### McConnell, Robert From: Sent: To: Cc: Subject: Attachments:BobJanelle , Fe li ce <Felice.Janelle@des
. nh.gov> Tuesday , December 29 , 2015 3 : 18 PM McConnell, Robert Roberge , Michele; Arnold, Anne RE : Withdrawal of visibility portion from section 110(a)(2)(J) of NH i-SIPs 12-29-201 SAttachments.pdf

1 have a me nded the orig i nal documents. It is a more co ncise representation of the changes we made. (attached) Regards, Felice 

### From: McConnell, Robert [mailto:mcconnell.robert@epa.gov] 

### Sent: Tuesday, December 29, 2015 2:18 PM To: Janelle, Felice Cc: Roberge, Michele; Arnold, Anne Subject: FW: Withdrawal of visibility portion from section 110(a)(2)(J) of NH i-SIPs Felice - just confirming that the words, "and visibi l ity protection" should be struck from the three referenced submittals, as I ' ve shown i n strike-out in this attachment. If you could confirm for me that's . the case, we should be all set. Thanks, Bob McConnell, Environmental Engineer Air Quality Planning Unit US EPA, Region 1 Boston, Massachusetts 617-918-1046 From: Roberge, Michele [mailto : Michele.Roberge@des.nh
. gov] Sent: Tuesday, December 29, 2015 11:23 AM To: McConnell, Robert <mccon nell. rob ert @epa.gov> Cc: Dahl, Donald <dah l.donald@epa .gov >; Conroy, David <Conroy.Dave@epa.gov>; Curley, Michael <Curley . M ichael@epa.gov> Subject: RE: Withdrawal of visibility portion from section 110(a)(2)(J) of NH i-SIPs Bob, Attached is a letter withdrawing the visibility portion of NH's 2008 03, 2010 N02 and 2010 502 I-SIP submittals . If you have any qu estions, please give me a call at the number below. Thanks for your help . Best regards, Michele Michele J. Roberge SIP Planning Administrator 1NH Department ofEnvironmental Services Air Resources Division 29 Hazen Drive PO Box 95 Concord, New Hampshire 03302 - 0095 Phone: (603} 271-6793 Email: Mich ele. Rober g e@des
. nh. g ov
From: McConnell, Robert [ mailto:mcconnell . robert@epa.gov] Sent: Tuesday, December 08, 2015 9:16 AM To: Roberge, Michele Cc: Oahl, Donald; Conroy, David; Curley, Michael Subject: Withdrawal of visibility porti on from section 110(a)(2)(J) of NH i-SIPs Michele - as discussed, we suggest that New Hampshire withd .raw the visibility portion of its i-SIP submittals made to address EPA's 2008 ozone, 2010 N02, and 2010 S02 NAAQS. (New Hampshire did not make a submittal for this sub-element within its i-SIP for EPA's 2008 lead NAAQS). The visibility require111ents fall under section 11 O(a)(2)(J), but EPA' s guidance indicates that no requirements come due pursuant to this provision when EPA revises a NAAQS. However, since NH made a submittal for this sub - element within the i-SIPs mentioned above, EPA is obligated to act on that**s~bmission** unless it is withdrawn by the state . Here's language you could use in a withdrawal letter : In acknowledgement of the fact that EPA's September 13, 2013 guidance to states regarding i - SIPs does not require states to make SIP submittals to address the visibility provisions found at section 11 O(a)(2)(J) of the Clean Air Act, New Hampshire requests withdrawal of the submittals made to address this aspect of 11 O(a)(2)(J) within the following infrastructure SIP submittals: 1 . 2008 ozone NAAQS submittal dated 12/3112012, wherein on page 11 of 13 reference is made

. regarding visibility protection in several areas under the heading, " Subparagraph 110(a)(2)(J):

PSD and Visibility Protection" ; 2. 2010 N02 NAAQS submittal dated 1/28/2013 , wherein on page 10 of 12 reference is made regarding visibility protection in several areas under the heading , "Subparagraph 110(a)(2)(J): PSD and Visibility Protection " ; and, 3. 2010 S02 NAAQS submittal dated 9/13/2013 , wherein on page 13 of 45 reference is made regarding visibility protection in several areas under the heading, "Subparagraph 11 O(a)(2)(J): PSD and Visibility Protection". If you attach to the withdrawal letter replacement pages that have these references to visibility protection struck, that should take care of things. Thanks, and let me know if you have any questions, Bob McConnell, Env i ronmenta l Engineer Air Quality Planning Unit US EPA, Reg io n 1 Boston, Massachus etts 617-918-1046
2Page 11of1 3

.... Subparagraph 110(a)(2)(J): PSD aed Visibility Preteetien 

### CAA Citation: "Each such plan shall ...meet the applicable requiremen ts of. ..part C (relating to prevention of significant deterioration of air quality and visibility protection); ... " 

### Applicable NH Laws and 

### Regulations: • RSA 125 : 81 , XIV (recodified as RSA 125-C:6, XIV) authorizes the agency to establish and operate a statewide system under which permits shall be required for the construction and operation of new and modified stationary sources. • Env-A 619: Prevention of S ignific ant Deterioration addresses PSD and ¥isibility proteetioft and is essential to meeting the requiremen ts of40 CFR 51.166 and 40 CFR 52.21. 

### Additional Information: Revisions to Env-A 619 (and Env -A 100: Organizational Rul es) pertaining to the regulation of greenhouse gases were approved by EPA in a final rule published on Februa ry 6 , 2012 . (See 77 FR 5700 . ) Subsequent revisions to Env-A 619 w ere submitted as a SIP revision for EPA's approval on November 15 , 2012 .

. .... Subparagraph 110(a)(2 )(K): Air Quality Modeling/Data**·~------ ------~**  CAA Citation: "Each such plan shall ... "provide for
- (i) the performance of such air quality modeling as the Administrator may prescribe for the purpose of predicting the effect on ambient air quality of any emissions of any air pollutant for which the Administrator has established a national ambient air quality standard, and (ii) the submission, upon request, of data related to such air quality modeling to the Administrator." 

### Applicable NH Laws and Regulations:**~** RSA 125 : 81 (recodified as RSA 125-C:6) authorizes the department to exercise general supervision of the administration and enforcement of the statute and all rules adopted and orders promulgated under it; to develop a comprehensive program and p rovide services for the study , prevention , and abatement of air pollution; to conduct and encourage studies relating to air quality; to collect and disseminate the results of studies relating to air quality ; to advise, consult, and cooperate with the cities and towns and other agenci es of the state, federal gover nment, interstat e agencies, and other affected agencies or groups in matters relating to air quality; and , among other authorities, to exercise all incidental pow ers necessary to carry ou t the purposes of the statute. • Env-A 613 .02: Denial of Permit Issuance authorizes NHDES to deny the issuance of a construction permit if modeling shows that a major source proposing to construct or make modific ations in a nonattainment area will cause or contribute to a vi olation ofthe NAAQS for a pollutant for which that area is in attainment. • Env-A 619.03: PSD Program Requirements incorpora tes by reference numerous paragraphs of40 CFR 52.21, including (k)(l) , (l) , and (m), which require modeling by major sources prior to con struction or major modifications.

- 

## --- ------- ------------- --- -----

### --- - - --- - ..,.Subsection 110(a)(2)(J): P ublic Notification C AA C itation:

" E ach such plan shall ... meet the appl icable requ irements of .. . s ectio n 127 ( relati ng to public notification), ... " 

### Applicable NH Laws and Regulations: Page JO of 12

• RSA 125:8 1 (recodified as RSA 125
- C:6) provid e s as follows: ' ·Jn addition to the other powers and duties gran ted herein , the agency shall have and ma y exerci se the fo ll owi ng powers and duties: ... IV. To collect and d isseminate the results of studie s relating to air pollut i on; V . To advise , c o n sult, and cooperate w it h the cities and town s and other agencies of the state, federal government, interstate agencies, and oth er affected agencies or groups in matters relating to air pollution; VI. To encourage local units to promote coop eration by the people , political subdivi sio ns , industries , and o thers in preventing and contro lli ng air pollution in the state; . . . " 

### Additional Information: N02 and o th er oxides of nitrogen (NOx) are chemi cal precursors to ground -level ozone and presumed prec ursors to fine particle fo rm ation. On days when ambient ozone or PM2_s concentrations are predicted to be high, NHDES exercises the authority granted un der RSA 125:81 (reco di fi ed as RSA 1 25
- C:6) to issue public alerts. NHDES makes press releases and posts website notices advi sing people on how to h e lp prev ent air pollution and mi n imize the worst health eff ects ofpoor air quality. "Nln)ES is one ofthe state partners in EPA ' s AIRN OW and Enviroflash Air Quality Alert progr ams . (See www.airno\ .gO\. )



### ----------- ..,.Subsection 110(a)(2)(J): P S D aed Visibility Preteetiee CAA Citation :

" E ach such plan shall.. .meet the applicable requirements of ...part C (relating to prevention of significant deterioration of a ir qua lity and visibility protection) ; ... " 

### Applicable NH Laws and Regulations: • RS A 12 5:81 , XIV (recodi fied as R SA 1 25-C:6, XIV) aut horizes the agency to establish and operate a statewide sys t em under which p ermits shall be required for the construction an d operatio n of ne w and modified statio nary sources . • Env-A 619: Pre"ention of Significant Deter ioration addres se s PSD an d 

### •1 isibility proteetion and i s esse ntial to m eeting the requirements of 40 CFR S 1.166, 40 CFR 52.21 and RSA 125-C .**ubsection** 

### 110(a)(2) (K): 

### Air Quality M odeling/D ata



## - - CAA Citation:

" Each suc h plan shall . . . " provide for
- (i) the performan ce of such air quality mo deli ng as thePage 13 of45 people, political subdivisions , industries, and others in preventing and controlling air pollution in the state; ... "

1 

### Additional Information : 

## I S02 is a chemical precursor, and one of many known contributors , to fine

### rti~le (PM2. 5) pollution. On da ys when ambient PM2.s (or ozone) concentrations are predicted to be high, NHDES exercises the authority g rante d under RSA 

### 125:81 (recodified as .RSA 

### 125-C:6.) to issue public alerts. NHDES makes press releases and pos ts website notices advising people on how to help prevent air pollution and minimize the worst health effects ofpoor air quality . NHDE S is one of the state partners in EPA's AIRNOW and Enviroflash Air Quality Alert programs. (See .www .airnow.gov .. )



### -------------- 

## ----- --- ----- 

## ,------- --- --- ··--- - 

### --·- - 

### -- - 

### - ----- 

# l.... Subsection 110(a)(2)(J): PSD and**~~sihility Preteet~~**  

### __________ _ CAA Citation: "Each such plan shall ...meet the applicable requir ements of ...part C (relating to prevention of significant deterioration of air qualit y and visibility protection); ... " 

### Applicable NH Laws and Regulations: • RSA 

### 125:81, XIV (recodified as .RSA 

### 125-C:6., XIV ) authori zes the agency to establish and operate a statewide system under which pennits shall be required for the construction and operation ofnew and modified stationary sources . • Env-A 

### 619: Prevention of Si gnific an t D eteri oration. addresses PSD and •risibility proteetion and is essential to meeting the requirements of 

### .40 CFR 

### 51.166., .40 C FR 

### 52.21 . . and .RSA 

### 125-**~-·**



## --- - ------ 

# ,- ---·-----·--- 

### - - - -· - . ·-- -· - - · --- 

### -- 1 

### IJI. Subsection 110(a)(2)(K): Air Quality Modeling/Data

, CAA Citation:

"Each such plan shall. .. "provide for
- (i) the performance of such air quality modeling as the Administrator may prescribe for the purpose ofpredicting the effect on ambient air quality of any emissions of any air pollutant for which the Administrator has established a national ambient air quality standard, and (ii) the submission, upon request, of data related to such air quality modeling to the Administrator." 

### Applicable NH . Laws and Regulations: • RSA 

### 125:81 (recodified as .RSA 

### 125-C:6.) authorizes the department to exercise g eneral supervision ofthe administration and enforcement of the sta tu t e and all rules adopted and**rders** promulgated under it; to develop a comprehen s iv e p:ogram**~d** provide sei:ices for the _