGAMAKYNCVAMDALTNTXMOFLWINJMESCNHDEKSMNIACTOKMSLANEVTARRIDC**A n** **n u** **a l** **A v** **e r** **a g** **e C** **o n** **t r** **i b** **u t** **i o** **n (** **g /** **m 3** **S O** **4 )**  Ac adia Gre at Gu lf Lye Brook Mooseh orn 

## MAPage 50

**Figure 20**  **: Ranked state percent sulfate contributions to Mid -**  **Atlantic Class I receptors based on emissions divided by distance (Q/d) results** 

0.00 0.10 0.20 0.30 0.40 0.50 0.60 0.70OHPAWVNCCanadaMDINVAKYGANYILTNMIALNJTXFLDESCMOWIMAMSKSMNOKIALACTNHARNEMEDCRIVT**A n** **n u** **a l** **A v** **e r** **a g** **e C** **o n** **t r** **i b** **u t** **i o** **n (** **μ g** **/ m** **3 S** **O 4** **)** Brig an ti ne Dol ly So ds Sh en an do ah

The ranking of emission contributions to visibility impairment in the MANE - VU Class I areas b y methods such as these has direct relevance to the consultation process described previously in Section 3. Using results from the REMSAD model, MANE - VU applied the f ollowing three criteria to identify states and regions for the purposes of consultation on regional haze: 1. Any state/region that contributed 0.1  g/m 3 sulfate or greater on the 20 percent worst visibility day s in the base y ear (2002) 2. Any state/region that contributed at least 2 percent of total sulfate observed on the 20 percent worst visibility

day s in 2002 3. Any state/region among the top ten contributors on the 20 percent worst visibility day s in 2002. For the purposes of deciding how broadl y to consult, the MANE - VU States settled on the second of the three criteria: an y state/region that contributed at least 2 percent of total sulfate observed on the 20 percent worst visibility

day s in 2002. In the following seven figures, states and regions meeting the three listed criteria are identified graphicall y for seven Class Iareas: Shenandoah and Dolly Sods are Class I areas in the VISTAS region that are impacted b y emissions from MANE - VU states; the other five Class Iareas are in MANE - VU. Note that the IMPRO VE monitor at Great Gulf also represents the Presidential Range - Dry River Wilderness, and the IMPROVE monitor at Moosehorn also represents Roosevelt Campobello International Park. Each figure has three components: 

## MAPage 51

 On the left is a single bar graph of th e IMPROVE - monitored PM 2.5 mass concentration (  g/m 3 ) by constituent species for the baseline years 2000 - 2004. The bottom (yellow) portion of the bar represents the measured sulfate concentration.  The middle component of each figure provides a bar graph of the 2002 total sulfate contribution of each state or region as estimated by REMSAD.  Finally , the right segment contains three maps showing which states meet the criteria described above. The three arrows from the bar graph in the middle component indicat e the cut - offs for state inclusion in the maps in the right segment. Connecticut, Rhode Island, Vermont, and the District of Columbia were not identified as being among the political or regional units contributing at least 2 percent of sulfate at any of the seven Class I areas. However, as participants in MANE - VU, those entities have agreed to pursue adoption of regional control measures aimed at visibility improvement on the haziest day s and prevention of visibility degradation on the clearest day s. Bas ed on the MANE - VU Contribution Assessment, emissions from Massachusetts contribute to visibility degradation in the following Class I areas: Acadia National Park, Great Gulf Wilderness, Ly e Brook Wilderness, Presidential Range/Dry River Wilderness, Mooseh orn Wilderness, and Roosevelt/Campobello International Park. Figure 21 ,Page 52

Figure 26 , and Figure 27 , respectivel y , illustrate that emissions from Ma ssachusetts do n ot contribute greater than 0.1  g/m 3 sulfate or 2% of sulfate to the Brigantine , Shenandoah , and Doll y Sods Class I areas. **Figure 21**  **: Modeled 2002 Contributions to Sulfate by State at Brigantine** 

# Brigantine 20% Worst Day s

0 5 10 15 20 25

Br igantine Su lfate Nitrate EC OC Se a Salt So il 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Bri ganti ne CA NA DA CENRA P SE _BC W_BC N_ BC V T RI ME DC MS CT NH MA WI NY A L IL SC MI KY TN IN NJ DE GA WV MD V A NC OH PA 0.1 μ g/m 3 Sulfate

2 % of Sulfate

Top 10 States

**IMPROVE m ass 00**  **- 04**  **Threshold options REMSAD**  **2002 Contribution to Sulfate**g/m3

# # #Page 53 **Figure 22**  **: Modeled 2002 Contributions to Sulfate by State at Lye Brook** 

# Lye Brook 20% Worst Day s

0 2 4 6 8 10 12 14 16

Ly e Br ook Su lfa te Nitrate EC OC Sea Salt So il 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Ly e Brook CA NA DA CE NRA P SE _BC W_BC N_BC DC RI MS ME CT V T NH WI DE SC A L NJ IL MA TN GA MI KY V A IN NC MD WV NY OH PA 0.1 μ g/m 3 Sulfate

2 % of Sulfate

Top 10 States

**IMPROVE mass 00 -**  **04 Threshold options**  **REMSAD 2002 Contribution to Sulfate** g/m3

# # #

**Figure 23**  **: Modeled 2002 Contributions to Sulfate by State at Great Gulf and Presidential Range/Dry River Wilderness**  

# Great Gulf 20% Worst Day s

0 2 4 6 8 10 12

Great Gulf Su lf ate Nitrate EC OC Sea Salt So il 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Great Gul f CA NA DA CENRA P SE _BC W_BC N_ BC DC MS V T RI ME CT DE A L NJ WI SC TN V A IL MD GA NH KY NC MI WV IN MA NY PA OH **IMPROVE mass 00 -**  **04 Thresh**  **old options REM**  **SAD 2002 Contribution to Sulfate**  0.1 μ g/m 3 Sulfate

2 % of Sulfate

Top 10 Statesg/m3

# # #Page 54 **Figure 24**  **: Modeled 2002 Contributions to Sulfate by State at Acadia** 

# Acadia 20% Worst Day s

0 2 4 6 8 10 12

Aca dia Su lfate Nitrate EC OC Se a Salt So il 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Aca di a CA NA DA CENRA P SE _BC W_BC N_ BC DC MS VT RI AL DE WI CT TN GA SC NJ VA IL KY MD MI NC NH IN WV ME NY PA OH MA 0.1 μ g/m 3 Sulfate

2 % of Sulfate

Top 10 States

**IMPROVE mass 00 -**  **04 Threshold options**  **REMSAD 2002 Contribution to Sulfate** g/m3

# # #

**Figure 25**  **: Modeled 2002 Contributions to Sulfate by State at Moosehorn and Roosevelt Campobello International Park**  

# Moosehorn 20% Worst Days

0 2 4 6 8 10 12

Mo os ehorn Su lfate Nitrate EC OC Se a Salt So il 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Mo os ehorn CA NA DA CENRA P SE _BC W_BC N_ BC MS DC VT RI AL CT WI DE SC TN GA NJ VA MI IL KY NH MD NC IN WV ME NY OH PA MA 0.1 μ g/m 3 Sulfate

2 % of Sulfate

Top 10 States

**IMPROVE mass 00 -**  **04 Threshold options**  **REMSAD 2002 C**  **ontribution to Sulfate**g/m3

# # #Page 55

**Figure 26**  **: Modeled 2002 Contributions to Sulfate by State at Shenandoah**  

# Shenandoah 20% Worst Days

0 2 4 6 8 10 12 14 16 18 20

Sh enandoah Su lfate Nitrate EC OC Se a Salt So il **IMPROVE mass 00 -**  **04** 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Shenandoah CA NA DA CENRA P SE _BC W_BC N_ BC VT RI ME DC MS NH CT MA NJ DE SC WI AL TN IL GA NY NC MI MD VA KY IN WV PA OH **Threshold options**

0.1 μ g/m 3 Sulfate

2 % of Sulfate

Top 10 States

**REMSAD 2002 Contribution to Sulfate**  # # #g/m3

**Figure 27**  **: Modeled 2002 Contributions to Sulfate by State at Dolly Sods** 

# Dolly Sods 20% Worst Days

0 2 4 6 8 10 12 14 16 18 20

Dolly Sods Su lfa te Nitrate EC OC Se a S alt Soil 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Do lly Sods CA NA DA CE NRA P SE _BC W_BC N_BC RI V T ME DC CT NH MA MS DE NJ WI NY MD SC MI IL V A A L TN NC GA IN KY PA WV OH 0.1 μ g/m 3 Sulfate

2 % of Sulfate

Top 10 States

**IMPROVE mass 00 -**  **04 Threshold**  **options REMSAD**  **2002 Contribution to Sulfate** # # #g/m3Page 56

**7.3.** 

### Emissions Sources and Characteristics T he major pollutants responsible for regional haze are SO 2 , N O X , VOCs, NH 3 , PM 10 , and PM 2.5 . The following is a description of the sources (e.g., point, area, and mobile) and characteristics of pollutant emissions contributing to haze in the eastern United States. Emissions data and graphics presented in this sect ion are taken from the MANE - VU 2002 Baseline Emissions Inventory , Version 2.0 (note that the more recent MANE - VU 2002 Baseline Emissions Inventory , Version 3.0, released in April 2006, has superseded Version 2.0 for modeling purposes). Although the emissi ons inventory database also includes carbon monoxide (CO) , this primary pollutant is not considered here because it does not contribute to regional haze. In addition to the MANE - VU inventory , useful emissions inventories include the 1996 EPA National Em issions Trends database (NET) and the 1999 National Emissions Inventory (NEI) 11 . Trends among the three emissions inventories

– NET 1996, NEI 1999, and MANE - VU 2002

– are highlighted in the text and graphics presented below. **Sulfur Dioxide (SO 2** 

**)** SO 2 is the primary

precursor pollutant for sulfate particles. Sulfate particles commonly account for more than 50 percent of particle - related light extinction at northeastern Class I areas on the clearest day s and for as much as or more than 80 percent on the hazies t day s. Hence, SO 2 emissions are an obvious target for reducing regional haze in the eastern United States. Combustion of coal and, to a lesser extent, of certain petroleum products accounts for most anthropogenic SO 2 emissions. Infact, in 1998 a singl e source category , coal - burning power plants, was responsible for two - thirds of total SO 2 emissions nationwide (Appendix P ).

11 EPA's Emission Factor and Inventory Group (EFIG) / Office of Air and Radiation (OAR) / Office of Air Quality Planning and Standards (OAQ PS) / Emissions, Monitoring and Analysis Division (EMAD) prepares a national database of air emissions information with input from numerous state and local air agencies, from tribes, and from industry. This database contains information on stationary and mo bile sources that emit criteria air pollutants and their precursors, as well as hazardous air pollutants (HAPs). The database includes estimates of annual emissions, by source, of air pollutants in each area of the country on an annual basis. The NEI i ncludes emission estimates for all 50 states, the District of Columbia, Puerto Rico, and the Virgin Islands. Emission estimates for individual point or major sources (facilities), as well as county level estimates for area, mobile, and other sources, are available currently for years 1985 through 2005 for criteria pollutants, and for years 1996 and 2005 for HAPs. Data from the NEI help support air dispersion modeling, regional strategy development, setting regulations, air toxics risk assessment, and trac king trends in emissions over time. For emission inventories prior to 1999, the National Emission Trends (NET) database maintained criteria pollutant emission estimates, and the National Toxics Inventory (NTI) database maintained HAP emission estimates. Beginning with 1999, the NEI began preparing criteria and HAP emissions data in a more integrated fashion to take the place of the NET and the NTI.Page 57

Figure 28 shows SO 2 emissions trends in the MANE - VU states extracted from the NEI for the ye ars 1996, 1999, and from the 2002 MANE - VU inventory 12 . Most of the states show declines in y ear 2002 annual SO 2 emissions as compared to 1996 emissions. The decline can be attributed to implementation of the second phase of the EPA Acid Rain Program, which in 2000 further reduced allowable emissions and extended emissions limits to more power plants.

12 EPA (2005) http://www.epa.gov/ttn/chief/ei information.html and MARAMA (2004) http://www.marama.org/visibility/2002%20NEI/index.htmlPage 58 **Figure 28**  **: Trends in Annual Sulfur Dioxide Emissions by State**

**0.0 0.2**  **0.4 0.6**  **0.8 1.0**  **1.2 1.4**  **Connecticut De** 

**laware District of Columbia**  **Maine Ma**  **ryland Massachusetts** 

**New Hampshire**

**Ne w Jersey**  **New York**

**Pennsylvania**

**Rhode Island Vermont** **m i** **l l** **i o** **n t** **/ y**  **NEI 1996 NEI 1999 V3**  **MANE-VU 2002 V3**

Figure 29 shows the percent contribution from different source categories to overall, annual 2002 SO 2 emissions in the MANE - VU states. The chart shows that point sources dominate SO 2 emissions, which primarily consist of stationary

combustion sources for generating electricity, industri al energy , and heat. Smaller stationary

combustion sources called “area sources” (primaril y commercial and residential heating, and smaller industrial facilities) are another important source category in the MANE - VU states. By contrast, on - road and non - r oad mobile sources make only a relatively

small contribution to overall SO 2 emissions in the region (Appendix P ).Page 59 **Figure 29**  **: 2002 Sulfur Dioxide Emissions (SO 2**  **) by State**

0% 25% 50% 75% 100%

Co nne ct ic ut De law are Di st ri ct of Col um bi a Ma in e Ma ryla nd Ma ssa chuse tt s Ne w Ham ps hir e Ne w Jersey Ne

w York Pen nsylva nia Rh ode I sl an d Verm on t 0. 0

0. 2 0. 4 0. 6 0. 8 1. 0 1. 2**m i** **l l** **i o** **n t** **/ y** 

AR EA NO NRO AD ON ROAD PO IN T Em is si on Bar Graph: Percentage Fract ions of the Four Source Categories ( - o - ) Line Graph: Total State Annual Emissions (10 6 tpy ) **Volatile Organic Compounds (VOCs)** Existing emissions inventories generally refer to volatile organic compounds (VOCs) for h ydrocarbons whose volatility

in th e atmosphere makes them particularl y important from the standpoint of ozone formation. From a regional haze perspective, there is less concern with the volatile organic gases emitted directly

to the atmosphere and more with the secondary organic aerosol ( SOA) that the VOCs form after condensation and oxidation processes. Thus the VOC inventory category is of interest primarily because of the organic carbon component of PM 2.5 . After sulfate, organic carbon (OC) generall y accounts for the next largest sh are of fine particle mass and particle - related light extinction at northeastern Class I sites. The term organic carbon encompasses a large number and variety of chemical compounds that may come directly

from emission sources as a part of primary

PM or may form in the atmosphere as secondary pollutants. The organic carbon present at Class Isites includes a mix of species, including pollutants originating from anthropogenic (i.e., manmade) sources as well as biogenic h ydrocarbons emitted by vegetation. Re cent efforts to reduce manmade organic carbon emissions have been undertaken primarily to address summertime ozone formation in urban centers. Future efforts to further reduce organic carbon emissions may be driven by programs that address fine particles and visibility . Massachusetts will continue to evaluate methods to reduce the contribution of organic carbon emissions to regional haze ; however , significant visibility improvements will not occur until sulfate - dominated visibility impairment has been red uced. Understanding the transport dy namics and source regions for organic carbon in northeastern Class I areas is likel y to be more complex than for sulfate. This is partly because of the large number and variet y of OC species, the fact that their transp ort characteristics vary widely , and the fact that a givenPage 60

species may

undergo numerous complex chemical reactions in the atmosphere. Thus, the organic carbon contribution to visibility impairment at most Class Isites in the East is likely to include manmade pollution transported from a distance and from nearb y sources, and biogenic emissions, especiall y terpenes, from coniferous forests As shown in Figure 30 , the VOC emissions inventory is dominated by

mobile and area sources. On - road mobile sources of VOCs include exhaust emissions from gasoline passenger vehicles and diesel powered heav y - dut y vehicles, as well as evaporative emissions from transportation fuels. VOC emissions also may

originate from a variet y of area sources (including solvents, architectural coatings, and dry cleaners) and from some point sources (e.g., industrial facilities and petroleum refineries). Biogenic VOCs may

play an important role within the rural settings ty pical of Class Isite s. The oxidation of hydrocarbon molecules containing seven or more carbon atoms is generall y the most significant pathway

for the formation of light - scattering organic aerosol particles 13

. Smaller reactive hy drocarbons that may

contribute significantl y to urban smog (ozone) are less likely to play a role in organic aerosol formation, though it was noted that high ozone levels can have an indirect effect on visibility by promoting the oxidation of other available hy drocarbons, including biogenic emissions (Appendix P ). Inshort, further work is needed to characterize the organic carbon contribution to regional haze in the Northeast and Mid - Atlantic states and to develop emissions inventories that will be of greater value for visi bility planning purposes. **Figure 30**  **: 2002 Volatile Organic Carbon (VOC) Emissions by State**

0% 25% 50% 75% 100%

Co nne ct ic ut De la wa re Di st ri ct o f C ol um bi a Ma in eMa ry la nd Ma ssa chuse tt s Ne w Ham ps hi re Ne w Jersey Ne w York Pe nn syl va nia Rh ode I sl an d Ve rm on t**m i** **l l** **i o** **n t** **/ y** 

0. 0 0. 2 0. 4 0. 6 0. 8 1. 0 1. 2 1. 4 1. 6

AR EA NO NRO AD ON RO AD POIN T Em is si on Bar Graph: Percentage Fractions of the Four Source Categories ( - o - ) Line Graph: Total State Annual Emissions (10 6 tpy )

13 Odum, J.R., Jungkamp, T.P.W., Griffin, R.J., Flagan, R.C., and Seinfeld, J.H. (1997) “The Atmo spheric Aerosol - forming Potential of Whole Gasoline Vapor.” 276: 96 - 99.Page 61

**Oxides of Nitrogen (NO**  **X )**  NO x emissions contribute to visibility impairment in the eastern U.S. by forming light - scattering nitrate particles. Nitrate generally accounts for a substantially smaller fraction of fine particle mass and related light extinction than sul fate and organic carbon at northeastern Class I sites. Notably , nitrate may play a more important role at urban sites and in the wintertime. Inaddition, NO x may have an indirect effect on summertime visibility by virtue of its role in the formation of o zone, which in turn promotes the formation of secondary

organic aerosols (Appendix P ). Figure 31 shows NO x emissions in the MANE - VU region at the state level. Since 1980, nationwide emissions of NO x from all sources have sho wn little change. In fact, emissions increased b y 2 percent between 1989 and 1998 14

. This increase is most likely due to industrial sources and the transportation sector, s ince power plant combustion sources ha d implemented modest emissions reductions dur ing the same time period. Most states in the MANE - VU region experienced declining NO X emissions from 1996 through 2002. Exceptions include Massachusetts, Maryland, New York, and Rhode Island, which show an increase in NO x emissions in 1999 before declini ng in 2002 to levels below 1996 emissions. For Massachusetts , the increase in NO x emissions from 1996 to 1999 was due largel y to increases in emissions from off

- road and stationary

point sources. The subsequent decline in NO x emissions from 1999 to 2002 i s mainly attributable to controls in the o n - road mobile category , including Enhanced Inspection and Maintenance ( I/M ) and California Low Emission Vehicle ( CA - LE V ) programs . There also were significant reductions in the stationary p oint source category , m ainly power plants , that are attributable to NO x RACT.

14 EPA. (2000) National Air Quality and Emission Trends Report, 1998 , EPA 454/R - 00 - 003, available online: http://www.epa.gov/oar/aqtrnd98/ .Page 62 **Figure 31**  **: Trends in Annual Nitrogen Oxide (NO x** **) Emissions by State**

**0.0 0.5**  **1.0 1.5**  **Connecticut Delaware** 

**District of Columbia Maine**  **Maryland Ma**  **ssachusetts Ne**  **w Hampshire**

**New Jersey New York** 

**Pennsylvania**

**Rhode Island Vermont** **m i** **l l** **i o** **n t** **/ y**  **NEI 1996 NEI 1999 V3**  **MA NE-VU 2002 V3** 

Power plants and mobile sources generall y dominate state and national NO x emissions inventories. Nationa lly , power plants account for more than one - quarter of all NO x emissions, amounting to over six million tons. The electric sector plays an even larger role, however, in parts of the industrial Midwest where high NO x emissions have a particularl y significant power plant contribution. By contrast, mobile sources dominate the NO x inventories for more urbanized Mid - Atlantic and New England states to a far greater extent, as shown in Figure 32 . In these states, on - road mobile sources represent the most signif icant NO x source category . Emissions from non - road mobile sources, primarily diesel - fired engines, also represent a substantial fraction of the inventory. While there are fewer uncertainties associated with available NO x estimates than in the case of oth er key haze - related pollutants, including primary fine particle and ammonia emissions, further efforts could improve current inventories in a number of areas (Appendix P ).Page 63 **Figure 32**  **: 2002 Nitrogen O xide (NO**  **x ) Emissions by State** 

0% 25% 50% 75% 100%

Co nne ct icu t De law are Dist ri ct of Col um bia Maine Ma

ryl and Ma ssa chuse tt s Ne w Ham ps hire Ne w Jersey Ne w York Pe nn syl va ni a Rh ode I sla nd Ve rm on t**m i** **l l** **i o** **n t** **/ y** 

0. 0 0. 3 0. 6 0. 9

AR EA NO NROAD ON RO AD POIN T Em is si on Bar Graph: Percentage Fractions of the Four Source Categories ( - o - ) Line Graph: Total State Annual Emissions (10 6 tpy ) **Primary P**

**article Matter (PM**  **10 and PM** 

**2.5 )**  Directl y emitted or “primary” p articles include both fi lterable and condensable particulates. These are distinct from secondary

particles that form in the atmosphere through chemical reactions involving precursor pollutants like SO 2 and NO X . Both primary and secondary

particles can contribute to regional haz e. For regulatory

purposes, a distinction is made between particles with an aerod yn amic diameter less than or equal to 10 micrometers and smaller particles with an aerodyn amic diameter less than or equal to 2.5 micrometers (i.e., primary PM 10 and PM 2.5 , r espectively). Figure 33 an d Figure 34 show PM 10 and PM 2.5 emissions for the MANE - VU states for the ye ars 1996, 1999, and 2002. Most states show a stead y decline in annual PM 10 emissions over this time period, with the exception of Maine. By contrast, em ission trends for primary PM 2.5 are more variable. For Massachusetts, both PM 10 and PM 2.5 emissions increased from 1996 to 1999, then declined to 2002. Similar to trends in NO x emissions, the increase was due largel y to increases in emissions from off - ro ad and stationary

point sources. The subsequent decline in PM emissions from 1999 to 2002 is mainly attributable to controls in the o n - road mobile category , including Enhanced I/M and CA - LEV. There also were significant reductions in the stationary p oint source category , mainl y power plants , that are attributable to NO x RACT.Page 64 **Figure 33**  **: Trends in Primary Coarse Particle (PM 10**  **) Emissions by State**

**0.0 0.1**  **0.2 0.3**  **0.4 0.5**  **0.6 0.7**  **0.8**

Connecticut Delaware

District of Columbia Maine Maryland Massachusetts

New Hampshire New Jersey New York Pennsylvania

Rhode Island Vermont**m i** **l l** **i o** **n t** **/ y**  **NEI 1996 NEI 1999 V3**  **MA NE-VU 2002 V3** 

**Figure 34**  **: Trends in Primary Fine Particle (PM 2.5**  **) Emissi ons by State** 

**0.0 0.1**  **0.2 0.3**  **Connecticut Delaware** 

**District of Columbia Ma**  **ine Maryland** 

**Massachusetts**

**New Hampshire**

**Ne w Jersey**  **New York**

**Pennsylvania**

**Rhode Island Vermont** **m i** **l l** **i o** **n t** **/ y**  **NEI 1996 NEI 1999 V3**  **MA NE-VU 2002 V3** Page 65

Crustal sources are significant contributors of primary PM emissions. This category includes fugitive dust emissions from construction activities, paved and unpaved roads, and agricultural tilling. Ty pically , monitors estimate PM 10 emissi ons from these ty pes of sources by

measuring the horizontal flux of particulate mass at a fixed downwind sampling location within perhaps 10 meters of a road or field. Comparisons between estimated emission rates for fine particles using these t yp es of me asurement techniques and observed concentrations of crustal matter in the ambient air at downwind receptor sites suggest that phy sical or chemical processes remove a significant fraction of crustal material relativel y quickly. As a result, it rarely entra ins into lay ers of the atmosphere where it can transport to downwind receptor locations. Because of this discrepancy between estimated emissions and observed ambient concentrations, modelers ty pically reduce estimates of total PM 2.5 emissions from all cru stal sources by

appl yi ng a factor of 0.15 to 0.25 to the total PM 2.5 emissions before including it in modeling analy ses. From a regional haze perspective, crustal material generall y does not play a major role. On the 20 percent best - visibility

day s durin g the baseline period (2000 - 2004), it accounted for six to eleven percent of particle - related light extinction at MANE - VU Class 1 sites. On the 20 percent worst - visibility day s, however, crustal material generall y pla ys a much smaller role relative to oth er haze - forming pollutants, ranging from two to three percent. Moreover, the crustal fraction includes material of natural origin (such as soil or sea salt) that is not targeted under the Regional Haze Rule. Of course, the crustal fraction can be influen ced by certain human activities, such as construction, agricultural practices, and road maintenance (including wintertime salting) , and thus to the extent that these ty pes of activities are found to affect visibility

at northeastern Class I sites, control measures targeted at crustal material may prove beneficial. Experience from the western United States, where the crustal component has generally play ed a more significant role in driving overall particulate levels, may be helpful to the extent that it i s relevant in the eastern context. Inaddition, a few areas in the Northeast, such as New Haven, Connecticut and Presque Isle, Maine, have some experience with the control of dust and road - salt as a result of regulatory obligations stemming from their pas t non - attainment status with respect to the National Ambient Air Quality Standard (NAAQS ) for PM 10 . Current emissions inventories for the entire MANE - VU area indicate residential wood combustion represents 25 percent of primary fine particulate emissions in the region. This implies that rural sources can play an important role in addition to the contribution from the region’s many highl y populated urban areas. An important consideration in this regard is that residential wood combustion occurs primarily in the winter months, while managed burning activities occur largel y in other seasons. Managed burning includes agricultural and prescribed fires, as well as use of naturall y i gnited fires to achieve resource benefits and slash burning of logging debris ( which is prohibited in Massachusetts). Particulate emissions from managed burns can be limited b y confining burning activities to times when favorable meteorological conditions can efficientl y disperse the emissions. Wood smoke impacting MANE - VU Class I areas is more local in origin than sources of SO 2 , except for major transport events. Figure 35 below is from the MANE - VU Contribution Assessment (Appendix A; see Appendix B) and represents the results of source apportionment and trajectory anal ys es. It illustrates that the impacts of wood smoke on MANE - VU Class I areas are more likely due to emissions from within MANE - VU and Canada. The green - highlighted portion of the map depicts the wood smoke source region in the Northeast s tates. The stars on the map represent air monitor sites (including those atPage 66

several Class I areas) whose data sets were determined to be useful to the modeling anal ys is used to attribute wood smoke impacts. The MANE - VU Technical Support Document on Agric ultural and Forestry Smoke Management in the MANE- VU Region (Appendix Q ) concluded that fire from land management activities (agricultural, prescribed, and slash burning, and managed wildfires) was not a major c ontributor to regional haze in MANE - VU Class I areas, and that the majority of emissions from fires were from residential wood combustion. Although data are currently lacking, Massachusetts is concerned about the growing use of residential wood stoves by homeowners seeking alternatives to petroleum - based fuels for home heating. Recent, localized problems with smoke emissions from outdoor wood boilers (wood - fired h ydronic heaters) led MassDEP to promulgate regulations that tighten requirements on the sale , installation, and use of these devices. MassDEP will keep close watch on smoke emissions from the residential sector to determine whether additional control measures on this source category may be necessary

in the next few y ears. **Figure 35**  **: Wood Smoke Source Regional Aggregations**

**NE: ACAD, PMRC, LYBR MA: WASH, SHEN, JARI**  **SE: GRSM, MACA**Page 67

Figure 36 and Figure 37 show that area and mobile sources dominate prima ry PM emissions. (The NEI inventory categorizes residential wood combustion and some other combustion sources as area sources.) The relative contribution of point sources is larger in the primary PM 2.5 inventory

than in the primary PM 10 inventory

since the crustal component (which consists mainly of larger or “coarse - mode” particles) contributes mostly to overall PM 10 levels. At the same time, pollution control equipment commonly

installed at large point sources is usually more efficient at capturing coarse - mode particles.

**Figure 36**  **: 2002 Primary PM 10**  **Emissions by State**

0% 20% 40% 60% 80% 100%

Co nne ct ic ut De law are Di st ri ct o f C ol umbi a Mai ne Maryl and Ma ssa ch use tt s Ne w Hamp shire Ne w Jersey Ne w Yo rk Pen ns ylv an ia Rh ode I sl an d Ve rmo nt**m i** **l l** **i o** **n t** **/ y** 

0. 0 0. 1 0. 2 0. 3 0. 4 0. 5

AR EA NO NRO AD ON ROAD PO IN T Em is si on Bar Graph: Percentage Fractions of the Four Source Categories ( - o - ) Line Graph: Total State Annual Emissions (10 6 tpy )Page 68 **Figure 37**  **: 2002 Primary PM 2.5**  **Emissions by State**

0% 25% 50% 75% 100%

Co nne ct ic ut De law ar e Di st ri ct o f C ol umbi a Ma in e Maryl and Massa chu se tt s Ne w Hamp shire Ne w Jersey Ne w York Pe nn sylva nia Rh ode I sl an d Ve rmo nt**m i** **l l** **i o** **n t** **/ y** 

0. 00 0. 05 0. 10 0. 15 0. 20

AR EA NO NROAD ON ROAD POIN T Em is si on Bar Graph: Percentage Fractions of the Four Source Categories ( - o - ) Line Graph: Total State Annual Emissions (10 6 tpy ) **A mmonia Emissions (NH**  **3 )**  Because ammonium sulfate [ (NH 3 ) 2 SO 4 ] and ammonium nitrate (NH 3 NO 3 ) are significant contributors to atmospheric light scattering and fine particle mass, knowledge of ammonia emission sources is important to the development of effective regional haze reduction strategies. According to 1998 estimates, livestock agriculture and fertilizer use accounted for approximately 86 percent of all ammonia emissions to the atmosphere 15

. However, better ammonia inventory data is needed for the photochemical models used to simulate fine particle formation and tr ansport in the eastern United States. States were not required to include ammonia in their air emissions data collection efforts until fairl y recentl y (see Consolidated Emissions Reporting Rule, 67 FR 39602; 6/10/2002), and so it will take time for the qu alit y of ammonia inventory data to match the quality of the data for the other criteria pollutants. Ammonium ion (formed from ammonia emissions to the atmosphere) is an important constituent of airborne particulate matter, ty picall y accounting for 10

–20 percent of total fine particle mass. Reductions in ammonium ion concentrations can be extremely beneficial because a more - than proportional reduction in fine particle mass can result. Ansari and Pandis 16 showed that a 1  g/m 3 reduction in ammonium ion cou ld result in up to a 4  g/m 3 reduction in fine particulate matter. Decision

15 EPA 454/R - 00 - 002 . (2000) National Air Pollutant Trends, 1900

– 1998 . Available online: http://www.epa.gov/ttn/chief/trends/trends98/trends98.pdf . 16 Ansari, A. S., and Pandis, S.N. (1998) “Response of inorganic PM to precursor concentrations,” Environ Sci Technol , 32: 2706 - 2714.Page 69

makers, however, must weigh the benefits of ammonia reduction against the significant role it plays in neutralizing acidic aerosol. 17 To address the need for improved ammonia inve ntories, MARAMA, NESCAUM, and EPA funded researchers at Carnegie Mellon University (CMU) in Pittsburgh to develop a regional ammonia inventory . 18 This study

focused on three issues with respect to current emissions estimates: (1) a wide range of ammonia em ission factor values, (2) inadequate temporal and spatial resolution of ammonia emissions estimates, and (3) a lack of standardized ammonia source categories. The CMU project established an inventory framework with source categories, emissions factors, an d activity data that are readily

accessible to the user. With this framework, users can obtain data in a variet y of formats 19 and can make updates easily , allowing additional ammonia sources to be added or emissions factors to be replaced as better information becomes available. 10 Figure 38 shows that estimated ammonia emissions were fairl y stable in the 1996 NEI, 1999 NEI, and 2002 Version 3 MANE - VU inventories for MANE - VU states, with some slight increases observed for most states in MANE - VU. This apparent increase in emissions from 1999 to 2002 is due to a difference in the models used to generate the emissions data . 20 1999 emissions were generated using an EPA model, whereas the 2002 emissions were generated using the CMU ammonia model described above . The CMU ammonia model incorporates categories such as humans, house pets, wild animals, fertilizers, soils, and miscellaneous animals that are not incorporated into the EPA model. Area and on - road mobile sources dominate ammonia emissions ( Figure 39) . Specificall y, emissions from agricultural sources and livestock production account for the largest share of estimated ammonia emissions in the MANE - VU region, except in the District of Columbia. The two remaining sources with a significant emissions contribution are wastewater treatment sy stems and gasoline exhaust from highway vehicles.

17 SO 2 reacts in the atmosphere to form sulfuric acid (H 2 SO 4 ). Ammonia can partially or fully neutralize this strong acid to form ammonium bisulfate or ammonium sulfate. If planners focus future control strategies on ammonia and do not achieve corresponding SO 2 reductions, fine particles formed in the atmosphere will be substantially more acidic than those presently observed. 18 Davidson, C., Strade r, R., Pandis, S., and Robinson, A. Preliminary Proposal to MARAMA and NESCAUM: Development of an Ammonia Emissions Inventory for the Mid - Atlantic States and New England . Carnegie Mellon University, Pittsburgh, PA. January, 1999. 19 For example, the user w ill have the flexibility to choose the temporal resolution of the output emissions data or to spatially attribute emissions based on land - use data. 20 The NEI 1999 V.3 NH3 emissions were developed by EPA for a limited amount of livestock. ( ftp://ftp.epa.gov/EmisInventory/finalnei99ver3/criteria/documentation/area/area_99nei_finalv3_0204.pdf ) In contrast, the MANE - VU 2002 V.3 NH3 emissions wer e developed by the Carnegie Mellon University (CMU) Ammonia Model that is more comprehensive than EPA's 1999 method.Page 70 **Figure 38**  **: Trends in Ammonia Emissions by State**

**0.00 0.05**  **0.10 0.15**  **0.20 Connecticut**  **Delaware**

**District of Columbia Maine**  **Maryland Ma**  **ssachusetts New Hampshire** 

**Ne w Jersey**  **New York**

**Pennsylvania**

**Rhode Island Vermont** **m i** **l l** **i o** **n t** **/ y**  **NEI 1996 NEI 1999 V3**  **MA NE-VU 2002 V3** 

**Figure 39**  **: 2002 NH 3**  **Emissions by State**

0% 25% 50% 75% 100%

Co nnec ti cu t De la war e Di st ri ct o f Col um bia Ma in e Mary la nd Mas sac hus et ts Ne w Ha mps hi re Ne w Jer se y Ne w Yo rk Penns yl va ni a Rh ode Is la nd Vermon t**m i** **l l** **i o** **n t** **/ y** 

0. 00 0. 06 0. 12

AR EA NO NROAD ON RO AD POIN T Em is si on Bar Graph: Percentage Fr actions of the Four Source Categories ( - o - ) Line Graph: Total State Annual Emissions (10 6 tpy )Page 71 

# 8. **BEST AVAILABLE RETRO FIT TECHNOLOGY**  In the Regional Haze Rule, EPA included provisions designed specifically to reduce emissions of visibility- impairing po llutants from large sources that, because of their age, were exempted from new source performance standards (NSPS) established under the Clean Air Act. These provisions, known as Best Available Retrofit Technology , or BART, are located at 40 CFR 51.308(e) . Massachusetts is required by 40 CFR 51.308(e) to submit an implementation plan containing emission limits representing BART and schedules for compliance with BART for each eligible source that may reasonabl y be anticipated to cause or contribute to any impairment of visibility in an y mandatory Class I Federal area. This requirement applies unless Massachusetts demonstrates that an emission trading program or other alternative will achieve greater reasonable progress toward natural visibility conditions. BART requirements apply to 26 specified major point source categories, including power plants, industrial boilers, paper and pulp plants, cement kilns, and other large stationary sources. 21 To be considered BART - eligible, emission units from these spec ified categories must have commenced operation or come into existence in the 15 - ye ar period prior to August 7, 1977 (the date of passage of the 1977 Clean Air Act Amendments, which first required new source performance standards). In addition, the cumulat ive “potential to emit” levels of all BART - eligible units at a facility must be at least 250 tons per year of an y visibility - impairing pollutant. 22 Visibility- impairing pollutants include , but are not limited to, sulfur dioxide (SO 2 ), nitrogen oxides (NO x ) , particulate matter less th an or equal to 10 mic rons in diameter (PM 10 ), volatile organic chemicals (VOCs), and ammonia. **8.2.** 

### BART Overview The BART program is intended to reduce visibility - impairing emissions of the pollutants from large stationary sources th at were not required to meet certain emission control requirements at the time the CAA was amended in 1977. Under Section 169A, States must consider five statutory factors when determining BART control requirements for BART - eligible units:

 Cost of co mpli ance ,  Energy

and non - air quality

environmental impacts of compliance ,  Existing pollution control technology in use at the source,  Remaining useful life of the source, and  Degree of improvement in v isibility reasonabl y anticipat ed from use of BART . In June 2005, EPA adopted the final BART rule. 23 Under the final rule, the BART program requires states to develop an inventory of sources within each state that could be subject to control. Specifically , the rule:

21 A full list of the 26 source categories can be found in 40 CFR Part 51 Appendix Y: Guidelines for BART Determinations Under the Regional Haze Rule. 22 “Source” can refer to an emission unit or to a facility and is used in the Clean Air Act and in EPA’s Guidance on Regional Haze. 23 40 CFR Part 51 Appendix Y: Guidelines for BART Determinations Under the Regional Haze Rule.Page 72

 Outlined methods to determine if a source is “r easonably anticipated to cause or contribute to haze;”  Defined the methodology for conducting a BART control anal ys is;  Provided presumptive control limits for electricity generating units (EGUs) larger than 750 Megawatts (i.e. “presumptive BART”);  Provide d a justification for the use of the Clean Air Interstate Rule (CAIR) as BART for CAIR state EGUs. 24 Be yond the specific elements listed above, EPA provided the states with a great degree of flexibility in how they choose to implement the BART program. A s set forth in 40 CFR 51.308(e)(2), states may choose to implement or require participation by BART sources in an emissions trading program or an alternative measure that will achieve greater reasonable progress than BART implementation at all sources subj ect to BART. In addition, if such alternative measure has been designed primaril y to meet a Federal or State requirement other than BART, a more simplified approach can be used to demonstrate that the alternative measure will make greater reasonable progr ess than implementing BART alone. **8.3.** 

### BART **- Eligible Sources in Massachusetts**  Massachusetts identified its BART - eligible sources using the methodology in the Guidelines for Best Available Retrofit Technology (BART) Determinations under the Regional Haze Rule, 4 0 CFR Part 51, Appendix Y. Seventeen sources were found to be eligible for BART and are listed in Table 10 . These include nine electric generating units (EGUs), four industrial/commercial/ institutional (I CI ) boilers/chemical processing plants, one munici pal waste combustor (MWC), and three petroleum storage facilities.

24 On August 8, 201 1, EPA promulgated the Cross - State Air Pollution Rule to replace CAIR.Page 73 **Table 10**  **: BART -**  **Eligible Facilities in Massachusetts**

**I.D. Source**  **Units Ty**  **pe** 1190012 Boston Generating - New Boston Unit 1 EGU 1190128 Boston Generating – Mystic U nit 7 EGU 1190491 Braintree Electric Unit 3 EGU 1200061 Dominion - Brayton Point Units 1, 2, 3, and 4 EGU 1190194 Dominion - Salem Harbor Unit 4 EGU 1190092 Harvard University - Blackstone Units 11 and 12 EGU 1200054 Mirant - Canal Station Units 1 and 2 EGU 1190093 Mirant - Kendall LLC Units 1 and 2 EGU 1200067 Taunton Municipal Light Plant

(TMLP) - Clear y Flood Units 8 and 9 EGU 1190175 Eastman Gelatin Units 1, 2, 3 and 4 ICI Boilers/Chemical Processing 1190138 General Electric Aircraft - Lynn Uni t 3 ICI Boilers/Chemical Processing 420086 Solutia Units 9 and 10 ICI Boilers/Chemical Processing 1190507 Trigen - Kneeland St Unit 3 ICI Boilers/Chemical Processing 1197654 Wh eelabrator – Saugus Units 1 and 2 Municipal Incinerator 1190484 Exxon Mobil – Everett All Process Units Petroleum Storage 1190487 Global Petroleum – Revere All Process Units Petroleum Storage 1190483 Gulf Oil – Chelsea All Process Units Petroleum Storage **8.4.** 

### Determination of which BART **- eligible sources are subject to BART**  Massachus etts is a member of the Mid - Atlantic/Northeast Visibility Union (MANE - VU). As part of the consultation process among MANE - VU states a policy decision was made by

the MANE - VU Board in June 2004 that all BART - eligible sources are subject to BART. As such, no BART exemptions will be given, meaning all BART - eligible sources are included in the BART review process. **8.5.** 

### Pollutants Covered by BART As allowed under BART, Massachusetts has determined that SO 2 , NO x and PM are the contributing visibility- impairing pollutants most appropriate to target under its BART approach . Massachusetts did not include either VOCs or ammonia b ecause of the lack of tools to estimate emissions and subsequently to model VOC s and ammonia, and because Massachusetts is aggressivel y address ing VOCs through its ozone SI Ps . This conclusion is consistent with discussions in the MANE - VU consultation process. Therefore, Massachusetts did not further consider BART for the three petroleum storage facilities identified in Table 10 above.Page 74

**8.6.** 

### Modeling **of BART Visibility Impacts** MANE - VU conducted modeling anal ys es of BART - eligible sources using CAL PUFF in order to provide a regionally - consistent foundation for assessing the degree of visibility improvement which could result from installation of BART controls ( s ee Attachment R). MANE - VU model ed BART visibility impacts us ing 2002 emissions of SO 2 , NO x , and PM 10 from all BART - eligible units in the region, including all BART - eligible sources in Massachusetts. 25 The NWS and MM5 meteorological platforms were both used to model each BART - eligible unit’s maximum 24 - hr, 8 th highest 24 - hr, and annual average impact at the Class Iarea most heavily impacted, as well as the total impact from all BART sources on each Class I area. These visibility

impacts were model ed relative to 20 percent best day s, 20 percent worst day s, and annual average natural background conditions. For the purposes of this anal ys is, MANE - VU examined the 24 - hr maximum visibility impact relative to the 20 percent best day s. In accordance with EPA guidance, which allows the use of either estimates of the 20 percent best or annual average natural background visibility conditions as the basis for calculating the deciview difference that individual sources would contribute for BART modeling purpos es , MANE - VU opted to use the more conservative best conditions estimates approach because it is more protective to the region. In addition to modeling the maximum potential improvement from BART, MANE - VU also determined that 98 percent of the cumulative v isibility impact from all MANE - VU BART eligible sources corresponds to a maximum 24 - hr impact of 0 .22 dv from the NWS - driven data and 0.29 dv from the MM5 data. As a result, MANE - VU concluded that, on the average, a range of 0.2 to 0.3 dv would represent a significant impact at MANE - VU Class Iareas, and sources having less than 0.1 dv impact are unlikel y to warrant additional controls under BART. 26 **8.7.** 

### Visibility Impacts of Massachusetts BART **- Eligible Sources**  The results of CALPUFF modeling using MM5 and NWS m eteorological platforms for Massachusetts BART - eligible facilities (excluding VOC sources) are found i n Table 11 and Table 12 , respectivel y. These results display

facility - wide impacts on the worst day at the site experiencing the largest impact relative to the 20 percent best natural background conditions.

25 Emissions information was gathered from the MANE - VU 2002 Version 2 (Base A) emissions inventory. Since then, the MANE - VU 2002 Version 3 (Base B) emissions inventory has been develope d which includes several changes made by the OTC modeling committee. 26 As an additional demonstration that sources whose impacts were below the 0.1 dv level were too small to warrant BART controls, the entire MANE - VU population of these units was modeled t ogether to examine their cumulative impacts at each Class I site. The results of this modeling demonstrated that the maximum 24 - hour impact at any Class I area of all modeled sources with individual impacts below 0.1 dv w as only a 0.35 dv change relative to the estimated best days natural conditions at Acadia National Park. This value is well below the 0.5 dv impact recommended by EPA for exemption modeling and used by most other RPOs.Page 75 **Table 11**  **: CALPUFF Visibility Modeling Results using MM5 Platform**

**MM5 -**  **Impact on Worst Day Relative to 20 Percent Best Natural**

**Conditions (delta deciview; ddv)** Facility Class I Site Total SO4 NO3 PM10 Dominion - Brayton Point Acadia 11.152 9.740 3.354 0.031 Mirant - Canal Station Acadia 6.643 6.018 1.310 0.000 My stic Station Moosehorn W ilderness 1.023 0.943 0.117 0.002 Dominion - Salem Harbor Moosehorn W ilderness 0.982 0.8 86 0.151 0.001 Trigen - Kneeland Station Acadia 0.146 0.023 0.127 0.001 Wh eelabrator - Saugus Acadia 0.250 0.026 0.232 0.000 General Electric Aircraft - Lynn Acadia 0.239 0.148 0.092 0.000 TMLP - Cleary Flood Acadia 0.103 0.028 0.076 0.003 Mirant - Kend all Acadia 0.095 0.015 0.082 0.000 Harvard University - Blackstone Acadia 0.060 0.039 0.027 0.001 New Boston Presidential Range 0.044 0.000 0.044 0.000 Braintree Electric Acadia 0.031 0.004 0.029 0.000 Eastman Gelatin Acadia 0.029 0.002 0.026 0.000 So lutia Presidential Range 0.003 0.000 0.003 0.000

**Table 12**  **: CALPUFF Visibility Modeling Results using NWS Platform**

**NWS -**  **Impact on Worst Day Relative to 20 Percent Best Natural Conditions (ddv)**  Facility Class I Site Total SO4 NO3 PM10 Dominion - Brayton Point Moosehorn W ilderness 7.200 6.206 1.754 0.026 Mirant - Canal Station Acadia 3.485 3.251 0.427 0.000 My stic Station Moosehorn W ilderness 0.660 0.556 0.108 0.003 Dominion - Salem Harbor Acadia 0.545 0.488 0.108 0.001 Tri gen - Kneeland Station Ly e Brook Wi lderness 0.097 0.005 0.092 0.002 Wh eelabrator - Saugus Ly e Brook Wi lderness 0.183 0.004 0.179 0.000 General Electric Aircraft - Lynn Acadia 0.159 0.118 0.085 0.000 TMLP – Clear y Flood Moosehorn W ilderness 0.061 0.022 0.037 0.002 Mirant - Kendall Ly e Brook Wi lderness 0.059 0.003 0.057 0.000 Harvard University - B lackstone Acadia 0.034 0.023 0.010 0.001 New Boston Ly e Brook Wi lderness 0.028 0.000 0.027 0.001 Eastman Gelatin Acadia 0.025 0.002 0.024 0.000 Braint ree Electric Moosehorn W ilderness 0.014 0.002 0.012 0.000 Solutia Acadia 0.003 0.000 0.003 0.000 **8.8.** 

### Overview of Massachusetts BART **- Eligible Sources**  There are three categories of BART - eligible sources in Massachusetts that emit SO 2 , NO x , and PM : a “cap out” source, sources with de minimis visibility impacts, and sources that contribute significantly to visibility impa irment. **“Cap Out” Source**  BART eligibility

is limited to sources in one of 26 source categories that had units installed and operating between 1962 and 1977 with the current cumulative potential to emit more than 250 tons perPage 76

ye ar of a visibility

impairing pollutant. EPA guidance allows BART - eligible sources to adopt a federally enforceable permit limit to permanently limit emissions of visibil ity impairing pollutants to less than 250 tons per ye ar, thereb y “capping - out” of BART. General Electric

– Lynn has actual emissions of visibility

impairing pollutants of fewer than 250 tons per y ear and was BART - eligible only because its potential emiss ions exceed the statutory BART threshold of 250 tons per y ear. MassDEP has issued a permit to General Electric

– Lyn n establishing cap s of less than 250 tpy for NO x and SO 2 emissions from Unit 3 in order to cap - out of BART requirements (Appendix BB) ; PM 10 potential emissions alread y are less than 250 tpy . Therefore, General Electric

– Lyn n Unit 3 is no longer BART eligible . **S ources with De Minimis Impacts on Visibility**  According to the 2005 Regional Haze Rule, once a state has compiled its list of BART - eligible sources, it needs to determine whether to make BART determinations for all of the sources or to consider exempting some of them from BART because they may not reasonabl y be anticipated to cause or contribute to an y visibility impairment in a Class I area. MANE - VU has identified a set of sources whose potential “degree of visibility improvement” is so small (<0.1 ddv) that no reasonable weighting could justify

additional controls under BART. (Note that the cumulative impact of all of the s e MANE VU sources combined is lower than EPA’s guidance , which states that the threshold for determining whether a source “contributes” to visibility impairment should be ≤0.5 dv.) A description of this modeling can be found in Appendix R , Section 4.1, and the mode ling results can be found in Appendices R - 1 and R - 2 . MANE - VU has termed these sources to have a “de minimis visibility impact.” For Massachusetts, sources meeting this criterion are listed in Table 13 . Trigen

– Kneeland has been added to this list, desp ite its modeled impact of 0.146 ddv (0.127 ddv from NO 3 ) using the MM5 modeling platform, due to two significant errors in the 2002 input data used by MANE - VU to screen facilities for their impact on visibility . First, Units 1 - 4 were included in the model ing when onl y Unit 3 is BART - eligible. Second, the 2002 modeled NO x emissions from Unit 3 were 396 tons, rather than the actual 96 tons of NO x emissions. Massachusetts believes that modeling using the corrected 2002 NO x emissions from Trigen - Kneeland w ould indicate a total visibility impact of <0.1 ddv; therefore Trigen

– Kneeland is being considered a source with de minimis impact on visibility .

**Table 13**  **: Massachusetts Sources with De Minimis Visibility Impact I.D.**  **Source Ty**  **pe** 1190491 Braintree Electric EGU 1190092 Harvard University - Blackstone EGU 1190093 Mirant - Kendall LLC EGU 1190012 New Boston EGU 1190175 Eastman Gelatin ICI Boilers/Chemical Process 420086 Solutia ICI Boilers/Chemical Process 1190507 Trigen - Kn eeland ICI Boilers MassDEP has determined that the visibility improvement that would be achieved by the installation of BART controls at these sources does not justify the installation of such controls.Page 77

**Sources that Contribute to Visibility Impairment** Massachusetts BART - subject sources with greater than a de minimis impact on visibility include three coal - fired EGUs (Bray

ton Point Units 1 - 3), seven oil - fired EGUs (Bray ton Point Unit 4, Canal Station Units 1 - 2, My stic Station Unit 7, Salem Harbor Unit 4, and Cleary Flood Units 8 and 9) and two MWC units (Wheelabrator

– Saugus). An overview of these sources is contained in Table 14 . It should be noted that all of these sources are subject to MassDEP pollution control requirements that limit SO 2 and NO x . All of the these sources , except Cleary Flood and Wheelabrator - Saugus, are subject to 310 CMR 7.29, Emissions Standards for Power Plants, which MassDEP adopted in 2001 to control the emissions of NO x , SO 2 , mercury , and carbon dioxide from the state’s lar gest EGUs. In addition, these sources, as well as Cleary Flood, are subject to MassDEP’s NO x RACT rules and ozone season MassCAI R control program, 310 CMR 7.32. 27 Wheelabrat o r - Saugus is subject to 310 CMR 7.08 (2) : Municipal Waste Combustors and 310 CMR 7. 19(9) (NO x RACT for Municipal Waste Combustor Units) . The Regional Haze Rule allows Massachusetts to either make individual BART determinations or to implement an alternative that will achieve greater reasonable progress toward natural visibility conditi ons. Massachusetts has developed a BART determination for Wheelabrator that will be implemented through a permit revision and will address the remaining BART sources through BART determinations or under an alternative to BART program .

**Table 14**  **: Overview of BART -**  **Eligible EGUs & MWC s**  **Source Ty**  **pe Source**  **Unit Subject to**  **Presumptive BA**  **RT? Primary** 

**Fuel Secondary** 

**Fuel(s) Unit Type**  **Built Year**  EGU Brayton Point 1 ye s Coal (1.5%S) Natural Gas,

Residual Oil Tangentially - fired 1963 EGU Brayton Point 2 ye s Coal (1.5%S) Natural Gas,

Residual Oil Tangentially - fired 1964 EGU Brayton Point 3 ye s Coal (1.5%S) Natural Gas,

Residual Oil Dry

bottom wall - fired boiler 1969 EGU Brayton Point 4 ye s Residual Oil Natural Gas Dry bottom wall - fired boiler 1974 EGU Canal Station 1 ye s Residual Oil Diesel Oil Dry bottom wall - fired boiler 1970 EGU Canal Station 2 ye s Residual Oil Diesel Oil,

Natural Gas Dry

bottom wall - fired boiler 1976 EGU My stic

Station 7 ye s Residual Oil Natural Gas Tangentially - fi red 1974 EGU Salem

Harbor 4 ye s Residual Oil Dry bottom wall - fired boiler 1972 EGU Clear y Flood 8 no Residual Oil Diesel Oil Dry bottom wall - fired boiler 1966

27 MassCAIR cannot be implemented beginning with the 2012 ozone season because Massachusetts was not included in EPA’s Cross - State Air Pollution Rule. MassDEP is developing a replacement to MassCAIR that will continue to limit ozone season NO x emissions.Page 78

EGU Clear y Flood 9 no Natural Gas Diesel Oil,

Residual Oil Other boiler 1976 MW C Wh eel abrator

- Saugus 1 no Municipal Solid Wa ste Mass burn waterwall boiler 1975 MW C Wh eelabrator

- Saugus 2 no Municipal Solid Wa ste Mass burn waterwall boiler 1975 **8.9.** 

### BART Determination for **Wheelabrator -**  **Saugus** Massachusetts has one BART - eligible incinerator, Wheelabrator

– Saugus, which contains two mass burn incinerators with water wall boilers, each rated at 325 MMBtu/hr heat input. Each boiler can produce up to 195,000 lbs/hr of steam at 650 psi and 850o F. Both incinerator units are BART - eligible , with reported combined 2002 emissions of 84 tons of SO 2 and 721 tons of NO x 28 Wheelabrator

– Saugus is subject to MassDEP’s 1995 NO x Reasonably Available Control Technology (RACT) regulation, 310 CMR 7.19(9). Wheelabrator

– Saugus also is subject to more strin gent NO x emissions limit ation s in MassDEP’s Municipal Waste Combus tor regulation, 310 CMR.7.08(2), which was promulgated in 1998 (and amended in 2001) to implement EPA’s 1995 Emissions Guidelines for existing large (greater than 250 tons) Municipal Waste C ombustors pursuant to Sections 111(d) and 129 of the federal Clean Air Act. 29 Section 129 requires that these guidelines must be based on Maximum Achievable Control Technology (MACT). In 2006, EPA revised its Emissions Guidelines for large Municipal Waste Combustors , lowering the PM emission guidelines (as well as for other non - BART relevant pollutants), but leaving the SO 2 and NO x emissions guidelines unchanged. In 201 2 , MassDEP plans to revise 310 CMR 7.08(2) to adopt the lowered 2006 Emissions Guideli nes . In addition, MassDEP has committed in its 2008 Ozone SIP to conduct additional anal ysis as to whether existing NO x controls still constitute RACT, and will consider including more stringent NO x limits in 310 CMR 7.19 when it proposes revisions to 31 0 CMR 7.08(2) in 2012 . Wheelabrator

– Saugus will be required to comply with an y more stringent emissions limits included in 310 CMR 7.08(2) and 310 CMR 7.19. **NO x**  Wheelabrator has NO x control equipment for both units that includes low - NO x burners and S e lective N on - Catal yt ic R eduction (SNCR) . Wheelabrator’s permitted NO x emission limit under 310 CMR 7.08(2)(f)3 is 205 ppm (by volume at 7 percent oxygen dry basis , 24 - hr daily

arithmetic average). Compliance is determined by continuous emissions monitors (CEMs). MassDEP’s regulatory limit is consistent with EPA’s Emissions Guidelines (both 1995 and 2006) . However, MassDEP believes that the capabilities of current NO x control technologies can achieve emissions lower than EPA’s MACT . At MassDEP’s reques t , Wheelabrator performed furnace gas temperature profiling and conducted SNCR optimization testing to determine the capability of further reducing NO x emissions while minimizing ammonia slip (see Appendix Z) . T he optimization test results indicate that a reduced NO x emissions target of 185 ppm (dry , 7% O 2 ) at current boiler operating loads of approximately 150,000 lbs/hr could be achieved with the existing SNCR sy stem. Based on MassDEP’s review of Wheelabrator

– Saugus’ existing control technologies, Mas sDEP has determined that the NO x emissions rate target of 185 ppm (30 - day average) for each of Wheelabrator’s units represents BART.

28 No data w as reported for PM emissions. 29 EPA recalculated and changed the emissions limits for some of the pollutants in the Emissions Guidelines in a direct final rule in 1997.Page 79

As described in Tables 11 and 12, Wheelabrator

– Saugus’ visibility impacts on Class Iareas based on 2002 emissions was 0.232 ddv and 0.179 ddv, depending on the modeling platform, which are close to MANE - VU’s de minimis level (0.1 ddv) and are well below EPA’s threshold guidance of 0.5 ddv for determining whether a source “contributes” to visibility impairment. Therefore , n o detailed visibility modeling was performed to determine the benefit of achieving the lower NO x emission rate , although MassDEP expects a modest visibility improvement to result from a lower NO x emission rate. Additional technologies and costs wer e not evaluated because MassDEP believes that low - NO x burners and SNCR are state of the art for municipal waste combustors , and through optimization can achieve a NO x emissions limit lower than the current federal MACT limit. MassDEP intends to propose a permit for Wheelabrator with the NOx limit in February 2012 and finalize the permit for incorporation into this SI P in June 2012 . **SO 2**  Wheelabrator’s existing control technology for SO 2 emissions includes a spray dry absorber (SDA) with lime slurry

inj ection. Wheelabrator’s permitted SO 2 emission limit under 310 CMR 7.08(2)(f)2 is 29 ppm (by volume at 7 percent oxygen dry basis) or 75 percent reduction by weight from uncontrolled SO 2 levels. Compliance is based on a 24 - hour geometric mean. MassDEP’s regulatory limit is consistent with EPA’s Emissions Guidelines (both 1995 and 2006). CAL PUFF modeling suggests that visibility impacts from 2002 SO 2 emissions from Wheelabrator - Saugus are below 0.1 ddv on the worst day at an y Class Iarea (see Tables 11 and 12 ). MassDEP has determined that further controls for SO 2 are not warranted given the additional cost required to install supplementary

SO 2 controls because Wheelabrator alread y has control equipment equivalent to MACT and the degree of visibility improvement that could be achieved (<0.1 ddv) is de minimis. **PM** Each of Wheelabrator’s units are equipped with 10 - module fabric filters (baghouses) and are subject to 310 CMR 7.08 (2)(f)2 limits for PM of 27 mg/dscm or less at 7 percent oxygen (dry basis ). This emissions limit is consistent with EPA’s 1995 Emissions Guidelines for MWCs. In 2006, EPA lowered the Emissions Guideline for PM to 25 mg/dscm. MassDEP intends to propose to adopt this lower PM emissions limit in revisions to 310 CMR 7.08(2) planned for 201 2 and believes this MACT limit represents BART . Once finalized, Wheelabrator

– Saugus will be required to comply with the lower PM emissions rate. MassDEP has determined that a PM emissions limit lower than 25 mg/dscm is not warranted given th e additional cost required to install supplementary PM controls because Wheelabrator already has control equipment equivalent to MACT and the degree of visibility improvement that could be achieved is de minimis. **Energy and Non -**  **air Quality Impacts** There are no significant energy and non - air qualit y impacts associated with the proposed BART for Wheelabrator - Saugus. One environmental benefit of a lower NO x emissions limit , in addition toPage 80

improved visibility , is the impact on acid deposition in Massachusetts and Northern New England. Reductions in ambient concentrations of NO x will reduce acid deposition as well as excess nitrogen deposition, thereb y reducing the acidification of lakes, streams and soils and material damage to buildings, and the eutrophication of inland and coastal waters. **Remaining Useful Life** As a member of MANE - VU, Massachusetts has determined that a BART - eligible source that is found to have reasonable control options available to it should either control emissions from that BART - elig ible source prior to July

1, 2013 , or accept a federally enforceable permit limitation or retirement date prior to adoption of this SI P. **Schedule for BART determination and Federal Enforceability** 40 CFR 51.308(e)(1)(iv) requires that BART controls must b e in operation for each applicable source no later than five ye ars after EPA SI P approval. MassDEP will require Wheelabrator to compl y with the lower NO x and PM emissions limit s as expeditiously as practicable but in no case later than March 31, 2014. BAR T determinations are required to be federall y enforceable. MassDEP will require that Wheelabrator - Saugus modify its emissions control plan s pursuant to 310 CMR 7.08(2) to make the lower BA RT NO x and PM emissions rate s state and federally enforceable. **8.10.** 

### BA **RT or Alternative to BART**  **for Remaining Sources [Reserved]** This Section is reserved; MassDEP intends to re - propose this Section in early 2012. **8.11.** 

### Reasonably Attributable Visibility Impairment 40 CFR 51.302(c) provides for general plan requirements in cases where the affected Federal Land Manager has notified the state that Reasonably Attributable Visibility

I mpairment (RAVI) exists in a Class I Area in the state. Based on the modeling conducted b y MANE - VU and consultations with Federal Land Managers, there are no RAVI sources in Massachusetts or the other MANE - VU states.Page 81 

# 9. **REASONABLE PROGRESS GOALS**  For each Class I area within a State/Tribe, 40 CFR Section 51.308(d)(1) requires th e State/Tribe to establish reasonable progress goals (expressed in deciviews) that provide for reasonable progress towards achieving natural visibility . EPA released guidance on June 7, 2007 to use in setting reasonable progress goals. The goals must provide improvement in visibility for the most impaired day s and ensure no degradati on in visibility for the least impaired day s over the SIP period. The State/Tribe also must provide an assessment of the number of ye ars it would take to attain natural visibility condition s if improvement continues at the rate represented b y the reasonab le progress goals. Under 40 CFR Section 51.308(d)(1)(iv) , consultation is required in developing reasonable progress goals. The rule states: In developing each reasonable progress goal, the State must consult with those States which may reasonably be a nticipated to cause or contribute to visibility impairment in the mandatory Class I Federal area. In any situation in which the State cannot agree with another such State or group of States that a goal provides for reasonable progress, the State must describe in its submittal the actions taken to resolve the disagreement. In reviewing the State's implementation plan submittal, the Administrator will take this information into account in determining whether the State's goal for visibility improvement provides for reasonable progress towards natural visibility conditions. In developing the reasonable progress goal , the Class I State/Tribe also must consider four factors (cost of compliance, time needed for compliance, energy and non - air quality

environmental i mpacts, and remaining useful life of any affected source). The State/Tribe also must show that it considered the uniform rate of progress and the emission reduction measures needed to achieve reasonable progress for the period covered b y the implementatio n plan, and if the state proposes a rate of progress slower than the uniform rate of progress, assess the number of y ears it would take to attain natural conditions if visibility improvement continues at the rate proposed. Because Massachusetts does not contain an y Class Iareas, it did not determine reasonable progress goals but did consult with states it impacts . Massachusetts consulted with Maine, New Hampshire, and Vermont, which hav e Class I areas impacted b y emissions from sources within Massachuse tts . Massachusetts agrees with the reasonable progress goals established by the se states through the MANE VU planning process for their Class Iareas . As a benchmark to aid in developing reasonable progress goals, MANE - VU compared baseline visibility con ditions to natural visibility conditions at each MANE - VU Class I area. The difference between baseline and natural visibility conditions for the 20 percent worst day s was used to determine the uniform rate of progress that would be needed during each impl ementation period in order to attain natural visibility

conditions by

2064. Table 21 presents baseline visibility , natural visibility , and required uniform rate of progress for the MANE - VU Class Iarea s affected by emissions from sources within Massachuse tts . Visibility values are expressed in deciviews (dv), where each single - unit deciview decrease would represent a barel y perceptible improvement in visibility .Page 82

**Table 15**  **: Uniform Rate of Progress Calculation (all values in decivie**  **ws) Class I Area**  **2000 -**  **2004**

**Baseline Visibility**  **(20% Worst Days)**  **Natural**

**Visibility (20% Worst**  **Days) Total** 

**Improvement Needed by**  **2018 Total** 

**Improvement Needed by**  **2064 Uniform** 

**Annual Rate of**  **Improvement** Acadia National Park 22.9 12.4 2.4 10.5 0.174 Mooseho rn Wilderness and Roosevelt Campobello International Park 21.7 12.0 2.3 9.7 0.162 Great Gulf Wilderness and Presidential Range - Dry River Wilderness 22.8 12.0 2.5 10.8 0.180 Lye Brook Wilderness 24.5 11.7 3.0 12.8 0.212 Note: Both natural conditions and baseline visibility for the 5 - year period from 2000 through 2004 were calculated in conformance with an alternative method recommended by the IMPROVE Steering Committee. 30 The reasonable progress goals established for each of the Class I are as are expected to provide greater visibility improvements than the uniform rate of progress shown in Table 2 1. A summary of the reasonable progress goals are shown in Table s 22 and 23 . **Table 16**  **: Reasonable Progress Goals -**  **20% Worst**  **Days (all values in deciviews) Visibility Condition**  **2000 -**  **2004 Baseline**  **Visibility 2018 Reasonable** 

**Progress Goal Visibility** 

**Improvement by 2018**  **Natural**

**Visibility** Acadia National Park 22.9 19.4 3.5 12.4 Moosehorn Wilderness Area/ Roosevelt Campobel lo International Park 21.7 19.0 2.7 12.0 Great Gulf Wilderness 22.8 19.1 3.7 12.0 Presidential Range

– Dry River Wilderness 22.8 19.1 3.7 12.0 Lye Brook Wilderness 24.4 20.9 3.5 11.7

30 “Baseline and Natural Visibility Conditions, Considerations and Proposed Approach to the Calculation of Baseline and Natural Visibility Condition s at MANE - VU Class I Areas,” NESCAUM, December 2006.Page 83

**Table 17**  **: Reasonable Progress Goals -**  **20% Best**  **Days (**  **all values in deciviews) Visibility Condition**  **2000 -**  **2004 Baseline**  **Visibility 2018 Reasonable** 

**Progress Goal Visibility** 

**Improvement by 2018**  **Natural**

**Visibility** Acadia National Park 8.8 8.3 0.5 4.7 Moosehorn Wilderness Area/ Roosevelt Campobe llo International Park 9.2 8.6 0.6 5.0 Great Gulf Wilderness 7.7 7.2 0.5 3.7 Presidential Range

– Dry River Wilderness 7.7 7.2 0.5 3.7 Lye Brook Wilderness 6.4 5.5 0.9 2.8Page 84 

# 10. **LONG -**  **TERM STRATEGY** 40 CFR Section 51.308(d)(3) requires Massachusetts t o submit a long - term strategy that addresses regional haze visibility

impairment for each mandatory Class I Federal area within and outside the state that may be affected b y emissions from within the state. The long - term strategy must include enforceable emissions limitations, compliance schedules, and other measures necessary to achieve the reasonable progress goals established by states where the Class I areas are located. Consultation between states affecting and/or containing Class I areas must be per formed to develop coordinated emission management strategies. The state must demonstrate that it has included all measures necessary to obtain its share of the emission reductions needed to meet the progress goal for the area. If the state has participat ed in a regional planning process, the state must include measures needed to achieve its obligations agreed upon through that process. This section describes the long - term strategy that Massachusetts will pursue to address visibility impairment for each of the following Class I areas that are affected b y emissions from within Massachusetts: Acadia National Park, Great Gulf Wilderness, Ly e Brook Wilderness, Presidential Range/Dry

River Wilderness, Moosehorn Wilderness, and Roosevelt/Campobello Internation al Park. The long - term strategy

includes enforceable emissions limitations, compliance schedules, and other measures necessary

to achieve the reasonable progress goals established for the Class I areas. To the extent that it is practicable , Massachusetts commits to adopting these measures before submitting a report on reasonable progress to EPA in 2013 . Additional measures may be reasonable to adopt at a later date after further consideration and review. **10.2.** 

### Overview **of the**  **Long -**  **Term Strategy Development P**  **rocess** As a participant in MANE - VU, Massachusetts supported a regional approach towards deciding which control measures to pursue for regional haze based on technical anal ys es documented in the following reports:

 Contributions to Regional Haze in the Northeast and Mid - Atlantic United States (called the Contribution Assessment, Appendix A ),  Five -Factor Analysis of BART -Eligible Sources: Survey of Options for Conducting BART Determinations (Appendix R),  Compariso n of CAIR and CAIR Plus Proposal using the Integrated Planning Model® (called the CAIR+ Report, Appendix S ),  Assessment of Reasonable Progress for Regional Haze in MANE- VU Class I Areas (called the Reasonable Progress Report, Appendix T ), and  Assessment of Control Technology Options for BART -Eligible Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp Facilities (Appendix U ). The regional strategy

development process identified reasonable measures that would reduce emissi ons contributing to visibility

impairment at Class Iareas affected b y emissions from within the MANE - VU region by 2018 or earlier. The technical basis for the long - term strategy is discussed in the following section , which describes the process of identi fying potential emission reduction strategies. MANE - VU reviewed a wide range of potential control measures to reduce emissions from sources contributing to visibility

impairment in affected Class Iareas. The process by which MANE - VU arrivedPage 85

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 a naly sis of ozone and regional haze control measure options. OTC provided the contractor with a “master list” of some 900 potential control measures, based on experience and previous state implementation plan work. With the help of an internal OTC control measure workgroup, the contractor 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: bey on d - CAIR sulfate reductions f rom EGUs, low - sulfur heating oil (residential and commercial), and controls on I CIboilers (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 h aze control measure selection process was to further refine the interim list. The CAIR+ Report (Appendix S ) documents the analysis of the cost of additional SO 2 and NO x controls at EGUs in the Eastern U.S. The Reasonable Prog ress Report (Appendix T ) documents the assessment of control measures for EGUs and the other source categories selected for analysis. Further anal ys is is provided in the NESCAUM document entitled, “ Assessment of Control Techno logy Options for BARTEligible Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and Pulp Facilities ” (Appendix 0 ) . The bey ond - CAIR EGU strategy continued to stay

on the list since E GU sulfate emissions have, b y far, the largest impact on visibility in the MANE - VU Class Iareas. Li kewise, a low - sulfur oil strategy gained support after a NESCAUM - initiated conference with refiners and fuel - oil suppliers concluded that such a strategy

c ould realistically

be implemented in the 2014 timeframe. T h e low - sulfur heating oil and the oil - fired ICI boiler sector control measures merged into an overall low - sulfur oil strategy for distillate and residual oils for both the residential and commercia l 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 are too f ew coal - fired ICI boilers in the MANE - VU states to be considered a “regional” control strategy , but could be a sector pursued by individual states. They

also determined that control of lime and cement kilns, of which there are few in the MANE - VU region, w ould likel y be handled in each state’s BART determination process. Residential wood burning and outdoor wood boilers remained a strategy for those states where localized visibility impacts may be of concern even though emissions from these sources are pri marily

organic carbon and direct particulate matt er. Finally , outdoor wood burning also was determined to be better left as a sector to be examined and controlled further by individual states, due to issues of enforceability and penetration of existing st ate regulations. **10.3.** 

### Technical Basis for Strategy Development 40 CFR Section 51.308(d)(3)(iii) requires states to document the technical basis for the state’s apportionment of emission reductions necessary to meet reasonable progress goals in each Class I are a affected b y the state’s emissions. Massachusetts relied on technical anal ys es developed b y MANE - VU to demonstrate that its emission reductions, when coordinated with those of other states, are sufficient to achieve reasonable progress goals in Class Iareas affected by Massachusetts.Page 86

T he emission reductions necessary to meet reasonable progress goals in each Class Iarea affected by Massachusetts are summarized in the following sections of this SI P and are described in the following document s :

 Contribu tions to Regional Haze in the Northeast and Mid - Atlantic United States (called the Contribution Assessment, Appendix A )  Baseline and Natural Background Visibility Conditions

— Considerations and Proposed Approach to the Calculation of Baseline and Natural Background Visibility Conditions at MANE- VU Class I Areas (Appendix E )  MANE- VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportion ment, and Control Measure Benefits (Appendix F )  2018 Visibility Projections (Appendix G )  Five -Factor Analysis of BART -Eligible Sources: Survey of Options for Conducti ng BART Determinations (Appendix R)  Comparison of CAIR and CAIR Plus Proposal using the Integrated Planning Model® (called the CAIR+ Report, Appendix S )  Assessment of R easonable Progress for Regional Haze in MANE- VU Class I Areas (called the Reasonable Progress Report) (Appendix T )  Assessment of Control Technology Options for BART -Eligible Sources: Steam Electric Boilers, Industri al Boilers, Cement Plants and Paper and Pulp Facilities (Appendix 0 )  The Nature of the Fine Particle and Regional Haze Air Quality Problems in the MANE - VU Region: A Conceptual Description (Appendix V ) In addition, Massachusetts relied on anal ys es conducted by neighboring RPOs, including the following documents, which are available upon request but are not incorporated into this SIP:

 VI STAS Reasonable Progress Anal ys is P lan by VI STAS, dated September 18, 2006  Reasonable Progress for Class IAreas in the Northern Midwest - Factor Analy sis, by EC/R, dated July

18, 2007 Massachusetts worked with other members of the Ozone Transport Commission and MANE - VU, as described in Sect ion 2, to consider a wide variet y of potential emission reduction strategies covering a wide range of sources of SO 2 and other pollutants contributing to regional haze. 40 CFR 51.308(d)(1) requires states to consider several factors in developing their lo ng - term strategies. Using available information about emissions and potential impacts, the MANE - VU Reasonable Progress Workgroup selected the following source categories for detailed anal ys is:

 Coal and oil - fired electric generating units (EGUs);  Point an d area source industrial, commercial and institutional boilers;  Cement kilns;  Lime kilns;  The use of low - sulfur heating oil; and  Residential wood combustion and open burning. These efforts led to the selection of the emission reduction strategies presente d in this SIP.Page 87

**10.4.** 

### 2018 Emission Reductions Due to Ongoing Air Pollution Controls 40 CFR Section 51.308(d)(3)(v)(A) requires states to consider emission reductions from ongoing pollution control programs. Indeveloping its long - term strategy , Massachusetts co nsidered emission control programs being implemented between the 2002 baseline period and 2018, as discussed below. Many of the emission reduction programs represent commitments already made by Massachusetts and other states to implement air pollution control measures for EGU point sources, non - EGU point sources, and area sources, respectively . These control measures are the same measures that were included in the 2018 emissions inventory and used in the modeling. While these control measures were not de signed expressly for the purpose of improving visibility , the pollutants they control include those that contribute to visibility

impairment in MANE - VU Class I Areas. MANE - VU’s 2018 “beyond on the way ” (BOTW) emissions inventory accounts for emission controls that are alread y in place, as well as those that are not y et finalized but are likely to achieve additional reductions b y 2009. 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 b y 2018. The inventory is termed “bey ond on the way ” because it includes control measures that were developed for ozone SIPs that are not yet on the books in some states. For some states, it also included controls that were under consideration for Regional Haze SI P s that have not y et been adopted. Given the uncertainty inherent in the BOTW emissions inventory due to lack of enforcea

bilit y, Massachusetts is continuing to evaluate these measures to determine whether they are reasonable to adopt and implement by 2018 and expects to make that determination in the progress report it will submit in 2013 . More information may

be found in the following documents:

 MANE- VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Control Measure Benefits (Appendix F )

 2018 Visibility Projections (Appendix G )

 Development of Emissions Projections for 2009, 2012, and 2018 for Non -EGU Point, Area, and Non - road Sources in the MANE- VU Region (Appendix N )

 Documentation of 2018 E missions from Electric Generating Units in the Eastern U.S. for MANE- VU’s Regional Haze Modeling (Appendix W ) **EGU Emissions**  **Controls Expected by 2018** The following EGU emission reduction programs were included in the modeling used to develop the reasonable progress goals and as the basis for the long - term strategy : Clean Air Interstate Rule (CAIR) . The CAIR program was intended to permanently cap emissions of SO 2 and NO x in the eastern United States by 2015 and r educe SO 2 emissions in the CAIR region by more than 70 percent and NO x emissions by more than 60 percent from 2003 levels. However, CAIR was vacated b y the U.S. Court of Appeals on July 11, 2008. A subsequent remand to EPA for remedy occurred on December 23, 2008. CAI R remain ed in place through 2011. On August 8, 2011, EPA promulgated the Cross State Air Pollution Rule, effective beginning January 1, 2012. The IPM ® modelPage 88

was used to predict future emissions from EGUs after implementation of CAIR. 31 Al l MANE - VU Class I states used CAIR as a basis for modeling progress towards the reasonable progress goals in their Regional Haze SIPs. For the short - term, this modeling is still valid. MANE - VU will incorporate the details of EPA’s CSAPR into future model ing. Modifications to the output of IPM ® made to better represent anticipated controls are described in the report Documentation of 2018 Emissions from Electric Generating Units (Appendix W ). Controls considered i n making these modifications include the following: Connecticut EGU Regulations : Connecticut adopted the following regulations governing EGU emissions:

 Regulations of Connecticut State Agencies (RCSA) section 22a - 174 - 19a, limiting the SO 2 emission rate to 0.33 lb SO 2 /MMBtu for fossil fuel - fired EGUs greater than 15 MW that also are Title IV sources. (Implementation status - 2007)  RCSA section 22a - 174 - 22, limiting the non - ozone seasonal NO x emission rate to 0.15 lb NO x/MMBtu for fossil fuel - fired EGUs greater than 15 MW. (Implementation status - 2007)  Connecticut General Statutes section 22a - 199, limiting the mercury (Hg) emission rate to 0.0000006 lb Hg/MMBtu for all coal - fired EGUs , or alternativel y coal - fired EGUs can meet a 90% Hg emission reduct ion. (Implementation status - 2008) Delaware EGU Regulations : Delaware adopted the following regulations governing EGU emissions: 1. Reg. 1144, Control of Stationary Generator Emissions , SO 2 , PM, VOC and NO x emission control, Statewide, Effective January 2 006. 2. Reg. 1146, EGUs, Electric Generating Unit (EGU) Multi -Pollutant Regulation, SO 2 and NO x emission control, Statewide, Effective December 2007. SO 2 reductions will be more than regulation specifies. 3. Regulation No. 1148, Control of Stationary Combustion Turbine Electric Generating Unit Emissions , SO 2 , NO x, and PM 2.5 emission control, Statewide, Effective January 2007. Delaware estimates that these regulations will result in the following emission reductions for affected units: SO 2 2002 levels of 32,630 tons to 8,137 tons in 2018 (75 percent decrease )

NO x 2002 levels of 8,735 tons to 3,740 tons in 2018 (57 percent decrease ) Delaware Consent Decree : Valero Refinery Delaware Cit y, DE (formerl y Motiva, Valero Enterprises). 2002 SO 2 levels of 29,747 tons w ill d ecrease to 608 tons in 2018 (98 percent decrease ). NO x 2002 levels of 1,022 tons will decrease to 102 tons in 2018 (90 percent decrease ). Maine EGU Regulations : Maine adopted the following regulations governing EGU emissions:

31 Although the IPM ® mo del runs also anticipated the implementation of EPA’s Clean Air Mercury Rule (CAMR), that rule has since been vacated by the courts. How ever, it is anticipated the adjustments to the predicted SO 2 emissions from EGUs used in the air quality modeling, which were based on state - specific comments on the amount of SO 2 controls that will actually be installed due to state - specific regulations and EPA’s CAIR rule, will have more of an impact on the air quality mo deling analysis conducted for this SIP than the vacatur of the CAMR rule. MANE - VU believes the adjustments based on state - specific comments improved the reliability of the inventory and made the modeling results more dependable.Page 89

Chapter 145 NO x Contr ol Program , which limits the NO x emission rate to 0.22 lb NO x/MMBtu for fossil fuel - fired units greater than 25 MW built before 1995 with a heat input capacit y between 250 and 750 MMBtu/hr and also limits the NO x emission rate to 0.15 lb NO x/MMBtu for foss il fuel - fired units greater than 25 MW built before 1995 with a heat input capacit y greater than 750 MMBtu/hr. (Implementation - 2007) Massachusetts EGU Regulations: Massachusetts adopted 310 CMR 7.29, Emissions Standards for Power Plants, in 2001, which :  Applies to six of the largest fossil fuel - fired power plants in Massachusetts, including Bray ton Point (Units 1, 2, 3, 4), My stic (Units 4, 5, 6, 7, 81, 82, 93, and 94 ), NRG Somerset (Units 8), Mount Tom (Unit 1), Canal Station (Units 1 and 2), and Salem Harbor (Units 1, 2, 3, and 4) .  Limits SO 2 emissions to 6.0 lbs/MWh each month and 3.0 lbs/MWh as a rolling average incorporating allowances and earl y reduction credits.  Li mits NO x emissions to 3.0 lbs/MWh each month and 1.5 lbs/MWh as a rolling average.  Limits mercury

(Hg) emissions to 85% Hg reduction or 0.0075 lbs Hg/GWh in 2008 and 90% Hg reduction or 0.0025 lbs Hg/GWh in 2012.  Limits CO 2 emissions to 1 , 800 lb s CO 2 /MWh. These regulations will achieve an approximately 50 percent reduction in NO x emissi ons and 50 - 75 percent reduction in SO 2 emissions. New Hampshire EGU Regulations : New Hampshire adopted the following regulations governing EGU emissions: 1. Chapter Env - A 2900 , which caps NOx emissions on all existing fossil steam units to 3,644 tons NO x per ye ar, SO 2 emissions on all existing fossil steam units to 7,289 tons SO 2 per y ear, and CO 2 emissions on all existing fossil steam units to 5,425,866 tons CO 2 per y ear. (Implementation - 2007) 2. Chapter Env - A 3200 , which limits NO x emissions on all fossi l fuel - fired EGUs greater than 15 MW to 0.15 lb NO x/MMBtu. (Implementation - 2007) New Jersey

New Source Review Settlement Agreements : The New Jersey settlement agreement with PSEG required the following actions: 1. Repower Bergen Unit #2 to combined cy cle by December 31, 2002. **2.** For Hudson Unit #2 , install Dry FGD or approved alternative technology by Dec. 31, 2006 to contr ol SO 2 emissions and operate the control technology at all times the unit operates to limit SO 2 emissions to 0.15 lb SO 2 /MMBtu; install SCR or approved alternative technology by May 1, 2007 to control NO x emissions and operate the control technology y ear - round to limit NO x emissions to 0.1 lb NO x/MMBtu; and install a baghouse or approved alternative technology by May 1, 2007 to control PM emissions and limit PM emissions to 0.015 lb PM/MMBtu. The settlement also requires coal with a monthly average sulfur content no greater than 2% at units operating an FGD. 3. For Mercer Unit #1: install Dry FGD or approved alternative technology by Dec. 31 , 2010 to control SO 2 emissions and operate the control technology at all times the unit operates to limit SO 2 emissions to 0.15 lb SO 2 /MMBtu and install SCR or approved alternative technology by 2005 toPage 90

control NO x emissions and operate the control techno logy ozone season only

in 2005 and ye ar round by May 1, 2006 to limit NO x emissions to 0.13 lb NO x/MMBtu. The settlement also requires coal with a monthly average sulfur content no greater than 2% at units operating an FGD. 4. For Mercer Unit #2: install Dry FGD or approved alternative technology by Dec. 31, 2012 to control SO 2 emissions and operate the control technology at all times the unit operates to limit SO 2 emissions to 0.15 lb SO 2 /MMBtu and install SCR or approved alternative technology by 2004 to c ontrol NO x emissions and operate the control technology ozone season only

in 2004 and ye ar round by May 1, 2006 to limit NO x emissions to 0.13 lb NOx/MMBtu. The settlement also requires coal with a monthly average sulfur content no greater than 2% at unit s operating an FGD. New York EGU Regulations : New York adopted the following regulations governing EGU emissions: Part 237 , which limits NO x emissions from all fossil fuel - fired EGUs greater than 25 MW to a non ozone season cap of 39,908 tons in 2007 and annual SO 2 emissions from all fossil fuel - fired EGUs greater than 25 MW to an annual cap of 197,046 tons SO 2 /year starting in 2007 and an annual cap of 131,364 tons SO 2 /year starting in 2008. North Carolina Clean Smokestacks Act : Under the act, enacted in 2002, coal - fired power plants (EGUs) in North Carolina must achieve a 77 percent cut in NO x emissions by 2009 and a 73 percent cut in SO 2 emissions by

2013. This legislation establishes annual caps on both SO 2 and NO x emissions for the two primary uti lity companies in North Carolina, Duke Energy and Progress Energy . These reductions must be made in North Carolina, and allowances are not saleable. Consent Agreements in the VISTAS region : The impacts of the following consent agreements in the VI STAS states were reflected in the emissions inventory used for those states:

 Santee Cooper: A 2004 consent agreement calls for Santee Cooper in South Carolina to install and commence operation of continuous emission control equipment for PM/SO 2 /NO x emissions; comply

with sy stem - wide annual PM/SO 2 /NO x emissions limits; agree not to bu y, sell or trade SO 2 /NO x allowances allocated to Santee Cooper S ys tem as a result of said agreement; and to comply with emission unit limits of said agreement.

 TECO: Under a settlem ent agreement, b y 2008, Tampa Electric in the state of Florida will install permanent emissions control equipment to meet stringent pollution limits; implement a series of interim pollution - reduction measures to reduce emissions while the permanent control s are designed and installed; and retire pollution emission allowances that Tampa Electric or others could use, or sell to others, to emit additional NO x , SO 2 and PM.

 VEPCO: Virginia Electric and Power Co. agreed to spend $1.2 billion between b y 2013 to el iminate 237,000 tons of SO 2 and NO x emissions each ye ar from eight coal - fired electricit y generating plants in Virginia and West Virginia.

 Gulf Power 7: A 2002 agreement calls for Gulf Power to upgrade its operation to cut NO x emission rates by

61 percent at its Crist 7 generating plant b y 2007 with major reductions beginning in earl y 2005. The Crist plant is a significant source of nitrogen oxide emissions in the Pensacola Florida area.Page 91

**Non -**  **EGU Point Source Controls Expected by 2018** Control factors were applied to the 2018 MANE - VU inventory to represent the following national, regional, and state control measures:

 NO x SIP Call Phase I (NO x Budget Trading Program)  NO x SIP Call Phase II  NO x RACT in 1 - hour Ozone SI Ps  NO x OTC 2001 Model Rule for ICI Boilers  2 - , 4 - , 7 - , and 10 - year MACT Standards  Combustion Turbine and RI CE MACT  Industrial Boiler/Process Heater MACT 32

 EPA’s Refinery

Enforcement Initiative In addition, states provided specific control measure information about specific sources or regulatory programs in their state. MANE - VU used the state - specific data to the extent it was available. For other regions, MANE - VU used inventories developed by the RPOs for those regions, including VI STAS 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 VI STAS Base G2 inventory .) Non - EGU source controls incorporated into the modeling include the following consent agreements reflected in the VI STAS inventory :

 Dupont: A 2007 agreement calls for E. I. Dupont Nemours & Compan y’ s James River plant to install dual absorption pollution control equipment by September 1, 2009, resulting in emission reductions of approximately 1,000 tons SO 2 annually . The James River plant is a non - E GU located in the state of Virginia.

 Stone Container: A 2004 agreement calls for the West Point Paper Mill in Virginia owned b y Smurfit/Stone Container to control with a wet scrubber the SO 2 emissions of the #8 Power Boiler. This control device should re sult in reductions of over 3,500 tons of SO 2 in 2018. **Area Source Controls Expected by 2018** For area sources within MANE - VU, Massachusetts relied on MANE - VU’s Version 3.0 Emissions Inventory for 2002. In general, the 2018 inventory for area sources was d eveloped 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 and regional control measures:

 OTC VOC Model Rules (Consumer products, architectural and indu strial maintenance coatings, portable fuel containers, mobile equipment repair and refinishing, and solvent cleaning)  Federal On - board Vapor Recovery  New Jersey

Post - 2002 Area Source Controls  Residential Woodstove NSPS

32 The inventory was prepared before the MACT for Industrial Boilers and P rocess Heaters was vacated. Control efficiency wa s assumed to be at 4 percent for SO 2 and 40 percent for PM.Page 92

The following additional control m easures were included in the 2018 anal ys is to reduce VOC emissions for the following area source categories for some states (as identified below):

 NO x measures (natural gas, No. 2 fuel oil, No. 4 and 6 fuel oil, and coal; only in CT, NJ, and NY) ;

 VOC mea sures: adhesives and sealants (all MANE - VU states except VT);

 emulsified and cutback asphalt paving (all MANE - VU states e xcept DE, ME, and VT);

 consumer products (all MANE - VU states except VT) ; and

 portable fuel containers (all MANE - VU states except VT) . As noted above, the inventory information used for other regions was obtained from those regions’ RPOs. **Onroad Mobile Source Controls Expected by 2018** For the onroad mobile source emission inventory , Massachusetts relied on MANE - VU’s Version 3.0 emissi ons inventory that included the following emission control measures in MANE - VU states: Heav y Dut y 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 y ear. This rule also includes standards for NO x and non - methane hy drocarbons (NMHC) of 0.20 g/bhp - hr and 0.14 g/bhp - hr, respectivel y. These NO x and NMHC standards will be phased in together between 2007 and 201 0 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 content of highway diesel fuel from its current lev e l of 500 parts per million (low - sulfur diesel, or L SD) 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 pro duce vehicles with emissions ranging from relatively dirty to zero, but the mix of vehicles a manufacturer sells each year must have average NO x emissions below a specified value. Tier 2 standards became effective in the 2005 model y ear and are included i n the assumptions used for calculating mobile source emissions inventories used for 2018. Large Spark Ignition and Recreational Vehicle Rule : EPA has adopted new standards for emissions of NO x , hy drocarbons (HC), and carbon monoxide (CO) from several gro ups of previously unregulated nonroad engines. Included in these are large industrial spark - ignition engines and recreational vehicles. Nonroad spark - ignition engines are those powered by gasoline, liquid propane, or compressed natural gas rated over 19 kilowatts (kW) (25 horsepower). These engines are used in commercial and industrial applications, including forklifts, electric generators, airport baggage transport vehicles, and a variet y of farm and construction applications. Nonroad recreational vehi cles include snowmobiles, off

- highway motorcy cles, and all terrain vehicles. These rules were initially effective in 2004 and were assumed to be fully phased - in by

2012.Page 93

**Nonroad Sources Controls Expected by 2018** Massachusetts used Version 3.0 of the MANE - VU 2002 Emissions Inventory . Since the NONROAD Model used to develop the nonroad source emissions did not include aircraft, commercial marine, and locomotives, MANE - VU’s contractor, MACTEC, developed the inventory for these categories. Nonroad mobile so urce emissions for the 2018 emission inventory were calculated with EPA’s NONROAD2005 emissions model as incorporated in the NMI M2005 (National Mobile Inventory Model) database. The NONROAD model accounts for the emissions benefits associated with Federal non - road equipment emissions control measures such as the following:  “Control of Air Pollution; Determination of Significance for Nonroad Sources and Emissions Standards for New Nonroad Compression Ignition Engines At or Above 37 Kilowatts,” 59 FR 31306, June 17, 1994.  “Control of Emissions of Air Pollution From Nonroad Diesel Engines,” 63 FR 56967, October 23, 1998.  “Control of Emissions From Nonroad Large Spark - Ignition Engines and Recreational Engines (Marine and Land - Based); Final Rule,” 67 FR 68241, November 8, 2002.  “Control of Emissions of Air Pollution From Nonroad Diesel Engines and Fuel; Final Rule,” April, 2004. This rule sets standards that will reduce emissions by more than 90 percent from nonroad diesel equipment and reduce sulfur levels by 9 9 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. As noted above, the inventory information used for other regions was obtained from those regions’ RPOs. **Additional Controls Analyzed as Part of Ozone SIPs** Additional control measures were considered b y s everal states as part of ozone planning. These control measures were included in the inventory used for regional haze modeling analy sis. The states may or may not have committed to adopting these measures in the ozone SIP. For specific states, the measures included in this analy sis 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):

 NO x measures:

 Asphalt production plants in CT, DC, NJ, and NY

 Cement kilns in ME, MD, NY, PA

 Glass and fiberglass furnaces in MD, MA, NJ, NY, PA  VOC measure: adh esives and sealants application (all MANE - VU states except NJ 33 and VT) These measures were included in the “Bey ond on the Way ” inventory for the states identified.

33 Note that New Jersey indicated that the reductions from the adhesives and sealants application control measure should only apply to area sources

—no reductions for point sources (SCC 4 - 02 - 0007 - xx) w ere included due to inventory double counting issues, not due to rule change issues.Page 94

The following additional control measures were included in the 2018 anal ys is to reduce VO C emissions for the following area source categories for some states (as identified below):

 NO x measures (natural gas, No. 2 fuel oil, No. 4 and 6 fuel oil, and coal) (Only CT, NJ, and NY)  VOC measures: adhesives and sealants (except VT)  emulsified and c utback asphalt paving (except ME and VT)  consumer products (except VT)  portable fuel containers (except VT) **10.5.** 

### Additional Reasonable Strategies In developing reasonable progress goals as required by 40 CFR 51.308(d)( 1 ) , Massachusetts and the MANE - VU state s identified specific emission control measures - bey ond those which individual states or RPOs have alread y made commitments to implement - that would be reasonable to undertake as part of a concerted strategy

to mitigate regional haze. The proposed addit ional control measures were incorporated into the regional strategy adopted b y MANE - VU on June 20, 2007, to meet the reasonable progress goals established by the Class I states. The basic elements of this strategy are described in the MANE - VU “Ask” (see b elow). States targeted for coordinated actions toward achieving these goals include all of the MANE - VU states plus Georgia, Illinois, Indiana, Kentucky , Michigan, North Carolina, Ohio, South Carolina, Tennessee, Virginia and West Virginia 34

. In addition t o proposed emission controls in the U.S., the MANE - VU Class Istates determined that it was reasonable to include anticipated emission reductions in Canada in the modeling used to set reasonable progress goals. This determination was based on evaluations conducted before and during the consultation process. Specificall y, the modeling accounts for six coal - burning EGUs in Canada having a combined output of 6,500 MW that are scheduled to be shut down and replaced b y nine natural gas turbine units with selec tive cataly tic reduction (SCR) by

2018. **Rationale for**  **Determining Reasonable Controls**  40 CFR 51.308 (d)(1)(i)(A) requires that, in establishing reasonable progress goals for each Class I area, the State must consider the costs of compliance, the time necess ary for compliance, the energy and non air quality

environmental impacts of compliance, and the remaining useful life of any potentiall y affected sources. The SIP must include a demonstration showing how these factors were taken into consideration in sett ing the reasonable progress goals. These factors are sometimes termed the “four statutory factors,” since their consideration is required by the Clean Air Act. Focus on SO **2 :**  MANE - VU conducted a Contribution Assessment (Appendix A) and developed a conce ptual model that indicated particulate sulfate formed from emissions of SO 2 was the dominant contributor to visibility

impairment at all sites and during all seasons in the base y ear. While other pollutants, including organic carbon and NO x , will need to be addressed in order to achieve the national visibility goals, MANE - VU’s contribution assessment suggested that an early emphasis on SO 2 will yi eld the greatest near - term benefit. Therefore, it is reasonable to conclude that the additional measures consi dered in establishing reasonable progress goals require reductions in SO 2 emissions.

34 In addition, the State of Vermont identified at least one source in the State of Wisconsin as a significant contri butor to visibility impairment at the Lye Brook Wilderness Class I Area.Page 95

Contributing Sources **:** The MANE - VU Contribution Assessment indicates that emissions in 2002 from within the MANE - VU region were responsible for about 25 to 30 percent of the sulfate at MANE - VU Class Iareas. Sources in the Midwest and Southeast regions were responsible for about 15 to 25 percent each, respectively . Point sources dominated the inventory of SO 2 emissions. Therefore, the MANE VU’s long - term strateg y inclu des additional measures to control sources of SO 2 both within the MANE VU region and in other states that were determined to contribute to regional haze at MANE - VU Class I areas. The Contribution Assessment documented the source categories most responsib le for visibility degradation at MANE - VU Class Iareas. As described earlier , there was a collaborative effort between the Ozone Transport Commission and MANE - VU to evaluate a large number of potential control measures. Several measures that would reduce SO 2 emissions were identified for further stud y. These efforts led MANE - VU to prepare the report entitled, “Assessment of Reasonable Progress for Regional Haze in MANE - VU Class I Areas” MACTEC, July 9, 2007 otherwise known as the Reasonable Progress Rep ort (Appendix T ), which documented an anal ys is of the four statutory factors for five major source categories. Table 24 summarizes the results of MANE - VU’s Reasonable Progress Report, which considered EGUs, I CIboilers, cement kilns, heating oil and resid ential wood combustion. The MANE - VU states reviewed the four - factor analy sis presented in the Reasonable Progress Report, consulted with each other about the measures, and concluded b y adopting the statements known as the MANE - VU “ Ask ” on June 20, 2007. These statements identify the control measures that would be pursued toward improving visibility in the region and that were included in the modeling used to establish reasonable progress goals.Page 96 **Table 18**  **: Summary of Results from th e Four**  **- Factor Analysis** 

**Source Category**  **Prim ary** 

**Regional Haze**  **Pollutant Control Measure(s)**  **Average Cost in 2006 dollars (per**  **ton of pollutant reduction)**  **Compliance**

**Timeframe Energy and Non**  **- Air** 

**Quality Environmental**  **Impacts Rem**  **aining**

**Useful Life** Electric Ge nerating Units SO 2 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 . IPM®* v.2.1.9 predicts $775 - $1,690. $170 - $5,700 based on available literature 2 - 3 y ears

following SIP submittal Fuel supply issues,

potential permitting issues, reduction in electricity production capacity, w astewater issues 50 years or mo re

Industrial, Commercial, Institutional Boilers SO 2 Switch to a low sulfur coal (g enerally <1% sulfur), switch to natural gas (virtually 0% sulfur), switch to a low er 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 y ears

following SIP submittal Fuel supply issues,

potential permitting issues, control device energy requirements, wa stewater issues 10 - 30 years

Cement and Lime Kilns SO 2 Fuel switching, Dry Flue Gas Desulfurization: Spray Dry er Absorption (FGD), Wet Flue Ga s Desulfurization (FGD), Ad vanced Flue Gas Desulfurization (FGD). $1,900 - $73,000 based on available literature. Depends on size. 2 - 3 y ears

following SIP submittal Control device energy

requirements, wa stewater issues 10 - 30 years

Heating Oil SO 2 Lo wer 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 im plementation of new fuel standards Increases in

furnace/boiler efficiency, decreased furnace/boiler maintenance requirements 18 - 25 years

Residential Wood Com bustion PM State implementation of NSPS, ban on resale of uncertified devices, installer training certification or inspection progra m, 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 greenhouse

gas emissions, increase efficiency of combustion device 10 - 15 years

*Integrated Planning Model®Page 97

**MANE -**  **VU Statement of June 20, 2007** The reasonable progress goals adopted b y the MANE - VU Class I states represent implementation of the regional course of action set forth b y MANE - VU on June 20, 2007 entitled “ Statement of the MidAtlantic/Northeast Visibility union (MANE- VU) Concerning a Course of Action within MANE- VU toward Assuring Reasonable Progress .” 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 “emission management” strategies, as appropriate and necessary : a Timely

implementation of BART requirements; and b 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: o Distillate oil to 0.05 percent sulfur b y weight (500 ppm) by no later than 2012, o #4 residual oil to 0.25 percent sulfur b y weight by no later than 2012, o #6 residual oil to 0.3

– 0.5 percent sulfur b y weight by no later than 2012, and o Further reduce the sulfur content of distillate oil to 15 ppm by 2016; and c 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 b y weight (500 ppm) by no later than 2014, o #4 residual oil to 0.25 percent - 0.50 percent sulfur by weight b y no later than 2018, o #6 residual oil to no greater than 0.5 percent sulfur by weight by

no later than 2018, and o Further reduce the sulfur content of distillate oil to 15 ppm by 2018 depending on suppl y and availability ; and d A 90 percent or greater reduction in SO 2 emissions f rom each of the 167 EGU stacks identified by

MANE - VU 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 e Continued evaluation of other control measures including energy efficiency, alternative clean fuels, and other measures to reduce SO 2 and NO x emissions from all coal - burning facilities by 2018 and new source performance standards for wood combustion. This long - term strategy

to reduce and prevent regional haze will lead each state to pursue adoption and implementation of reasonable and cost - effective NO x and SO 2 control measures as appropriate and necessary . While some measures that states pursue may not represent enforceable commitments immediately , they

may become enforceable in the future as new laws are passed, rules are written, and facility permits are issued. Massachusetts will provide an update on the implementation of the strategies listed in the “Ask” in the 2013 mid - term review . This suite of additional control measures are those that the MANE - VU states have agreed to pursue for the purpose of mitigating regional haze . The corollary is that the MANE - VU Class Istates (Maine, New Hampshire, Vermont, and New Jersey) asked states outside of the MANE - VU region that contribute to visibility impairment inside the region to pursue similar measures . The control measures that non MANE - VU st ates choose to pursue may be directed toward the same emission source sectors identifiedPage 98

by MANE - VU for its own emission reductions, or they may be equivalent measures targeting other source sectors. **Best Available Retrofit Technology** Implementation of the BART provisions of the Regional Haze Rule [ 40 CFR 51.308(e) ] is one of the reasonable strategies included in this SI P. BART controls in Massachusetts are described in Section 8 of this SI P . A dditional emission reductions will occur at man y other BAR T - eligible facilities within MANE - VU as a result of controls achieved by other programs that serve as BART but are not s pecificall y identified as such (e.g., RACT control measures). While not specificall y identified as being attributable to BART, these a dditional emission reductions were full y accounted for in the 2018 CMAQ modeling. Additional visibility

benefits are likel y to result from installation of new emission controls at BART eligible facilities located in neighboring RPOs. However, the MANE - VU modeling did not account for BART controls in other RPOs and, consequently , did not include visibility improvements at MANE - VU Class IAreas that would be likely to accrue from such measures. **Low -**  **Sulfur Fuel Oil Strategy** The important assumption underlyin g MANE - VU’s low - sulfur fuel oil strategy is based on the production and use of home heating and fuel oils that contain 50% less sulfur for the heavier grades (#4 and #6 residual), and a minimum of 75% and a maximum of 99.25% less sulfur in #2 fuel oil (als o known as home heating oil, distillate, or diesel fuel) at an acceptably small increase in price to the end user. As much as three - fourths 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. The costs of these emission reductions are estimated at $550 to $750 per ton, as documented in the MANE - VU Reasonable Progress Report. Insome seasons and some locations, low - sulfur diesel is actuall y cheap er than regular diesel fuel. NESCAUM’s report, “Low Sulfur Heating Oil in the Northeast States: An Overview of Benefits, Costs, and Implementation I ssues,” December 2005 (Appendix Y ) notes that the incremental cost of low - sulfur (500 ppm) highway diesel f uel has averaged 1.5 cents per gallon more than the cost of heating oil over the past decade. However, an y increased cost would be more than offset b y the avoided maintenance costs resulting from the reduced rate of equipment fouling when using low - sulfur oil. A recent study

developed for the N ational Oilheat Research Alliance (NORA) 35 uses data from the U.S. Energy Information Administration to evaluate the potential for suppliers to bring 15 ppm sulfur content heating oil into widespread use in the Nor theast by 2018. While the study

acknowledges that additional refining capacit y is needed to meet the increased demand in 2018 and beyond, it concludes that, given appropriate advance notice, the refining industry can suppl y the necessary fuels with minima l market disruptions and price impacts. In the short - term, excess production capacity of ultra - low sulfur diesel (UL SD) exists in the region. In the longer term, the transition to UL SD in the transportation sector, combined with clear signals from regulatory agencies that similar requirements will be widespread for heating oil in the coming y ears, will support a move toward greater availability of 15 ppm sulfur content heating oil . 35 Ultra - low Sulfur Diesel Fuel/Heating Oil Market Study, Kevin J. Lindemer, LLC, prepared for the National Oilheat Research Alliance, April 2010 ( http://www.nora - oilheat.org/site20/uploads/lowsstudy.pdf ).Page 99

The study projects a wholesale price differential between ULSD and high er sulfur heating oil of 1 - 3 cents per gallon, suggesting that the incremental cost of providing 15 ppm sulfur content heating oil will not be significant compared to normal price fluctuations. T he study also notes that the incremental cost to consumers w ill be more than offset by cost saving s associated with lower maintenance costs and higher fuel e fficienc y . For example, a ty pical consumer who uses 800 gallons of fuel per y ear would spend an additional $24 per year if per - gallon fuel costs increased b y $0.03. However, the same consumer could expect to save approximately $50 per y ear in avoided maintenance costs (cleaner fuel reduces the frequency

with which equipment must be serviced) and another $50 in avoided fuel costs from higher efficiency . This i s because existing equipment generall y operates more efficientl y with lower sulfur fuels, so less fuel is required to produce the same amount of heat; even larger efficiency gains are possible using newer furnaces specifically designed to use lower sulfur fuels. The sulfur content of residual fuel oils burned b y power plants and other large sources also can be cost effectivel y reduced. Residual oil is a byproduct of the refining process, and is produced in several grades that can be blended to meet a spec ified fuel sulfur content limit. In April 2011, MANE - VU published an Addendum to its 2007 “Assessment of Reasonable Progress” Report that evaluated residual oil ( Appendix T - 1 ) . The report averaged monthly price averages to compute annual prices and price differentials in cents per gallon for the ye ars 2006

– 2009. For these ye ars in the Northeast, lower sulfur No. 6 residual oil ( ≤ 1%) ranged from 8.9 to 12.9 cents per gallon more than higher sulfur No. 6 residual oil (> 1%). The additional expense wou ld be at least partially offset by reduced maintenance costs with the use of lower sulfur oil. Lo w sulfur oil is cleaner burning and emits less particulate matter than higher sulfur oil; this reduces the rate of fouling of heating units substantially and permits longer time intervals between cleanings. The decreased deposits also would enable a more efficient transfer of heat, thereb y reducing fuel use. Thus, there are potential costs savings for switching to lower sulfur residual oil. Reducing the sulfur content of residual fuel is a cost - effective SO 2 reduction strategy ; a simple calculation using a price differential of $0.089

– $0.129 suggests that a 78% reduction in SO 2 emissions (by converting from 2.2 percent to 0.5 percent sulfur residual oil) is achievable at an approximate cost of $800 - $1,100 per ton of SO 2 removed. This cost per ton removal compares favorabl y to the costs of other pollution controls ty pically required b y environmental agencies and is well within the range considered to be cos t - effective for SO 2 reductions . While the costs of the low - sulfur oil strategy will vary depending on market conditions, they are reasonable when compared to the costs of controlling other sectors . Importantly , a January 2008 Public Health Benefits stud y prepared b y NESCAUM shows that the low - sulfur fuel strategy will result in billions of dollars in public health benefits for the region (see Appendix AA). Controlling the fuel sulfur content to 500 ppm leads to health benefits of almost 3.4 billion dollars in MANE - VU and controlling the fuel - sulfur content to 15 ppm could lead to an additional 431 million dollars in benefits, bringing the total benefits to 3.7 billion dollars. The MANE - VU states agreed through consultations to pursue a low - sulfur fuel oi l strategy within the region. The MANE - VU low - sulfur fuel strategy will be implemented in two phases; however, both components of the strategy are to be fully

implemented by

2018. The first phase of the MANE - VU low sulfur fuel strategy

requires the lower ing of fuel sulfur content in distillate ( #1 and #2 oil) from current levels that range between 2,000 and 2,300 ppm down to 500 ppm . The second phase of the strategy further reduces the fuel - sulfur content of the distillate fractio n to 15 ppm sulfur. It also requires the lowering of sulfur content in residual oil to 0.5 percent sulfur b y weight .Page 100

The two phases of the MANE - VU low - sulfur fuel strategy are to be implemented in sequence with slightly different timing for an “inner zone” 36 and the remainder of MANE - VU. All MANE - VU states have agreed that a low - sulfur oil strategy is reasonable to pursue b y 2018 as appropriate and necessary. Based on the fuel sulfur limits within the first phase of the strategy, MANE - VU estimated a decrease of 140,000 tons of SO 2 emitted from distillate combustion and a decrease of 40 ,000 tons of SO 2 from residual combustion in MANE - VU. In the second phase in which distillate fuel sulfur limits are lowered from 500 ppm to 15 ppm, MANE - VU estimate d an additional reduction of 27 ,000 tons of SO 2 emissions in MANE - VU in 2018. Figure 4 0 shows the combined impact of both phases of the MANE - VU low - sulfur fuel strategy relative to the On The Books/On The Way baseline. NESCAUM used the concentration changes illustrated in Figure 4 0 t o estimate the visibility benefits for this strategy . Because the fuel sulfur program only affects sources within MANE - VU, that region sees the largest PM 2.5 reduction and the greatest visibility benefits. Massachusetts commits to pursue the implementati on of the low sulfur fuel strategy with 500 ppm percent sulfur b y weight for distillate oil and 1.0% sulfur by weight for residual oils by 2014, with further respective reductions to 15 ppm and 0.5% by 2018. Massachusetts plans to amend 310 CMR 7.05: Fuel s to incorporate these limits as part of this SI P .

36 The inner zone includes New Jersey, Delaware, New York City, and potentially portions of eastern Pennsylvania.Page 101

**Figure 40**  **: Average Change in 24 -**  **hr PM 2.5**  **Due to Low Sulfur Fuel Strategies Relative to OTB/OTW (**   **g/m 3**  **)**

**T argeted**  **EGU Strategy** SO 2 emissions from power plants ( electric generating units or EGUs) are the single largest sector contributing to the visibility impairment experienced in the Northeast’s Class I areas. The SO 2 emissions from power plants c ontinue to dominate the inventory . Sulfate formed through atmospheric processes from SO 2 emissions are responsible for over half the mass and approximately 70 - 80 percent of the light extinction on the worst visibility day s (Contribution Assessment, Append ix A ). In order to properl y target controls on EGUs, modeling was conducted to identify those EGUs with the greatest impact on visibility in MANE - VU. A list was developed that includes the 100 largest impacts at each MANE - VU Class Isite during 2002. These emissions were from 167 EGU stacks and are illustrated below (a complete list can be found in Appendix W ; see Appendix A ). Some of the stacks identified as impo rtant were outside the states identified as contributing at least 2 percent of the sulfate at MANE - VU Class I areas and were dropped from the list. Massachusetts sources identified in the list include Bray

ton Point, Canal Station , Mount Tom, Salem Harbor, and Somerset Station . Given the magnitude of their potential impact, controlling emissions from these stacks is important to improving visibility at MANE - VU Class Iareas.Page 102

MANE - VU’s agreed to regional approach for the EGU sector is to pursue a 90 perce nt reduction in SO 2 emissions ( from 2002 emissions ) from these 167 targeted stacks by 2018 as appropriate and necessary . MANE - VU concluded that pursuing this level of sulfur reduction is both reasonable and cost - effective. Even though current wet scrubbe r 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 SO 2 emissions reductions will vary b y unit, and the MANE - VU Reasonable Progress report (Appendix T ) summarizes the various control methods and costs available, ranging from $170 to $5,700 per ton, depending on site - specific factors such as the size and ty pe of unit, combustion technology , and t ype of fuel used.

**Figure 41**  **: 167 Targeted**  **EGU Stacks Affecting MANE -**  **VU Class I Areas**

To evaluate the impact of reducing emissions from the 167 EGU stacks, NESCAUM used CMAQ to model sulfate concentrations in 2018 after implementation of this co ntrol program. 2018 SO 2 emissions for these stacks were modeled at levels equal to 10 percent of their 2002 SO 2 emissions; sulfate concentrations were then converted to PM 2.5 concentrations. This preliminary modeling showed that requiring SO 2 emissions f rom the 167 EGU stacks to be reduced by 90 percent from 2002 emission levels could reduce 24 - hour PM 2.5 concentrations. Figure 43 shows the reduction in fine particle pollution in the Eastern U.S. that would result from implementing the targeted EGU SO 2 s trategy . Improvements in PM 2.5 concentrations would occur throughout the MANE - VU region as well as for portions of the VI STAS and Midwest RPO regions, especiall y the Ohio River Valley.Page 103

**Figure 42**  **: Average Change in 24 -**  **hr PM 2.5**  **due t o 90 Percent Reduction in SO**  **2 Emissions from 167**  **EGU Stacks Affecting MANE -**  **VU**

Although the reductions are potentiall y large, MANE - VU determined, after consultation with affected states, that it was unreasonable to expect that the full 90 - percent reductio n in SO 2 emissions would be achieved b y 2018. Therefore, additional modeling was conducted to assess the more realistic scenario in which emissions would be controlled b y the individual facilities and/or states to levels alread y projected to take place b y that date. At some facilities, the actual emission reductions are anticipated to be greater or less than the 90 percent benchmark. For details, see Appendix W “ Documentation of 2018 Emissions from Electric Generating Units i n the Eastern United States for MANE- VU’s Regional Haze Modeling .” Massachusetts has five sources with a total of 10 EGUs on the 167 Stacks list , including Brayton Point (units 1 - 3), Canal Station (units 1 - 2), Mount Tom (unit 1), Salem Harbor (units 1, 3, 4), and Somerset Station (unit 8) **Error! Reference source not found.** . Each of these facilities is subject to MassDEP’s 310 CMR 7.29, which limits SO 2 emissions facility - wide . Several stacks at Massachusetts sources alread y have install ed SO 2 controls or are planning additional SO 2 controls to help them meet 310 CMR 7.29 limits. Bra yt on Point has install ed SDA on Units 1 and 2 and will be installing and operating an SDA on Unit 3 by 2014 , and M ount Tom has install ed a dry scrubber and baghouse . Salem Harbor is currently using low - sulfur coal to meet its 310 CMR 7.29 limits but plans to shut down all units by June 201 4 . S omerset Station has shut down. MassDEP originall y proposed to rel y on EPA’s draft Transport Rule to meet the Targeted EGU stra tegy . However, because Massachusetts is not included in EPA’s final Cross - State Air Pollution Rule, MassDEP still must address this commitment. Therefore, MassDEP intends to propose a revised Targeted EGU strategy

in February

2012 and submit a final strategy to EPA in June 2012 .Page 104

Several states have implemented state - specific EGU emission reduction programs. These commitments, identified below, are included in the long - term strategy as reasonable measures to meet MANE - VU’ s reasonable progress goals and were used in the Best and Final 2018 CMAQ modeling (Appendix G ). Maryland Healthy

Air Act : Maryland adopted the following requirements governing EGU emissions: 1. For NOx: a. Phase I (2009): Sets unit - specific annua l caps (totaling 20,216 tons) and ozone season caps (totaling 8,900 tons). b. Phase II (2012): Sets unit - specific annual caps (totaling 16,667 tons) and ozone season caps (totaling 7,337 tons). 2. For SO 2 : a. Phase I (2010): Sets unit - specific annual caps (totaling 48,818 tons). b. Phase II (2013): Sets unit - specific annual caps (totaling 37,235 tons). 3. For mercury : a. Phase I (2010): 12 - month rolling average of a minimum of 80% removal efficiency . b. Phase II (2013): 12 - month rolling average of a minimum of 90% removal effic iency . The specific EGUs covered are: Brandon Shores (Units 1 and 2), C.P.Crane (Units 1 and 2), Chalk Point (Units 1, and 2), Dickerson (Units 1, 2, and 3), H.A. Wagner (Units 2 and 3) Morgantown (Units 1 and 2) and R. Paul Smith (Units 3 and 4). No out - of - state trading, no inter - company trading, and no banking from y ear to y ear is permitted . New Hampshire EGU Regulations : New Hampshire adopted the following regulations governing EGU emissions: Chapter Env - A 2900 requires the installation of scrubbers on Merrimack Station (Units 1 and 2) by July 1, 2013 to control SO 2 and mercury emissions with state - level SO 2 credits for over - or early compliance. New Jersey

Hg MACT Rule : All coal - fired EGUs must have a mercury removal efficiency

of 90%. Consent Agr eements in the VISTAS region : The impacts of the additional following consent agreements in the VI STAS states were reflected in the emissions inventory used for those states:

 EKPC: A July

2, 2007 consent agreement between EPA and East Kentucky Power Coop erative requires the utility to reduce its emissions of SO 2 by 54,000 tons per y ear and its emissions of NO x by

8,000 tons per y ear by

installing and operating selective catal yt ic reduction (SCR) technology , low - NOx burners, and PM and mercury Continuous E missions Monitors at the utility ’s Spurlock, Dale and Cooper Plants. According to EPA, total emissions from the plants will decrease between 50 and 75 percent from 2005 levels. As with all federal consent decrees, EKPC is precluded from using reductions required under other programs, such as CAIR, to meet the reduction requirements of the consent decree. EKPC is expected to spend $654 million to install pollution controls.

 AEP: American Electric Power agreed to spend $4.6 billion dollars to eliminate 72, 000 tons of NO x emissions each ye ar b y 2016 and 174,000 tons of SO 2 emissions each y ear b y 2018 from sixteen plants located in Indiana, Kentucky , Ohio, Virginia, and West Virginia.Page 105

**10.6.** 

### Source Retirement and **Replacement Schedules**  40 CFR Section 51.308(d)(3)( v)(D) requires Massachusetts 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 Appendix N , Appendix B - 5 . **10.7.** 

### Measures to Mitigate the Impacts of Construction Activities 40 CFR Section 51.308(d)(3)(v)(B) requires States 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 document entitled, Technical Support Document on Measures to Mitigate the Visibility Impacts of Construction Activities in the MANE- VU Region (Appendix X ). The following statements summarize the main points of this technical support document:  Although a temporary source, fugitive dust and diesel emissions from construction activities can affect local air quality .  While construction activities are responsible for a relativel y large fraction of direct PM 2.5 and PM 10 emissions in the region, the contribution of construction activities to reduced visibility is much smaller because dust settles out of the air relatively close to the sources.  Ambient air quality

data sh ows that soil dust makes up only a minor fraction of the PM 2.5 measured in MANE - VU Class Iareas. Further more , the impacts of diesel emissions in these rural areas are a small part of the total PM 2.5 .  The use of measures such as clean fuels, retrofit technology , best available technology , specialized permits, and truck staging areas (to limit the a dv erse impacts of idling) can help decrease the effects of diesel emissions on local air quality .  MANE - VU states have rules in place to mitigate potential impact s of construction activities on visibility in Class Iareas. MassDEP requires contractors working on certain state - financed projects to install retrofit pollution controls in thei r construction equipment engines. In addition, Massachusetts regulation 310 CMR 7.09 regulates dust from construction and demolition activities. 7.09(3) states, “No person responsible for an area where construction or demolition has taken place shall cause, suffer, allow, or permit particulate emissions therefrom to cause or contribute to a condition of air pollution...” Furthermore, the construction or demolition of large buildings requires a written notification to MassDEP ten working day s prior to operations. Due to the lower visibility impact of particulate matter from Massachusetts at Class Iareas (relative to SO 2 and NO x emissions), Mass DEP concludes that its regulations are currently sufficient to mitigate the impacts of construction activit i es. **10.8.** 

### Agricultural and Forestry Smoke Management 40 CFR Section 51.308(d)(3)(v)(E) re quires States to consider smoke management techniques for the purposes of agricultural and forestry management. A description of MANE - VU’s anal ys is of smoke management in the context of Regional Haze SIP s can be found in the MANE - VU Smoke Management TSD e ntitled, “ Technical Support Document on Agricultural and Forestry Smoke Management in the MANE- VU Region ” (Appendix Q ). This technical support document concluded that Smoke Management Programs (SMPs) are onl y required when smoke impacts from fires managed for resource benefits contribute significantl y to regional haze. Massachusetts does not currentl y have a smoke management program. The results of thePage 106

emissions inventory

indicate that emissions from agricultural, managed, and prescribed burning are very minor source categories (totaling 1.34% of PM 2.5 emissions in the MANE - VU region). Source apportionment results show that wood smoke is a moderate contributor to visibility impairment at some Class Iareas in the MANE - VU region; however, smoke is not an especiall y important contributor to MANE - VU Class I areas on either the 20% best or 20% worst visibility day s. Most of the wood smoke is attributable to residential wood combustion and it is unlikely that fires for agricultural or forestry management caus e large impacts on visibility in any of the Class I areas in the MANE - VU region. On rare occasions, smoke from major fires degrades the air qualit y and visibility in the MANE - VU area. However, these fires are generall y unwanted wildfires that are not subj ect to SMPs. MassDEP’s air regulations in clude 310 CMR 7.00, which bans open burning entirely in 22 urban municipalities and prohibits the use of open burning to clear commercial or institutional land for non agricultural purposes. Burning for “activiti es associated with the normal pursuit of agriculture” and the open burning of brush and debris between January 14 and April 30, “except during periods of a dv erse meteorological conditions,” are currently allowed. Prescribed burning also is allowed under 3 10 CMR 7.07(3)(f) upon specific permission from MassDEP. Massachusetts considers these efforts to be sufficient to protect visibility in the Class I areas affected by emissions from Massachusetts sources, including agricultural and forestry smoke. **Regulat ion of Outdoor Hydronic Heaters**  On December 26, 2008, Mass DEP finalized new regulations, 310 CMR 7.26(50) through (54), to control emissions from outdoor hy dronic heaters (OHHs, also known as outdoor wood - fired boilers or OWBs) , which are included in Appen dix CC as part of this SIP . The regulations are based in part on a NESCAUM model rule developed in January 2007 and have requirements for manufacturers, sellers, and owners of OHHs. Manufacturers must meet stringent performance standards in order to sell OHHs in Massachusetts. The Phase I emission standard is 0.44 lb/MMBtu for units sold after October 1, 2008, and th e Phase II emission standard is 0.32 lb/MMBtu for units sold after March 31, 2010. Owners of current and new OHHs are subject to regulation s regarding the operation of their OHHs. Massachusetts concludes that adoption of these proposed regulations will reduce future smoke and particulate emissions from OHHs. **10.9.** 

### Estimated Impacts of Long **- Term Strategy on Visibility**  Preliminary

modeling was conduc ted to estimate the impact of various elements of the MANE - VU “Ask.” This modeling is described in NESCAUM’s report entitled MANE- VU Modeling for Reasonable Progress Goals (Appendix F ). NESCAUM also conducted additional revised modeling to assess combined impacts. This modeling is described in NESCAUM’s report entitled 2018 Visibility Projections (Appendix G ). The following information about the effects of specific strategies is taken from those reports. As with all modeling, emissions estimates and modeling results for 2018 entail uncertaint y, and further evaluation may be conducted as part of the progress report required in five years under 40 CFR Section 51.308( g). **Additional Measures Included in Best and Final Modeling** In addition to the measures described in Section 10. 5 ( BART controls within MANE - VU, low - sulfur fuel within MANE - VU, and controls on specific EGUs), MANE - VU asked neighboring RPOs to consider further non - EGU emissions reductions comparable to those achieved through MANE - VU’s low - sulfur fuel strategies. Prior modeling indicated that the MANE - VU low - sulfur fuel strategy isPage 107

expected to achieve a greater than 28 percent reduction in non - EGU SO 2 emissi ons in 2018. After consultation with other states and consideration of comments received, the MANE - VU Class I s tates decided that the Best and Final modeling would include implementation of measures to match MANE VU’s 28 percent reduction in non - EGU SO 2 e missions in the VI STAS and MRPO regions. In order to model the impact of this strategy on visibility

at MANE - VU Class I areas, additional emissions reductions in the VISTAS and MRPO states were assumed to occur, resulting in a modeled 28 percent reduction in non - EGU SO 2 emissions in those regions. These reductions include: For both Southeast and Midwest States: Coal - Fired IC I Boilers: emissions were reduced by 60 percent Oil - Fired IC I boilers: emissions were reduced b y 75 percent IC I Boilers lacking fu el specification: emissions were reduced by 50 percent Additional controls only

in the Southeast States: Emissions from Other Area Oil - Combustion sources were reduced b y 75 percent (Used the same SCCs identified in MANE - VU Oil strategies list.) In additi on, NESCAUM removed SO 2 emissions from 6500 MW of six coal - burning EGUs in Canada that are scheduled to be shut down for the Best and Final Modeling. 37 It is expected that these units will be replaced with nine natural gas turbine units with selective cata ly tic reduction controls. NESCAUM based estimated emission rates for modeled pollutants on a combination of factors, including recommendations from the State of New Hampshire, a NYSERDA stud y, and AP - 42 ratios among pollutants. Emissions were reduced b y more than 144,000 tons per y ear as a result of this measure. **Visibility Impacts of Additional Reasonable Controls from Best and Final Modeling** 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 starting point for indicating progress achieved b y measures included 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 day s in each ye ar were averaged together, producing a single average deciview value for the best day s. Similarly , the d eciview values for the 20 percent worst day s in each y ear were averaged together, producing a single average deciview value for the worst day s. Initial modeling (Appendix F ) was then performed to identify reas onable progress goals. Results of this modeling showed that sulfate aerosol

– the dominant contributor to visibility impairment in the Northeast’s Class I areas on the 20 percent worst visibility day s – has significant contributions from states in all thr ee of the eastern RPOs. These emissions are projected to continue in future y ears. An assessment of potential control measures identified a number of promising strategies, including the adoption of a low - sulfur fuel oil strategy , the implementation of BA RT requirements, and additional controls on select EGUs, as well as a 28 percent reduction in non - EGU SO 2 emissions in VI STAS and MRPO states. These strategies were predicted to yield significant visibility benefits beyond the uniform rate of progress and , in fact, significantly bey ond the projected visibility conditions that would result from “on the books/on the way ” air qualit y protection programs.

37 NESCAUM’s 2018 Visibility Projections report cited a November 2006 paper by the Ontario Pow er Authority, “Ontario’s Integrated pow er System Plan Discussion Paper 7: Integrating the Elements

—A Preliminary Plan. See http://www.powerauthority.on.ca/ipsp/Storage/32/2734_DP7_IntegratingTheElements.pdfPage 108

NESCAUM conducted modeling for MANE - VU to document the impacts of the long - term strategy on visibility at affected Class Iareas. This “Best and Final” modeling is documented in the report 2018 Visibility Projections (Appendix G ), and estimates the composite visibility benefits of all strategies within and outside MANE - VU. Emissions inventory adjustments we re made for this modeling in order to better represent the likely outcome of efforts to pursue the BART, low - sulfur oil , and EGU control measures included in the MANE - VU June 20, 2007 statements. Figure 43 to Figure 4 6 illustrate the predicted visibility improvement by 2018 resulting from the implementation of the MANE - VU regional long - term strategy (the short green line above the y ear 2018). This improvement is compared to the Uniform Rate of Progress for affected Class I areas (shown as the diagonal purple line). No degradation is represented b y the dashed line, blue dots at the upper left indicate the 20 percent worst observed visibility day s, and the pink line at bottom left indicate the 20 percent best observed visibility day s. All MANE - VU sites ar e projected to meet or exceed the uniform rate of progress for 2018. Inaddition, no site anticipates increases in best - day visibility relative to the baseline. **Figure 43**  **: Projected Visibility Improvement at Acadia National Park B ased**  **o n 2018**  **Visibility Projections** Page 109

**Figure 44**  **: Projected Visibility Improvement at Great Gulf Wilderness Area Based on 2018**  **Visibility Modeling**  38

**Figure 45**  **: Projected Visibility Improvement at Lye Brook Wilderness Area Based on**  **2018 Visibility**  **Modeling**

38 The estimate for Great Gulf Wilderness Area also serves to provide an estimate for the Presidential Range/Dry River Wilderness AreaPage 110

**Figure 46**  **: Projected Visibility Improvement at Moosehorn Wilderness Area Based on 2018**  **Visibility Modeling**  39

**10.10.** 

### Massachusetts’ Share of Emissions Reduction 40 CFR Section 51.308 (d)(3)(ii) requires states to demonstrate that its implementation plan includes all measures necessary

to obtain its share of emission reductions needed to meet reasonable progress goals. The control measures included in this SI P represent the contributio n of Massachusetts towards achieving the reasonable progress goals of Class Istates by 2018. Table 8 in Section 6.8 shows that Massachusetts’ overall projected reduction of total regional haze pollutants between 2002 and 2018 is 31 percent. This is closely comparable to MANE - VU’s overall reduction of 29 percent for the same period. In addition, MANE - VU modeling demonstrates that Massachusetts’ long - term strategy , when coordinated with other states’ strategies as defined by th e MANE - VU statement, is sufficient to meet the reasonable progress goals of Class Istates. Thus, M assachusetts is contributing its share of emissions reductions needed to meet r easonable pr ogress g oals. The MANE - VU statement of June 20, 2007 provided th at each state will have up to 10 years to pursue adoption and implementation of reasonable NO x and SO 2 control measures as appropriate and necessary . This SI P is consistent with that statement. **10.11.** 

### Emission Limitations and Compliance **Schedules** 40 CFR 51.308(d )(3)(v)(C) requires Massachusetts to consider emission limitations and compliance schedules to achieve reasonable progress goals. Emission limitations and compliance schedules are

39 The estimate for Moo sehorn Wilderness Area also serves to provide an estimate for Roosevelt/Campobello International Park.Page 111

alread y in place for the Massachusetts programs outlined in Subsection 10 . 4 . MassDEP intends to amend 310 CMR 7.05: Fuels to establish emissions limitations and comp liance schedules for the low sulfur fuel oil strategy

consistent with the MANE - VU Ask. MassDEP will establish emissions limitations and compliance schedules for Wh eelabrator

– Saugus that will require implementation of BART and/or NO x RACT by July 201 2 . In earl y 2012, MassDEP intends to re - propose BART or an alternative to BART and a Targeted EGU Strategy that will address emissions limitations and compliance sched

ules for the BART - eligible EGU sources and Targeted EGUs. All emissions limitations will be in place by 2018 in order to achieve the reasonable progress goals. MassDEP will provide a status update on emissions limitations and compliance schedules in the 2013 regional haze SIP progress report. **10.12.** 

### Enforceability of Emission Limitations and Control Measures 40 CFR 51.308(d)(3)(v)(F) requires Massachusetts to consider the enforceability of emission s limitations and control measures. E missions reductions due to ongoing air pollution controls described in Section 10.4 are or will be enforceable b y 2018. For the additional reasonable strategies identified above , MassDEP alread y p romulgated new regulations, 310 CMR 7.26(50) through (54), to control emissions from outdoor hy dronic heaters , and includes these regulations in this SIP . MassDEP intends to propose regulatory

revisions to 310 CMR 7.05 in 201 2 to implement the low sulfur fuel strategy in accordance with the MANE - VU Statement , and will submit final regulat ions to EPA as a SI P revision . For the BART determination for Wheelabrator

– Saugus, the emissions limitation reflecting BART and/or NO x RACT will be incorporated into the facility ’s permit in 2012 to make it enforceable . **10.13.** 

### Prevention of Significant Deterior **ation** The Prevention of Significant Deterioration (PSD) program appli es to all new major stationary sources (or existing major stationary sources making a major modification) located in an area that is in attainment or is unclassified for a pollutant with a NAAQS . A major source is an emissions source that has the potential to emit more than 100 tons per year of a regulated pollutant in a listed category or 250 tons per y ear in any

other category . One of the intentions of the PSD program is to protect air quality in national parks, wilderness areas, and other areas of special natural, scenic, or historic value. The PSD permitting process requires a technical air qualit y anal ys is and additional analy ses to assess the potential impacts on soils, vegetation and visibility at Class I areas. MassDEP accepted delegation of the federal PSD program in 1982. In 2003, consistent with its delegation agreement, MassDEP returned the program to EPA and EPA Region I assumed the responsibility

for issuing PSD permits f or Massachusetts facilities. InApril 2011 , MassDEP took back delegation of the PSD program, and is developing state regulatory adoption of the PSD program for inclusion in the federall y enforceable Massachusetts State Implementation Plan. In addition, MassDEP has retained its state new source review program, which permits new and modified sources of emissions under 310 CMR 7.02

– Plan Approval and Emission L imitations. This regulation requires Best Available Control Technology (BACT) for all pollutant emissions and a determination that the new or modified source will not cause or contribute to a violation of a NAAQS. Depending upon the specific pollutant, the new or modified source also may be subject to non atta i nment review under 310 CMR 7.00 Appendi x A

– Emissions Offsets and Non - Attainment Review , which requires Lowest Achievable Emissions Rate (LAER).