VERMONT STATE IMPLEMENTATION PLAN (SIP)

REVISION

REGIONAL HAZE

STATE OF VERMONT

DEPARTMENT OF ENVIRONMENTAL CONSERVATION

JUNE 2009 
ii

TABLE OF CONTENTS

LIST OF FIGURES..................................................................................................................................................v

LIST OF TABLES................................................................................................................................................. vii

LIST OF ATTACHMENTS ................................................................................................................................ viii

ACKNOWLEDGMENTS.......................................................................................................................................ix

1. BACKGROUND ON REGIONAL HAZE IN THE LYE BROOK WILDERNESS..........................1

1.1 GENERAL BACKGROUND / HISTORY OF FEDERAL VISIBILITY RULES ..........................................................1

1.2 THE 1999 REGIONAL HAZE RULE ...............................................................................................................2

1.3 REGIONAL HAZE PLANNING AFTER THE VACATUR OF CAIR ......................................................................4

1.4 STATE IMPLEMENTATION PLAN REQUIREMENTS.........................................................................................7

1.5 THE BASICS OF HAZE ..................................................................................................................................8

1.6 ANATOMY OF REGIONAL HAZE.................................................................................................................10

1.7 THE LYE BROOK WILDERNESS AREA........................................................................................................12

1.8 MONITORING AND RECENT VISIBILITY TRENDS........................................................................................13

2. AREAS CONTRIBUTING TO REGIONAL HAZE ..........................................................................19

2.1 STATES CONTRIBUTING TO VISIBILITY IMPAIRMENT AT LYE BROOK........................................................22

2.2 OTHER CLASS I AREAS AFFECTED BY VERMONT EMISSIONS....................................................................23

3. REGIONAL PLANNING AND CONSULTATION ...........................................................................25

3.1 MID-ATLANTIC / NORTHEAST VISIBILITY UNION (MANE-VU) ...............................................................25

3.2 REGIONAL CONSULTATION AND THE MANE-VU “ASK”..........................................................................26

3.2.1 Vermont-Specific Consultations.......................................................................................................29

3.2.2 The MANE-VU “Ask”......................................................................................................................31

3.2.2.1 Meeting the “Ask” – MANE-VU States ................................................................................................ 31

3.2.2.2 Meeting the “Ask” – Vermont ................................................................................................................ 32

3.2.2.3 Meeting the “Ask” – States outside MANE-VU.................................................................................... 32

3.2.3 Technical Ramifications of Differing Approaches...........................................................................33

3.2.4 Consultation Issues ..........................................................................................................................34

3.2.5 State/Tribe and Federal Land Manager Coordination ....................................................................37

4. ASSESSMENT OF BASELINE AND NATURAL VISIBILITY CONDITIONS ............................39

4.1 CALCULATION METHODOLOGY.................................................................................................................40

4.2 MANE-VU BASELINE VISIBILITY ............................................................................................................41

4.3 LYE BROOK WILDERNESS BASELINE VISIBILITY ......................................................................................42

4.4 LYE BROOK WILDERNESS AREA – NATURAL BACKGROUND ....................................................................43

5. MONITORING STRATEGY................................................................................................................44

5.1 IMPROVE PROGRAM OBJECTIVES AND VERMONT MONITORING COMMITMENTS ...................................44

5.2 LYE BROOK WILDERNESS, VERMONT - MONITOR LOCATION ...................................................................45

5.3 LYE BROOK WILDERNESS MONITORING STRATEGY .................................................................................46

6. EMISSION INVENTORY.....................................................................................................................48

6.1 BASELINE AND FUTURE-YEAR EMISSIONS INVENTORIES FOR MODELING.................................................48

6.1.1 Baseline Inventory (2002)................................................................................................................49

6.1.2 Future-Year Emissions Inventories..................................................................................................50

6.2 EMISSION PROCESSOR SELECTION AND CONFIGURATION .........................................................................51

6.3 INVENTORIES FOR SPECIFIC SOURCE CATEGORIES....................................................................................51

6.3.1 Stationary Point Sources..................................................................................................................51

6.3.1.1 Electric Generating Units (EGUs) .......................................................................................................... 52

6.3.1.2 Non-EGU Point Sources......................................................................................................................... 52

6.3.2 Stationary Area Sources ..................................................................................................................53
iii

6.3.3 Non-Road Mobile Sources ...............................................................................................................53

6.3.4 On-Road Mobile Sources.................................................................................................................54

6.3.5 Biogenic Emission Sources ..............................................................................................................54

6.4 SUMMARY OF VERMONT EMISSIONS INVENTORIES ...................................................................................55

7. AIR QUALITY MODELING................................................................................................................57

7.1 METEOROLOGY.........................................................................................................................................58

7.2 DATA PREPARATION .................................................................................................................................59

7.3 MODEL PLATFORMS..................................................................................................................................59

7.3.1 CMAQ ..............................................................................................................................................61

7.3.2 REMSAD..........................................................................................................................................61

7.3.3 CALPUFF........................................................................................................................................61

7.4 REFERENCES FOR SECTION 7.....................................................................................................................62

8. UNDERSTANDING THE SOURCES OF HAZE-CAUSING POLLUTANTS ...............................63

8.1 FINE-PARTICLE POLLUTANTS....................................................................................................................63

8.2 CONTRIBUTING STATES AND REGIONS......................................................................................................64

8.3 EMISSION SOURCES AND CHARACTERISTICS.............................................................................................68

8.3.1 Sulfur Dioxide (SO2) ........................................................................................................................69

8.3.2 Volatile Organic Compounds (VOC)...............................................................................................70

8.3.3 Oxides of Nitrogen (NOX) ................................................................................................................72

8.3.4 Primary Particulate Matter (PM10 and PM2.5).................................................................................74

8.3.5 Ammonia Emissions (NH3)...............................................................................................................79

8.4 REFERENCES FOR SECTION 8.....................................................................................................................81

9. BEST AVAILABLE RETROFIT TECHNOLOGY (BART).............................................................83

9.1 BART-ELIGIBLE EGUS AND THE ROLE OF CAIR.......................................................................................84

10. REASONABLE PROGRESS GOALS .................................................................................................85

10.1 CALCULATION OF UNIFORM RATE OF PROGRESS ......................................................................................85

10.2 IDENTIFICATION OF (ADDITIONAL) REASONABLE CONTROL MEASURES ..................................................86

10.2.1 Rationale for Determining Reasonable Controls ........................................................................87

10.2.2 Best Available Retrofit Technology Controls..............................................................................89

10.2.3 Low-Sulfur Fuel Strategy ............................................................................................................90

10.2.4 Targeted EGU Strategy for SO2 Reduction.................................................................................95

10.2.5 Non-EGU SO2 Emissions Reduction Strategy for Non-MANE-VU States .................................101

10.3 REASONABLE PROGRESS GOALS FOR CLASS I AREAS IN THE STATE.......................................................108

10.4 VISIBILITY EFFECTS OF (ADDITIONAL) REASONABLE CONTROL MEASURES ..........................................109

10.5 REFERENCES FOR SECTION 10.................................................................................................................111

11. LONG-TERM STRATEGY ................................................................................................................112

11.1 OVERVIEW OF STRATEGY DEVELOPMENT PROCESS................................................................................112

11.2 TECHNICAL BASIS FOR STRATEGY DEVELOPMENT .................................................................................114

11.3 EXISTING COMMITMENTS TO REDUCE EMISSIONS ..................................................................................115

11.3.1 Controls on EGUs Expected by 2018........................................................................................116

11.3.2 Controls on Non-EGU Point Sources Expected by 2018 ..........................................................120

11.3.3 Controls on Area Sources Expected by 2018 ............................................................................121

11.3.4 Controls on Mobile Sources Expected by 2018.........................................................................122

11.3.5 Controls on Non-Road Sources Expected by 2018....................................................................123

11.4 ADDITIONAL REASONABLE MEASURES...................................................................................................123

11.4.1 BART .........................................................................................................................................125

11.4.2 Low-Sulfur Oil Strategy ............................................................................................................125

11.4.3 Targeted EGU Strategy.............................................................................................................126

11.5 SOURCE RETIREMENT AND REPLACEMENT SCHEDULES..........................................................................128

11.6 MEASURES TO MITIGATE THE IMPACTS OF CONSTRUCTION ACTIVITIES .................................................128

11.7 AGRICULTURAL AND FORESTRY SMOKE MANAGEMENT.........................................................................128
iv

11.8 ESTIMATED EFFECTS OF LONG-TERM STRATEGY ON VISIBILITY ............................................................129

11.9 VERMONT’S SHARE OF EMISSION REDUCTIONS ......................................................................................134

11.10 VERMONT COMMITMENTS TO SPECIFIC REGULATORY CHANGES THAT WILL FURTHER PROTECT 

VISIBILITY...............................................................................................................................................135

11.11 EMISSION LIMITATIONS AND COMPLIANCE SCHEDULES .........................................................................136

11.12 ENFORCEABILITY OF EMISSION LIMITATIONS AND CONTROL MEASURES...............................................136

11.13 PREVENTION OF SIGNIFICANT DETERIORATION ......................................................................................138

 
v

LIST OF FIGURES

Figure 1.1 Map of CAIR States...............................................................................................................................5

Figure 1.2 Illustrated Spectrum of Visibility Impairment Conditions at Lye Brook Wilderness ............................9

Figure 1.3 Contribution of Aerosol Species to Aerosol Mass and Light Extinction at Lye Brook, 2004..............11

Figure 1.4 Lye Brook Falls...................................................................................................................................12

Figure 1.5 Bourne Pond in the Lye Brook Wilderness Area.................................................................................13

Figure 1.6 Lye Brook Trail Signs .........................................................................................................................13

Figure 1.7 Lye Brook and Nearby Class I areas ..................................................................................................13

Figure 1.8 Lye Brook Boundary & Topography...................................................................................................13

Figure 1.9 Lye Brook Camera Site & View 1987-91 and Lye Brook Camera Site & View 1992-95....................14

Figure 1.10 Illustration of Lye Brook Visibility Conditions for the Stratton Mtn. Camera Site.............................14

Figure 1.11 Lye Brook Aerosol and Nephelometer Monitoring Site on Little Mt. Equinox ...................................15

Figure 1.12 Location of Lye Brook Monitoring site relative to the Wilderness Area.............................................15

Figure 1.13 Trends in Visibility on Clean and Hazy Days at the Lye Brook IMPROVE Site.................................17

Figure 1.14 Trends in LYBR Aerosol Bext on Clear Days (top left) and Hazy Days (bottom left), 1993-2005 & 

Upwind Incremental Probability Plots for Clear Days (top right) and Hazy Days (bottom right), 

1993-2005 ...........................................................................................................................................18

Figure 2.1 CALPUFF State Percent Contributions to Ambient Sulfate Concentrations at Lye Brook, 2002 ......19

Figure 2.2 Normalized Percent Contributions to LYBR Sulfate using Alternative Assessment Techniques.........20

Figure 2.3 Measured and Projected Sulfate Mass Contributions in 2002 and 2018 at Lye Brook Wilderness on 

20 Percent Worst Visibility Days ........................................................................................................21 

Figure 3.1 EPA-Designated Regional Planning Organizations (RPOs) ..............................................................25

Figure 5.1 Lye Brook Wilderness Area Location..................................................................................................46

Figure 5.2 Map of Lye Brook Wilderness Area and the IMPROVE Monitoring site............................................47

Figure 5.3 Lye Brook IMPROVE Monitoring Site on Little Mt. Equinox.............................................................47

Figure 7.1 National and Northeast Regional RPO Modeling Grid Domains.....................................................58

Figure 7.2 Examples of Processed Model-Ready Emissions: (a) SO2 from Point, (b) NO2 from Area, (c) NO2

from On-Road, (d) NO2 from Non-Road, (e) ISOP from Biogenic, and (f) SO2 from all Source 

Categories ...........................................................................................................................................60

Figure 8.1 Contributions to PM2.5 Extinction at 7 Class 1 Areas..........................................................................63

Figure 8.2 Ranked state percent sulfate contributions to Northeast Class I receptors based on emissions divided 

by distance (Q/d) results......................................................................................................................65

Figure 8.3 Ranked state percent sulfate contributions to Mid-Atlantic Class I receptors based on emissions 

times upwind probability (E x UP) results ..........................................................................................66

Figure 8.4 Comparison of normalized (percent contribution) results using different techniques for ranking state 

contributions to sulfate levels at the MANE-VU Class I sites .............................................................66

Figure 8.5 Modeled 2002 Sulfate Contributions at Lye Brook on the 20% Worst Days ......................................67

Figure 8.6 Trends in Annual Sulfur Dioxide (SO2) Emissions, by State ..............................................................69

Figure 8.7 2002 Sulfur Dioxide (SO2) Emissions, by State Bar Graph = Percentage Fractions of Four Source 

Categories Line Graph = Total Annual Emissions (106 tpy)..............................................................70

Figure 8.8 2002 Volatile Organic Carbon (VOC) Emissions, by State Bar Graph = Percentage Fractions of 

Four Source Categories Line Graph = Total Annual Emissions (106 tpy).........................................72

Figure 8.9 Trends in Annual Nitrogen Oxide (NOX) Emissions, by State.............................................................73

Figure 8.10 2002 Nitrogen Oxide (NOX) Emissions, by State Bar Graph = Percentage Fractions of Four Source 

Categories Line Graph = Total Annual Emissions (106 tpy)..............................................................73

Figure 8.11 Trends in Primary Coarse Particle (PM10) Emissions, by State .........................................................75

Figure 8.12 Trends in Primary Fine Particle (PM2.5) Emissions, by State.............................................................75

Figure 8.13 Upwind Incremental Probability for LYBR PMF Wood Smoke Source..............................................77

Figure 8.14 Incremental probability for 1989-1995 Underhill VT wood smoke compared with Canadian forest 

fire locations........................................................................................................................................77

Figure 8.15 2002 Primary Coarse Particle (PM10) Emissions, by State Bar Graph = Percentage Fractions of 

Four Source Categories Line Graph = Total Annual Emissions (106 tpy).........................................78

Figure 8.16 2002 Primary Fine Particle (PM2.5) Emissions, by State Bar Graph = Percentage Fractions of Four 

Source Categories Line Graph = Total Annual Emissions (106 tpy)..................................................79

Figure 8.17 Trends in Ammonia (NH3) Emissions, by State...................................................................................80
vi

Figure 8.18 2002 Ammonia (NH3) Emissions, by State Bar Graph = Percentage Fractions of Four Source 

Categories Line Graph = Total Annual Emissions (106 tpy)..............................................................81

Figure 10.1 Average Change in 24-hr PM2.5 Due to Low-Sulfur Fuel Strategy (Phases I and 2 Combined) 

Relative to OTB/OTW (values in μg/m3

) .............................................................................................92

Figure 10.2 Location of 167 EGU Stacks Contributing the Most to Visibility Impairment at MANE-VU Class I 

Areas ...................................................................................................................................................96

Figure 10.3 Preliminary Estimate of Average Change in 24-hr PM2.5 Resulting from a 90-Percent Reduction in 

SO2 Emissions from the Top 167 EGU Stacks Affecting MANE-VU Class I Areas.............................97

Figure 10.4 Demonstration of Required and Reasonable Visibility Progress for 20 Percent Worst Visibility 

Days ..................................................................................................................................................110

Figure 10.5 Demonstration of Required Maintenance or Improvement of Visibility for 20 Percent Best Visibility 

Days ..................................................................................................................................................110

Figure 11.1 Expected Visibility Improvement at Lye Brook Wilderness Based on Most Recent Projections.......131

Figure 11.2 Expected Improvements in Pollutant Concentrations at Lye Brook Wilderness on Best and Worst 

Days ..................................................................................................................................................132

Figure 11.3 Expected Visibility Improvement at Acadia National Park Based on Most Recent Projections .......132

Figure 11.4 Expected Visibility Improvement at Brigantine National Wildlife Refuge Based on Most Recent 

Projections ........................................................................................................................................133

Figure 11.5 Expected Visibility Improvement at Great Gulf Wilderness Based on Most Recent Projections......133

Figure 11.6 Expected Visibility Improvement at Moosehorn National Wildlife Refuge Based on Most Recent 

Projections ........................................................................................................................................134
vii

LIST OF TABLES

Table 2.1 Technical approaches for attributing contributions to sulfate in MANE-VU Class I areas ................19

Table 2.2 States that Contribute to Visibility Impairment in the MANE-VU Class I Areas of Acadia, Moosehorn, 

Great Gulf, Lye Brook, and Brigantine ...............................................................................................22

Table 2.3 Contributions of Individual States and Regions to Total Annual Average Sulfate Impact (Percent, 

Mass Basis) at the Lye Brook Wilderness in 2002 ..............................................................................23

Table 2.4 Vermont’s Contributions to Total Annual Average Sulfate Impact (Percent, Mass Basis) at Eastern 

Class I Areas in 2002 ..........................................................................................................................24

Table 3.1 MANE-VU Members...........................................................................................................................26

Table 3.2 MANE-VU Consultation Principles for Regional Haze Planning ......................................................27

Table 3.3 Summary of MANE-VU Consultations on Regional Haze Planning...................................................28

Table 3.4 States (Listed by Regional Planning Organization) and Provinces Contributing to Visibility 

Impairment at Vermont’s Lye Brook Wilderness Area........................................................................30

Table 4.1 IMPROVE Monitors for MANE-VU Class I Areas.............................................................................39

Table 4.2 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.................................................................41

Table 4.3 Baseline Visibility for the 20 Percent Best Days During 2000-2004 in the Lye Brook Wilderness 

Area.....................................................................................................................................................42

Table 4.4 Baseline Visibility for the 20 Percent Worst Days During 2000-2004 in the Lye Brook Wilderness 

Area.....................................................................................................................................................42

Table 6.1 2002 Emissions Inventory Summary Vermont (tpy).............................................................................55

Table 6.2 2018 OTB/OTW Emissions Inventory Summary for Vermont (tpy) .....................................................55

Table 6.3 2018 BOTW Emissions Inventory Summary for Vermont (tpy) ...........................................................55

Table 6.4 2018 Most Recent (“Updated Scenario”) Emissions Inventory Summary for Vermont (tpy)..............56

Table 8.1 Percent Contributions (Mass Basis) of Individual States and Regions to total Annual Sulfate Impacts 

at Northeast Class I Areas (REMSAD.................................................................................................64

Table 10.1 Uniform Rate of Progress Calculation (all values in deciviews).........................................................86

Table 10.2 Summary of Results from Four-Factor Analysis of Different Source Categories................................88

Table 10.3 Estimated Emissions from BART-Eligible Facilities in MANE-VU States (Facilities Likely to be 

Controlled as a Result of BART Alone)...............................................................................................90

Table 10.4 Estimated Cost Ranges for SO2 Control Options for Coal-Fired EGU Boilers (2006 dollars per ton 

of SO2 removed) .................................................................................................................................99

Table 10.5 Available SO2 Control Options for ICI Boilers..................................................................................103

Table 10.6 Estimated Costs of Dry Sorbent Injection (DSI) for ICI Boilers (2006 dollars)................................105

Table 10.7 Estimated Costs of Flue Gas Desulfurization for ICI Boilers (2006 dollars)....................................106

Table 10.8 Reasonable Progress Goals for Lye Brook Wilderness (in deciviews)...............................................108
viii

LIST OF ATTACHMENTS

ATTACHMENT A – MANE-VU Contribution Assessment 

ATTACHMENT B – Inter-RPO State/Tribal and FLM Consultation Framework 

ATTACHMENT C – Consultation Summaries and Other Documentation 

ATTACHMENT D – The MANE-VU “Ask” 

ATTACHMENT E – Comments from VISTAS and West Virginia Department of 

Environmental Protection 

ATTACHMENT F – MANE-VU Modeling for Reasonable Progress Goals 

ATTACHMENT G – Documentation of 2018 Emissions from EGUs in the Eastern United 

States 

ATTACHMENT H – Comments from (and VT responses to) FLMs, EPA and other 

Stakeholders 

ATTACHMENT I – MANE-VU Natural Background Visibility Conditions 

ATTACHMENT J – MANE-VU Baseline and Natural Background Visibility Conditions 

ATTACHMENT K – Technical Support Document for 20002 MANE-VU SIP Modeling 

Inventories, Version 3 

ATTACHMENT L – Development of Emission Projections for 2009, 2012, and 2018 for 

NonEGU Point and Nonroad Sources in the MANE-VU Region 

ATTACHMENT M – Development of MANE-VU Mobile Source Projection Inventories for 

SMOKE/MOBILE6 Application 

ATTACHMENT N – NYSDEC Technical Support Document TSD-1c 

ATTACHMENT O – MANE-VU 2018 Visibility Projections 

ATTACHMENT P – NYSDEC Technical Support Document TSD-1a 

ATTACHMENT Q – NYSDEC Technical Support Document TSD-1e 

ATTACHMENT R – NYSDEC Technical Support Document TSD-1d 

ATTACHMENT S – Technical Support Document on Agricultural and Forestry Smoke 

Management in the MANE-VU Region 

ATTACHMENT T – MANE-VU Five-Factor Analysis of BART-Eligible Sources 

ATTACHMENT U – Assessment of Reasonable Progress for Regional Haze 

ATTACHMENT V – Assessment of Control Technology Options for BART-Eligible Sources 

ATTACHMENT W – Low-Sulfur Heating Oil in the Northeast States 

ATTACHMENT X – Comparison of CAIR and CAIR Plus Proposal Using the Integrated 

Planning Model (IPM®) 

ATTACHMENT Y – The Nature of Fine Particle and Regional Haze Air Quality Problems in 

the MANE-VU Region 

ATTACHMENT Z – Technical Support Document on Measures to Mitigate Visibility Impacts 

of Construction Activities in the MANE-VU Region 
ix

ACKNOWLEDGMENTS

The Vermont Air Pollution Control Division would like to express appreciation for the 

invaluable assistance and contributions provided in developing this Plan by the dedicated staff 

of the NESCAUM, MARAMA and MANE-VU regional organizations, and the other MANEVU State Air Programs. We are particularly grateful for the substantial assistance and many 

helpful suggestions provided by the staff of the State of New Hampshire Department of 

Environmental Services.
1

1. Background on Regional Haze in the Lye Brook 

Wilderness 

1.1 General Background / History of Federal Visibility Rules 

In amendments to the Clean Air Act in 1977, Congress added Section 169 (42 U.S.C. 

7491) setting forth the following national visibility 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. 

The affected Class I areas include many of our best known natural places, including the 

Grand Canyon, Yosemite, Yellowstone, Mount Rainier, Shenandoah, the Great Smokies, 

Acadia, and the Everglades. In Vermont, the affected area is the Lye Brook Wilderness. 

Section 169 also directed EPA to promulgate regulations to assure reasonable progress 

toward this national visibility goal and to require State Implementation Plan (SIP) 

revisions in states containing the affected Class I Federal Areas as well as in states, “the 

emissions from which may reasonably be anticipated to cause or contribute to impairment 

of visibility in any such [Class I] area”. In 1980, EPA promulgated visibility regulations 

which focused primarily on impairment attributable to individual sources or small groups 

of sources (“plume blight”), but which also required long-term strategies to assure 

reasonable progress toward the national visibility goal. 

In April, 1986, the State of Vermont submitted a proposed SIP revision which determined 

that visibility in the Lye Brook Wilderness was not impaired by plume blight, but was 

severely impaired by regional haze, composed predominantly of sulfate aerosol transported 

from SO2 sources in upwind states. The 1986 VT SIP revision included a summer 

seasonal sulfate standard of 2 μg/m3 (roughly half the estimated prevailing concentration at 

that time) as an interim measure to assure reasonable progress toward the national visibility 

goal for Lye Brook. Vermont also requested that EPA implement an Eastern US regional 

SO2 emission reduction program to improve visibility in Lye Brook (and other eastern US 

Class I areas), and also specifically requested that EPA require SIP revisions in 8 upwind 

states (OH, PA, WV, IN, IL, KY, TN & MI) which were estimated to account for more 

than half of the sulfate in VT and which could clearly be identified as states “the emissions 

from which may reasonably be anticipated to cause or contribute to impairment of 

visibility” in Lye Brook (and many other Eastern US Class I areas). 

In July, 1987, EPA ruled on Vermont’s proposed visibility SIP. Although it concurred that 

“Vermont’s visibility impairment is predominantly due to out-of-state sulfur emissions”, 

EPA took “no action” on any aspects of the VT proposal that attempted to reduce regional 

haze, including the state sulfate standards, regional SO2 emission reductions, and requested 

SIP calls in major upwind contributing states. EPA argued that it had no current regulatory 
2

basis to address regional haze effects, and that substantial additional research was needed 

to develop the technical basis for such regulations. 

When the CAA was amended in 1990, Congress included (Title IV) a phased program of 

SO2 emission reductions in the Eastern US, similar to but somewhat less stringent than 

and with a longer time delay than what Vermont had requested in its 1986 SIP. The 1990 

CAA Amendments also added Section 169B (42 U.S.C. 7492), authorizing further 

visibility research and periodic assessments of the progress made toward improving 

visibility in Class I areas that resulted from the required CAA emissions reductions. 

In addition to authorizing creation of visibility transport commissions and setting forth 

their duties, Section 169B(f) of the 1990 CAA mandated creation of the Grand Canyon 

Visibility Transport Commission (GCVTC) to make recommendations to EPA for the 

region affecting the visibility of the Grand Canyon National Park. The Grand Canyon 

Visibility Transport Commission (Commission) submitted its report to EPA in June 1996, 

following four years of research and policy development. The Commission report, as well 

as the many research reports prepared by the Commission, contributed invaluable 

information to EPA in its development of the federal regional haze rule. 

1.2 The 1999 Regional Haze Rule 

EPA’s Regional Haze Rule was adopted July 1, 1999, and went into effect on August 30, 

1999. This rule seeks to address the combined visibility effects of various pollution sources 

over a wide geographic region. This wide reaching pollution net means that many states – 

including those without Class I Areas – are required to participate in haze reduction efforts. 

In consultation with the states and tribes, EPA designated five Regional Planning 

Organizations (RPO) to assist with the coordination and cooperation needed to address the 

Haze issue. The Mid-Atlantic / Northeast states, including the District of Columbia, 

formed the Mid-Atlantic / Northeast Visibility Union (MANE-VU).* 

EPA’s adoption of the Regional Haze Rule was not without controversy. On May 24, 2002 

the U.S. Court of Appeals, for the District of Columbia Circuit ruled on the challenge 

brought by the American Corn Growers Association against EPA’s Regional Haze Rule of 

1999. The Court remanded to EPA the BART provisions of the rule, and denied industry’s 

challenge to the haze rule goals of natural visibility and no degradation requirements. On 

June 15, 2005, EPA finalized a rule addressing the court’s remand. 

On February 18, 2005, the U.S. Court of Appeals for the District of Columbia Circuit 

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, no. 03-1222, 

(D.C. Cir. Feb. 18, 2005)(“CEED v. EPA”). In this case, the court granted a petition 

challenging provisions of the Regional Haze Rule governing the optional emissions trading 

program for certain Western States and Tribes (the WRAP Annex Rule). 

 

* A description of MANE-VU and a full list of its members is described in the Regional Planning Section of this SIP
3

EPA’s subsequent final rulemaking provided the following changes to the Regional Haze 

Regulations: 

1. Revised the regulatory text in Section 51.308(e)(2)(i) in response to the CEED

court’s remand, to remove the requirement that the determination of BART 

“benchmark” be based on cumulative visibility analyses, and to clarify the process 

for making such determinations, including the application of BART presumptions 

for EGUs as contained in Appendix Y to 40 CFR 51. 

2. Added new regulatory text in Section 51.308(e)(2)(vi), to provide minimum 

elements for cap and trade programs in lieu of BART 

3. Revised regulatory text in Section 51.309, to reconcile the optional framework for 

certain Western States and Tribes to implement the recommendations of the Grand 

Canyon Visibility Transport Commission (GCVTC) with the CEED decision. 

EPA’s 1999 regulations address visibility impairment in the form of regional haze. Haze is 

an atmospheric phenomenon that obscures the clarity, color, texture, and form of what we 

see. Haze in the Eastern US is caused primarily by anthropogenic (manmade) pollutants 

but can also be influenced by a number of natural phenomena, including forest fires, dust 

storms, and sea spray. The optical effects of these pollutants and natural substances result 

from the scattering and absorption of light by particles and gasses, with the scattering of 

light by fine particles (less than 2.5 microns diameter) being the predominant contributor at 

most times and places. Some haze-causing particles are emitted directly to the atmosphere 

by primary particle emission sources such as electric power plants, factories, automobiles, 

construction activities, and agricultural burning. Others occur when gases emitted to the air 

(particle precursors) interact to form secondary particles. Some secondary particles 

including sulfate and nitrate compounds are hygroscopic, and will grow in size and scatter 

more light as relative humidity increases. 

Fine particles formed from multiple primary and secondary sources can mix together over 

broad geographic areas and can be transported hundreds or thousands of miles. 

Consequently, regional haze occurs in every part of the nation. Because of the regional 

nature of haze, EPA’s regulations require the states to consult with one another toward the 

national goal of improving visibility – specifically, at the 156 parks and wilderness areas 

designated under the Clean Air Act as mandatory Class I Federal Areas. 

The Regional Haze Rule calls for each state to establish reasonable progress goals for 

visibility improvement and to formulate a long-term strategy for meeting these goals. 

These requirements apply to any state having a Class I area as well as any state that 

contributes to visibility impairment at any (downwind) Class I area. The visibility goals 

must be designed both to improve visibility on the haziest days and to ensure that no 

degradation occurs on the clearest days. 

A state’s long-term strategy must include enforceable emission reduction measures 

designed to meet reasonable progress goals. The first long-term strategy covers the 10 to 

15-year period ending in 2018, and subsequent revisions are to be issued every 10 years 

thereafter. In identifying the emission reduction measures to be included in the long-term 
4

strategy, states should address all types of manmade emissions contributing to visibility 

degradation in Class I areas, including those from mobile sources; stationary sources (such 

as factories and power plants); smaller, so-called “area” sources (such as residential wood 

stoves and small boilers); and prescribed fires. 

In developing their plans, states can take into account emission reductions attributable to 

ongoing air pollution control programs at the state, regional, or national levels. For most 

states and regions of the country, however, additional emission control measures beyond 

those already on the books will be necessary if national visibility goals are to be achieved. 

In addition, the Regional Haze Rule mandates that control measures be implemented for 

certain existing sources placed into operation between 1962 and 1977. This portion of the 

rule is known as BART, for Best Available Retrofit Technology. 

Each state’s plan for addressing regional haze will take the form of a State Implementation 

Plan (SIP) or SIP revision. Vermont’s SIP, was developed after extensive consultations 

with other states and regional planning organizations. In particular, Vermont contributed 

to many analyses and reports produced by the member states of the Northeast States for 

Coordinated Air Use Management (NESCAUM), the Mid-Atlantic Regional Air Managers 

Association (MARAMA), and the Mid-Atlantic/Northeast Visibility Union (MANE-VU) 

Regional Planning Organization for the purpose of coordinated regional haze planning. 

Vermont also consulted with states outside the Northeast and with the provinces of eastern 

Canada. 

In creating its regional strategy, Vermont and the other MANE-VU states looked beyond 

the provisions of the federal Clean Air Interstate Rule (CAIR) to identify additional 

emission control measures that could be effectively employed to mitigate regional haze. In 

this respect, Vermont and the rest of MANE-VU stand apart from some other states in 

asserting that additional measures beyond CAIR are essential to meeting established 

visibility goals at MANE-VU’s Class I Areas. 

The regulatory, organizational, and technical basis for Vermont’s regional haze plan will 

be found in Sections 1 through 8 of this SIP document. The prescriptive elements of 

Vermont’s plan – BART determinations, reasonable progress goals, and long-term strategy 

- are described in detail in Sections 9 through 11. 

1.3 Regional Haze Planning after the Vacatur 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 sulfur dioxide (SO2) 

and nitrogen oxides (NOX) emissions in the eastern United States through a cap-and-trade 

system using emission allowances. As promulgated, CAIR permanently caps emissions 

originating in 28 eastern states and the District of Columbia (Figure 1.1). Although 

Vermont was not designated as a participating CAIR state, this program would greatly 

affect future air quality in the state. 
5

Figure 1.1 Map of CAIR States 

http://www.epa.gov/cair/ 

According to EPA’s CAIR website, SO2 emissions in the affected states would be reduced 

by more than 70 percent from 2003 levels, and NOX emissions by more than 60 percent 

from 2003 levels, upon full implementation of CAIR (see http://www.epa.gov/cair/). 

Resulting improvements in air quality would yield $85 to $100 billion in health benefits 

and nearly $2 billion in visibility benefits per year by 2015, and premature mortality would 

be substantially reduced across the eastern U.S. 

This program came to an abrupt end, however, on July 11, 2008, when the U.S. Court of 

Appeals for the District of Columbia Circuit found that CAIR violated basic provisions of 

the Clean Air Act. The court vacated CAIR in its entirety and remanded to EPA to 

promulgate a new rule consistent with the court’s opinion. On September 24, 2008, EPA 

petitioned the D.C. Circuit for a rehearing or rehearing en banc on the vacatur of CAIR. 

Thereafter, the D.C. Circuit issued an order requesting briefs on the issue of whether any 

party is seeking vacatur of CAIR and whether the court should stay its vacatur until EPA 

promulgates a revised rule. Vermont, along with more than 20 other states, filed an amicus 

brief in support of staying the court decision vacating CAIR while EPA promulgates a 

revised rule that complies with the court’s decision. The states argued that because they 

“reasonably relied on CAIR in formulating long-term plans for improving air quality, in 

the short term even a flawed rule is better than no rule at all.” 

The vacatur of CAIR presented a major difficulty for the individual states in attempting to 

comply with the Regional Haze Rule. Because CAIR formed the regulatory underpinnings 

for most of the emission reductions that would produce visibility improvements in 
6

mandatory Class I areas, the probable demise of CAIR left a structural void around which 

states must build their regional haze SIPs. While all states have depended in varying 

degree on CAIR in the preparation of their regional haze SIPs, some Southeast states have 

relied almost entirely on CAIR to demonstrate compliance with the rule. As a major 

ramification, the vacatur of CAIR invalidated EPA’s determination that CAIR satisfies the 

requirements of BART. The vacatur of CAIR also called into question the validity of 

MANE-VU’s (and other RPO’s) emission inventories and air quality modeling studies 

already completed for the member states’ regional haze SIPs. 

However, on December 23, 2008, the D.C. Circuit decided that “a remand without vacatur 

is appropriate in this case” because “notwithstanding the relative flaws of CAIR, allowing 

CAIR to remain in effect until it is replaced by a rule consistent with our opinion would at 

least temporarily preserve the environmental values covered by CAIR.” State of North 

Carolina v. EPA, No. 05-1244, slip op. at 3 (D.C. Cir. Dec. 23, 2008). 

In light of this decision, Vermont believes that future emissions and air quality levels will 

not be vastly different from values predicted by MANE-VU’s completed modeling, even 

though that modeling was based on implementation of CAIR and did not take into account 

the remand of CAIR to EPA. Consequently, the reasonable progress goals and long-term 

strategy developed for Vermont’s regional haze SIP still represent a defensible position 

from which to go forward with measures to improve visibility in MANE-VU’s Class I 

Areas. 

Further, Vermont and the other MANE-VU states have maintained all along that the 

regional haze SIPs should look beyond the provisions of CAIR to identify additional 

emission control measures that could be effectively employed to mitigate regional haze. In 

this respect, Vermont and the rest of MANE-VU stand apart from some other states in 

asserting that additional measures beyond CAIR are essential to meeting established 

visibility goals at MANE-VU’s Class I Areas. 

In describing Vermont’s present situation, it may be helpful to note that the remand of 

CAIR without vacatur is a complicating factor for the long term, but does not present 

impediment to making visibility progress in the near term. The salient points to consider 

are as follows: 

• Because Vermont is a non-CAIR state, CAIR does not directly affect any of 

Vermont’s proposed in-state control strategies for visibility improvement. 

• Vermont will meet its “fair share” of emissions in comparison with other MANEVU states and the original CAIR states, as Vermont’s long-term strategy 

demonstrates (see Section 11.0). 

• Sources in upwind states release most of the pollutants contributing to visibility 

impairment in Vermont’s Class I Lye Brook Wilderness area. Therefore, Vermont 

will continue to depend on mitigative actions by other states if visibility goals are 

to be achieved for Lye Brook. 

• By the time of the first regional haze SIP progress report, in 2012, the regulatory 

framework should be clearer; and new modeling results should be available. It 
7

should then be possible to fine-tune regional haze plans to take into account any 

rule that EPA has promulgated to replace CAIR. Vermont is committed to 

reviewing and updating its regional haze SIP as new information becomes 

available. 

Given the D.C. Circuit’s remand without vacatur of CAIR, Vermont has chosen to retain 

appropriate references to CAIR in the completion of Vermont’s Regional Haze SIP, which 

will help to maintain continuity with the large body of completed work – much of it based 

on CAIR – that serves as the foundation for regional haze planning in the MANE-VU 

states to date. 

1.4 State Implementation Plan Requirements 

In accordance with 40 CFR 51.308(a) and (b), Vermont submits this SIP to meet the 

requirements of EPA’s Regional Haze Rule. This SIP addresses the core requirements of 

40 CFR 51.308(d) and the BART components of 40 CFR 50.308(e). In addition, this SIP 

addresses requirements pertaining to regional planning, and state/tribe and Federal Land 

Manager (FLM) coordination and consultation. 

40 CFR 51.308(f) requires the State of Vermont to submit periodic revisions to its 

Regional Haze SIP by July 31, 2018, and every ten years thereafter. Vermont 

acknowledges and will comply with this schedule. 

40 CFR 51.308(g) requires the State of Vermont to submit a report to EPA every 5 years 

that evaluates progress toward the reasonable progress goal for each mandatory Class I 

area located within the state and each mandatory Class I area located outside the state that 

may be affected by emissions from within the state. Vermont will submit the first progress 

report, in the form of a SIP revision, within 5 years from submittal of the initial State 

Implementation Plan, but no later than December 17, 2012. 

Pursuant to 40 CFR 51.308(d)(4)(v), Vermont will also make periodic updates to 

Vermont’s emissions inventory (see Section 6, Emissions Inventory). Vermont proposes 

to complete these updates to coincide with the progress reports. Lastly, pursuant to 40 CFR 

51.308(h), Vermont will submit a determination of adequacy of its regional haze SIP 

revision whenever a progress report is submitted. Depending on the findings of its fiveyear review, Vermont will take one or more of the following actions at that time, 

whichever actions are appropriate or necessary: 

• If Vermont determines that the existing State Implementation Plan requires no 

further substantive revision in order to achieve established goals for visibility 

improvement and emissions reductions, Vermont will provide to the EPA 

Administrator a negative declaration that further revision of the plan is not needed. 

• If Vermont determines that its implementation plan is or may be inadequate to 

ensure reasonable progress as a result of emissions from sources in one or more 

other state(s) which participated in the regional planning process, Vermont will 

provide notification to the EPA Administrator and to those other state(s). Vermont 
8

will also collaborate with the other state(s) through the regional planning process 

for the purpose of developing additional strategies to address any such deficiencies 

in Vermont’s plan. 

• If Vermont determines that its implementation plan is or may be inadequate to 

ensure reasonable progress as a result of emissions from sources in another country, 

Vermont will provide notification, along with available information, to the EPA 

Administrator. 

• If Vermont determines that the implementation plan is or may be inadequate to 

ensure reasonable progress as a result of emissions from sources within the state, 

Vermont will revise its implementation plan to address the plan’s deficiencies 

within one year from this determination. 

1.5 The Basics of Haze 

Small particles and certain gaseous molecules in the atmosphere cause poor visibility by 

scattering and absorbing light, thereby reducing the amount of visual information about 

distant objects that reaches an observer. Some light scattering by air molecules (Rayleigh 

scattering) and naturally occurring aerosols occurs even under natural conditions.*

 The 

distribution of particles in the atmosphere depends on meteorological conditions and leads 

to various forms of visibility impairment. When high concentrations of pollutants are well 

mixed in the atmosphere, they form a uniform haze. When temperature inversions trap 

pollutants near the surface, the result can be a sharply demarcated layer of haze. Plume 

blight – a distinct, frequently brownish plume of pollution from a particular emissions 

source – occurs under stable atmospheric conditions, where pollutants take a long time to 

disperse. 

Visibility impairment can be quantified using three different, but mathematically related 

measures: visual range (i.e., how far one can see); light extinction per unit distance (e.g., 

Mm-1)†

; and deciviews (dv), a useful metric for measuring increments of visibility change 

that are just perceptible to the human eye. Visibility impairment can be measured directly 

by nephelometer (light scattering) or transmissometer (light transmission – includes both 

scattering and absorption) and can also be calculated from color slide photographs using 

slide densitometry measurements, known target distances, and estimated inherent contrast 

measurements. Light extinction and other visibility metrics can also be “reconstructed”

from measured concentrations of ambient particle species components, taking into account 

their unique light-scattering (or absorbing) properties and making appropriate adjustments 

for relative humidity effects on hygroscopic species. Assuming natural conditions, 

visibility in the Northeast and Mid-Atlantic is estimated to be about 23 Mm-1, which 

corresponds to a visual range of about 170 kilometers or 8 dv. Under current polluted 

conditions in the region, average visibility ranges from 103 Mm-1 in the south to 55 Mm-1 

 

* The fact that air molecules scatter more short-wavelength (blue) light accounts for the blue color of the sky. The term 

“aerosol” is defined as a suspension of particles in a gas. In this report, the term refers to particles suspended in the 

atmosphere. 

†. In units of inverse length. An inverse megameter (Mm-1) is equal to one over one thousand kilometers.
9

in the north; these values correspond to a visual range of 40 to 70 kilometers or 23 to 17 

dv, respectively. On the worst 20 percent of days, visibility impairment in Northeast and 

Mid-Atlantic Class I areas ranges from about 20 to 30 dv. At Lye Brook Wilderness over 

the 5 year period from 2000 through 2004, reconstructed extinction averaged 6.4 dv (visual 

range of 222 kilometers) on the 20 percent cleanest days and 24.5 dv (visual range of 38 

kilometers) on the 20 percent haziest days. 

The photographs in Figure 1.2 illustrate the range of visibility conditions encountered at 

Lye Brook. They were taken by an automated camera which the USDA Forest Service 

operated from 1987 through 1991 at a location 2 kilometers south of Lye Brook Meadows. 

The view looks across the Wilderness area toward Mother Myrick Mountain, 18 kilometers 

to the NNW (336 degrees). The visibility metrics were calculated using slide densitometry 

measurements, known target distances, and estimated inherent contrast measurements. 

Figure 1.2 Illustrated Spectrum of Visibility Impairment Conditions at Lye Brook Wilderness 
10

The small particles that commonly cause hazy conditions in the East are primarily 

composed of ammoniated sulfate and nitrate compounds, organic matter (organic carbon 

and associated oxygen and hydrogen), elemental carbon (soot), crustal material (e.g., soil 

dust) and sea salt. Of these constituents, only elemental carbon impairs visibility by 

absorbing visible light; the others scatter light. Sulfates, nitrates, and some of the organics 

are secondary pollutants that form in the atmosphere from precursor pollutants, primarily 

sulfur dioxide (SO2), oxides of nitrogen (NOX), and volatile organic compounds (VOCs), 

respectively. By contrast, soot, sea salt, crustal material and some organic carbon particles 

are released directly to the atmosphere. Particle constituents also differ in their relative 

effectiveness at reducing visibility. Sulfates and nitrates, for example, contribute 

disproportionately to haze because of their chemical affinity for water. This property 

allows them to grow rapidly in the presence of moisture, and scatter much more light than 

they would under dry conditions. 

1.6 Anatomy of Regional Haze 

Monitoring data collected over the last decade show that fine particle concentrations, and 

hence visibility impairment, are generally highest near industrial and highly populated 

areas of the Northeast and Mid-Atlantic. Particle concentrations are lower, and visibility 

conditions are better, at the more northerly Class I sites (such as the Lye Brook 

Wildernesses), where visibility on the 20 percent best days* is close to natural, unpolluted 

conditions. By contrast, visibility at the more southerly Brigantine site in New Jersey is 

substantially impaired even on the 20 percent clearest days. On the 20 percent haziest days, 

visibility impairment is substantial throughout the region. 

Sulfate is the dominant contributor to fine particle pollution throughout the eastern U.S. 

On the haziest 20 percent of days, it accounts for one-half to two-thirds of total fine 

particle mass and is responsible for about three-quarters of total light extinction at Class I 

sites in the Northeast and Mid-Atlantic. Even on the clearest 20 percent of days, sulfate 

typically constitutes 40 percent or more of total fine particle mass in the region. Moreover, 

sulfate accounts for 60 to 80 percent of the difference in fine particle mass concentrations 

on hazy versus clear days. 

Organic carbon consistently accounts for the next largest fraction of total fine particle 

mass; its contribution typically ranges from 20 to 30 percent on the haziest days. Notably, 

organic carbon accounts for as much as 40 to 50 percent of total mass on the clearest days, 

indicating that biogenic hydrocarbon sources (i.e. vegetation) are important at Class I areas 

in the region. 

The relative contributions of nitrate, elemental carbon, and fine soil are smaller than those 

of sulfate and organic carbon – typically less than 10 percent of total mass and varying 

with location. However, in some settings such as a monitoring site in Washington, DC, 

 

* “20 percent best visibility conditions” are defined throughout this report as the simple average of the lower 20th 

percentile of a cumulative frequency distribution of available data (expressed in deciviews). Similarly, “20 percent worst 

visibility conditions” represent the upper 20th percentile of the same distribution of available data. 
11

nitrate plays a considerably larger role, pointing to the importance of local NOX and/or 

NH3 sources to fine-particle pollution in urban environments. 

About half of the worst visibility days in Lye Brook occur in the summer when 

meteorological conditions are more conducive to the formation of sulfate from SO2 and to 

the oxidation of organic aerosols. The remaining worst visibility days are divided nearly 

equally among spring, winter, and fall. In addition, winter and summer transport patterns 

are different, possibly leading to different contributions from upwind pollutant source 

regions. In contrast to sulfate and organic carbon, the nitrate contribution is typically 

higher in the winter months*. The crustal and elemental carbon fractions do not show a 

clear pattern of seasonal variation. Figure 1.3 shows the relative contributions of aerosol 

species at Lye Brook in 2004 to PM10 mass (top) and aerosol light extinction (bottom) on 

the 20% best days (left) and 20% worst days (right). 

Figure 1.3 Contribution of Aerosol Species to Aerosol Mass and Light Extinction at Lye Brook, 2004 

The basis for EPA’s regional haze regulations is recognition that visibility impairment is 

fundamentally a regional phenomenon. Emissions from numerous sources over a broad 

geographic area commonly create hazy conditions across large portions of the eastern U.S. 

as a result of the long-range transport of airborne particles and precursor pollutants in the 

atmosphere. The key sulfate precursor, SO2, for example, has an atmospheric lifetime of 

several days and is known to be subject to transport distances of hundreds of miles. Once 

converted to SO4 aerosol, the atmospheric lifetime and transport distances for sulfur 

compounds are even greater. Gaseous NOX, nitric acid, ammonia and some gaseous 

organic carbon species are also subject to transport, and their transport distances become 

substantially greater if they are transformed into particle phase. Small particles of soot and 

crustal material are also subject to long range transport, and in fact some of the highest 

concentrations of fine soil at rural sites in the Northeastern US have been traced to 

intercontinental transport of Asian and African dust. 

 

* This is largely due to the fact that the ammonium nitrate bond is more stable at lower temperatures. The role of 

ammonia in combination with both sulfate and nitrate is discussed further in later sections
12

The importance of transport dynamics is well illustrated by a particularly severe haze 

episode that occurred in mid-July of 1999. During this episode, unusually hot and humid 

conditions coincided with the development of a high-pressure system over the MidAtlantic States that produced atmospheric stagnation over the heavily urbanized, southern 

portion of the northeastern Regional Planning Organization region (i.e., Philadelphia - DC 

- southern New Jersey). At the same time, wind patterns above the area of stagnation 

brought a steady flow of air from the Midwest into the New England states. This set of 

conditions resulted in several days of unusually high concentrations of fine-particle 

pollution throughout the region. On July 17, 1999, ambient sulfate concentrations at 

Acadia National Park were 40 percent higher than any previous measurement at that site 

since the late 1980s. On the same day, visibility at the Burlington, Vermont, airport was 

limited to just 3 miles. Fine Particle mass concentrations in the Lye Brook Wilderness 

exceeded 40 μg/m3

, including nearly 30 μg/m3 of ammonium sulfate. As is often the case, 

high concentrations of ground-level ozone accompanied these severe haze conditions. 

These coinciding conditions occurred because haze and ground-level ozone – although 

they are fundamentally different phenomena – tend to form and accumulate under similar 

meteorological conditions. In addition, high concentrations of ozone and other 

photochemical oxidants can accelerate the formation of secondary sulfate and organic 

aerosols, with possible contributions of different precursor gasses – SO2, NOx, VOCs – 

from different sources in different regions mixing together and impairing visibility over 

large downwind regions. 

1.7 The Lye Brook Wilderness Area 

 Figure 1.4 Lye Brook Falls 

The Lye Brook Wilderness Area, within the Green 

Mountain National Forest, is located east of 

Manchester Center and Sunderland in the southern 

Green Mountains of Vermont (Figure 4). It was 

designated wilderness by Congress in 1975, and is 

currently comprised of 17,841 acres. It is named 

after Lye Brook, which flows through the western 

half of the wilderness before emptying into the 

Batten Kill near Manchester. Elevation ranges 

from 900 feet to 2,900 feet above sea level, with 

most of the wilderness on a high plateau above 

2,500 feet. Roughly 80% of the area is forested, 

with a mix of northern hardwoods with pockets of 

spruce/fir. The relatively flat southern section of 

the wilderness, known as Lye Brook Meadows 

contains several bogs, ponds and marshy areas 

which form the headwaters of Lye Brook. The 

western section is extremely steep, descending 

rapidly from the Green Mountain plateau to the 

Valley of Vermont. Four and a half miles of 

Appalachian Trail and Long Trail pass through the 

northwest corner of the wilderness. 
13

Figure 1.5 Bourne Pond in the Lye Brook 

Wilderness Area 

Figure 1.6 Lye Brook Trail Signs 

Lye Brook is just over 100 miles southwest of the Great Gulf and Presidential range 

Wilderness Areas in New Hampshire, roughly 250 miles west southwest of Acadia 

National Park in Maine, and 270 miles north of the Brigantine National Wildlife Refuge in 

New Jersey. The closest urban areas are Albany New York, 50 miles to the Southwest and 

Boston MA, 110 miles to the east. New York City and Montreal are roughly 170 miles to 

the south and north, respectively. 

Figure 1.7 Lye Brook and Nearby Class I 

areas 

Figure 1.8 Lye Brook Boundary & 

Topography 

1.8 Monitoring and Recent Visibility Trends 

Visibility monitoring at Lye Brook has included scene monitoring by automatic cameras, 

optical monitoring by integrating nephelometer and aerosol monitoring by the IMPROVE 

(Interagency Monitoring of PROtected Visual Environments) program. Between 1987 and 

1995, the USDA Forest Service operated 2 automated camera sites overlooking Lye Brook. 

Starting in May, 1987, a camera snapped 3 pictures a day (9 AM, noon and 3 PM) from a site 

just south of the wilderness looking NNW toward Mother Myrick Mtn. In June 1992, the 
14

camera was moved to a site on Little Mt. Equinox to the west of the Wilderness, looking ESE 

toward Stratton Mtn. which is just east of the Wilderness boundary (see Figure 1.9). 

Figure 1.9 Lye Brook Camera Site & View 1987-91 and Lye Brook Camera Site & View 1992-95 

Photos showing a wide range of visibility conditions from the Mother Myrick Mtn. camera 

were previously displayed in Figure 1.2. Figure 1.10 shows a range of visibility conditions 

for the Stratton Mtn. site – ranging from a visual range of 280 km (left) to 12 km (right). 

Figure 1.10 Illustration of Lye Brook Visibility Conditions for the Stratton Mtn. Camera Site 

Between 1993 and 2003, the USDA Forest Service operated an unheated (Optec NGN2) 

integrating nephelometer at the Little Mt. Equinox site to the west of the Wilderness. The 

nephelometer measured light scattering (hourly), was located near the camera site facing 

Stratton Mtn. and was collocated with the Lye Brook IMPROVE aerosol samplers (see Figure 

1.11). Note that this site is west of, and at 1015 meters elevation is slightly higher than the 

highest elevation (880 meters) in the wilderness (Figure 1.12), but haze and aerosol 

measurements are considered representative of regional haze conditions in Lye Brook. 
15

Figure 1.11 Lye Brook Aerosol and Nephelometer Monitoring Site on Little Mt. Equinox 

Figure 1.12 Location of Lye Brook Monitoring site relative to the Wilderness Area 
16

IMPROVE aerosol sampling was initiated at the Lye Brook Little Equinox site in September 

1991. Daily (24-hour midnight to midnight local time) samples were initially taken 

Wednesdays and Saturdays with the schedule revised to every 3rd day in 2001. Aerosol 

sampling and filter analysis is conducted according to procedures described in “IMPROVE 

Standard Operating Protocols: Particle Monitoring Network 

(http://vista.cira.colostate.edu/improve/Publications/IMPROVE_SOPs.htm). The data are 

stored in and available from the Visibility Information Exchange Web System (VIEWS at: 

http://vista.cira.colostate.edu/views/). 

The haze-relevant aerosol measurements include PM10 mass and PM2.5 mass (from which 

coarse mass is calculated), fine sulfate and nitrate ions (from which ammonium sulfate and 

ammonium nitrate are calculated), fine organic carbon (from which particulate organic matter 

is calculated), fine elemental carbon, fine elemental chlorine and chloride ion (from which sea 

salt mass is calculated), and fine crustal elements (Si, Al, Fe, Ca, Ti – from which fine soil is 

calculated). The calculated aerosol species mass concentrations are then combined with 

estimated dry light extinction efficiencies, enhanced hygroscopic growth functions (for sulfate 

nitrate & sea salt) using climatologically derived monthly relative humidity and f(RH) growth 

functions, and added to Rayleigh Scattering from natural gaseous air molecules (11 Mm-1 for 

Lye Brook). The equation presented below used for these extinction calculations – referred to 

as the IMPROVE Equation, Version II, and recommended by the IMPROVE Steering 

Committee is described in “Review of the IMPROVE Equation for Estimating Ambient Light 

Extinction Coefficients - Final Report”, J. L. Hand and W. C. Malm, March 2006 

http://vista.cira.colostate.edu/improve/Publications/GrayLit/016_IMPROVEeqReview/IMPR

OVEeqReview.htm. 

 

Bext ≈ 2.2 x fS (RH) x [Small (NH4)2SO4] + 4.8 x fL (RH) x [Large (NH4)2SO4] 

+ 2.4 x fS (RH) x [Small NH4NO3] + 5.1 x fL (RH) x [Large NH4NO3] 

+ 2.8 x [Small Organic Mass] + 6.1 x [Large Organic Mass] 

+ 10 x [Elemental Carbon] + 1 x [Fine Soil Mass] 

+ 1.7 x fSS (RH) x [Sea Salt Mass] + 0.6 x [Coarse Mass] 

+ Rayleigh Scattering (Site Specific) + 0.33 x [NO2 (ppb)] 

Where: 

Bext = The light extinction coefficient in inverse megameters [Mm-1], 

fs (RH) and fL (RH) = Humidity factor associated with small and large mode mass 

size distributions of (NH4)2SO4 and NH4NO3,

fss (RH) = Humidity factor associated with Sea Salt, 

 NO2 data are not available and concentrations are assumed to be negligible 

Apportionment of the total concentrations of ammonium sulfate ((NH4)2SO4) into the 

concentrations of small and large size fractions is accomplished using the following equations: 

[Large (NH4)2SO4] = [Total (NH4)2SO4]/20 x [Total (NH4)2SO4] 

[Small (NH4)2SO4] = [Total (NH4)2SO4] - [Large(NH4)2SO4]

Similar equations are used to apportion total ammonium nitrate (NH4NO3) and total particulate 

organic material (POM = 1.8·OC) concentrations into the small and large size fractions. 
17

The resulting light extinction estimates (Bext in Mm-1) can be converted to deciviews: 

Deciviews (dv) = 10 ln Bext/10 

The calculated deciviews are unitless values where the higher the value, the greater amount of 

visibility impairment exists. A change of one deciview is considered to be the smallest change 

that would be humanly perceptible. 

Figure 1.13 displays the trends in Lye Brook visibility averaged over the clearest 20 % of 

days in each year and the haziest 20% of days each year since 1993. It may be noted that 

there has been a general improvement in visibility on the cleanest days, but no consistent 

change has occurred on the haziest days over this 13-year period. 

Figure 1.13 Trends in Visibility on Clean and Hazy Days at the Lye Brook IMPROVE Site 

The EPA Regional Haze Rule requires that there be no deterioration of visibility on the 

cleanest 20% days, and that visibility impairment on the haziest days should improve from 

current “baseline conditions” (1999-2004 average of worst 20% days, currently estimated to 

be 24.5 dv for Lye Brook) to natural background conditions (currently estimated to be 11.7 dv 

on worst 20% days for Lye Brook) by the year 2064. 

Figure 1.14 shows the trends in aerosol light extinction at Lye Brook for the period 1993 

through 1995 for the best 20 % days (top left) and worst 20% days (bottom left) along with 

the contributions of individual aerosol species. While sulfate is the largest contributor to haze 
18

on the cleanest days, the improvement on clean days has also been due to a reduction in 

sulfate on these clean days over this 13-year period. On the haziest 20% days, sulfate has 

been an even more predominant proportionate contributor to haze, but there has been no 

significant reduction in sulfate or total light extinction on the haziest days. 

Figure 1.14 Trends in LYBR Aerosol Bext on Clear Days (top left) and Hazy Days (bottom left), 1993-

2005 & Upwind Incremental Probability Plots for Clear Days (top right) and Hazy Days (bottom right), 

1993-2005 

The right side of Figure 1.14 shows ATAD trajectory-based incremental probability fields 

(areas most likely to have been upwind for a selected condition at the receptor) calculated by 

the Combined Aerosol Trajectory Tool (http://datafedwiki.wustl.edu/index.php/CATT) for the 

clearest 20% days (top right) and haziest 20% days (bottom right) at Lye Brook 1993 through 

2005. On the clearest days (on which Lye Brook sulfate has improved over time), the air has 

previously resided over Vermont, other New England States, the North Atlantic and/or 

Eastern Canada. On the haziest days (on which Lye Brook sulfate has not improved), the air 

has previously resided well to the southwest of Vermont. Any reasonable progress toward 

improving conditions on the haziest days at Lye Brook can only be achieved by substantial 

sulfur emission reductions from these upwind regions. 
19

2. Areas Contributing to Regional Haze 

40 CFR 51.308(c)(1)(ii) of the Regional Haze Rule requires states to determine their 

contributions to visibility impairment at mandatory Class I areas. Using a variety of source 

apportionment modeling techniques, MANE-VU has identified and evaluated the major 

contributors to regional haze and specifically to sulfate aerosol at MANE-VU Class I Areas as 

well as Class I areas in nearby Regional Planning Organization (RPO) regions. These 

technical source apportionment approaches are summarized in Table 2.1 below, and presented 

in detail in the Appendix I Report “Contributions to Regional Haze in the Northeast and MidAtlantic United States,” August 2006, otherwise known as the Contribution Assessment. 

 

Table 2.1 Technical approaches for attributing contributions to sulfate in MANE-VU Class I areas 

Analytical technique Approach 

Emissions/distance Empirical 

Incremental probability Lagrangian trajectory technique 

Cluster-weighted probability Lagrangian trajectory technique 

Emissions × upwind probability Empirical/trajectory hybrid 

Source apportionment approaches Receptor model/trajectory hybrid 

REMSAD tagged species Eulerian source model 

CALPUFF with MM5-based meteorology Lagrangian source dispersion model 

CALPUFF with observation-based meteorology Lagrangian source dispersion model 

Figure 2.1 CALPUFF State Percent Contributions to Ambient Sulfate Concentrations at Lye Brook, 

2002 

Example results for the apportionment of 2002 sulfate at Lye Brook using the CALPUFF 

Lagrangian model combined with observation - based meteorology (modeling conducted by 
20

VT DEC staff) are displayed in Figure 2.1. Slightly different proportionate contributions to 

sulfate in Lye Brook and in other MANE-VU Class I areas were estimated by the other source 

apportionment techniques, but as indicated in Figure 2.2, the results were generally quite 

consistent across all the different methods – both in terms of percent and rank of the different 

state contributions. 

Figure 2.2 Normalized Percent Contributions to LYBR Sulfate using Alternative Assessment Techniques 

The regional REMSAD modeling performed by MANE-VU used a pollutant tagging scheme 

to produce a comprehensive assessment of the individual contributions from 28 nearby states 

to visibility impairment at Lye Brook and seven other nearby Class I areas. The modeling also 

provided a partial accounting of the contributions from several states along the western and 

southern edges of the modeling domain (i.e., boundary conditions) where only a portion of the 

states’ emissions were tracked. Modeling was conducted for the base year 2002 and then 

projected to year 2018, when currently anticipated emission control programs would be in 

place. 

 

Modeling results indicate that the relative contributions of states within the modeling domain 

were expected to decrease significantly by 2018 as a result of anticipated SO2 emission 

reductions from implementation of existing state programs, the federal Clean Air Interstate 

Rule (CAIR), and additional state and federal control measures described in following 

sections of this document. At the same time, there are estimated to be large increases in the 

relative contributions from Canada and the boundary areas. These predicted percentage 

increases are due simply to the fact that contributions from outside the modeling domain will 

represent a larger share of the total after the various emission control programs have reduced 

contributions from within the domain. 
21

According to the completed MANE-VU CMAQ modeling, sulfate concentrations at the Lye 

Brook Wilderness Area on the 20 percent worst visibility days will decline from 8.5 μg/m3 in 

2002 (representing the baseline period of 2000-2004) to 5.5 μg/m3 in 2018. Mirroring the 

results for sulfate, fine particulate matter (PM2.5) concentrations from all sources are projected 

to fall by a similar percentage, from 14.6 μg/m3

 in 2002 to 11.2 μg/m3 in 2018. The modeling 

that produced these results is described in Section 7.0, Air Quality Modeling, and in “2018 

Visibility Projections,” May 13, 2008 (Appendix X). The emission control programs 

responsible for the projected visibility improvements are described in Section 11.0, LongTerm Strategy. 

Figure 2.3 shows the magnitude of the 2002 (measured) and 2018 (projected) sulfate 

concentrations at the Lye Brook Wilderness, as well as the relative mass contributions of each 

state (or portion thereof in the model domain), on the 20 percent worst visibility days. Similar 

findings apply to other Class I areas in the MANE-VU region. 

Figure 2.3 Measured and Projected Sulfate Mass Contributions in 2002 and 2018 at Lye Brook 

Wilderness on 20 Percent Worst Visibility Days 
22

2.1 States Contributing to Visibility Impairment at Lye Brook 

Based on the combined results from the multiple assessment techniques employed in the 

MANE-VU Contribution Assessment, Vermont and other MANE-VU states 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% of the annual 

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

Through participation in the MANE-VU regional haze planning process, Vermont has 

identified the following States as causing or contributing to visibility impairment in the 

following Class I areas Acadia National Park, Brigantine Wildlife Refuge, Great Gulf 

Wilderness Area, Lye Brook Wilderness Area, Moosehorn Wildlife Refuge, Presidential 

Range-Dry River Wilderness Area, and Roosevelt-Campobello International Park.* 

Table 2.2 States that Contribute to Visibility Impairment in the MANE-VU Class I Areas of Acadia, 

Moosehorn, Great Gulf, 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 Island MANE-VU 

Vermont MANE-VU 

Georgia VISTAS 

Kentucky VISTAS 

North Carolina VISTAS 

South Carolina VISTAS 

Tennessee VISTAS 

Virginia VISTAS 

West Virginia VISTAS 

Illinois MRPO 

Indiana MRPO 

Michigan MRPO 

Ohio MRPO 

New Brunswick, Canada N/A 

Ontario, Canada N/A 

Quebec, Canada N/A 

 

* Vermont independently determined based on CALPUFF modeling, which was not considered in developing 

Table 2.2, that Wisconsin has the potential to contribute to visibility impairment in Lye Brook. Therefore, 

Vermont asked Wisconsin to consult. See Section 3.2.1 and Table 3.4. 
23

Table 2.3 shows the REMSAD estimates of percent contributions to 2002 annual average 

sulfate concentrations at Lye Brook Wilderness from states within the MANE-VU RPO as 

well as from other RPO regions, Canada and “Other” areas outside the REMSAD modeling 

domain. Taken from MANE-VU’s Contribution Assessment, the data provide clear evidence 

that the large majority of sulfate pollution at Lye Brook originates from sources outside the 

Vermont (>99%) and that nearly 70% of Lye Brook sulfate results from sources outside the 

MANE-VU RPO. 

Table 2.3 Contributions of Individual States and Regions to Total Annual Average Sulfate Impact 

(Percent, Mass Basis) at the Lye Brook Wilderness in 2002 

State or Region Percent 

Contribution 

Pennsylvania 11.72

New York 9.00

Maryland 2.66

Massachusetts 2.45

New Hampshire 1.68

New Jersey 1.44

Vermont 0.95

Delaware 0.93

Connecticut 0.55

Maine 0.31

Rhode Island 0.06

District of Columbia 0.02

MANE-VU 31.78

MIDWEST RPO 21.48

VISTAS 13.65

CENRAP 1.67

CANADA 12.43

OTHER 18.99

2.2 Other Class I Areas Affected by Vermont Emissions 

In accordance with 40 CFR 51.308(d)(4)(iii) the MANE-VU Contribution Assessment 

indicates that emissions sources within the State of Vermont have or may have impacts on the 

Lye Brook Wilderness Area, but do not have significant impacts on other Class I Areas in the 

MANE-VU region or in other RPO regions. The tagged REMSAD results indicate VT 

emissions account for less than 1% of average sulfate concentrations in Lye Brook and less 

than 0.5% of average sulfate concentrations in any other Class I area. 
24

Table 2.4 Vermont’s Contributions to Total Annual Average Sulfate Impact (Percent, Mass Basis) at 

Eastern Class I Areas in 2002 

Mandatory Class I Area(s) Percent Contribution

Lye Brook Wilderness* 0.95 

Acadia National Park* 0.13 

Brigantine Wilderness Area* 0.06 

Dolly Sods Wilderness 0.00 

Great Gulf Wilderness* & Presidential Range – Dry River Wilderness* 0.41 

Moosehorn Wilderness* & Roosevelt Campobello International Park* 0.09 

Shenandoah National Park 0.01 

* MANE-VU Class 1 Area 
25

3. Regional Planning and Consultation 

In 1999, EPA and affected states/tribes agreed to create five Regional Planning Organizations 

(RPOs) to facilitate interstate coordination on State Implementation Plans (SIPs) addressing 

regional haze. The RPOs, and states/tribes within each RPO, are required to consult on 

emission management strategies toward visibility improvement in affected Class I areas. As 

shown in the accompanying map (Figure 3.1), the five RPOs are MANE-VU (MidAtlantic/Northeast Visibility Union), VISTAS (Visibility Improvement State and Tribal 

Association of the Southeast), MRPO (Midwest Regional Planning Organization), CenRAP 

(Central Regional Air Planning Association), and WRAP (Western Regional Air Partnership). 

Vermont is a member of MANE-VU. 

Figure 3.1 EPA-Designated Regional Planning Organizations (RPOs) 

 

3.1 Mid-Atlantic / Northeast Visibility Union (MANE-VU) 

MANE-VU’s work is managed by the Ozone Transport Commission (OTC) and carried out 

by OTC, the Mid-Atlantic Regional Air Management Association (MARAMA), and the 

Northeast States for Coordinated Air Use Management (NESCAUM). The states, tribes, and 

federal agencies comprising MANE-VU are listed in Table 3.1. Individuals from the member 

states, tribes, and agencies, along with professional staff from OTC, MARAMA, and 

NESCAUM, make up the various committees and workgroups. MANE-VU also established a 

Policy Advisory Group (PAG) to provide advice to decision-makers on policy questions. 

EPA, Federal Land Managers, states, and tribes are represented on the PAG, which meets on 

an as-needed basis. 
26

Table 3.1 MANE-VU Members 

Connecticut Rhode Island 

Delaware Vermont 

Maine District of Columbia 

Maryland Penobscot Nation 

Massachusetts St. Regis Mohawk Tribe 

New Hampshire U.S. Environmental Protection Agency* 

New Jersey U.S. Fish and Wildlife Service* 

New York U.S. Forest Service* 

Pennsylvania U.S. National Park Service* 

 *Non-voting member 

Since its inception on July 24, 2001, MANE-VU has created an active committee structure to 

address both technical and non-technical issues related to regional haze. The primary 

committees are the Technical Support Committee (TSC) and the Communications Committee. 

While the work of these committees is instrumental to policies and programs, all policy 

decisions reside with and are made by the MANE-VU Board. 

The TSC is charged with assessing the 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. This committee has evolved to function as a valuable resource on all 

technical projects and issues for MANE-VU. The TSC has established a process to ensure that 

important regional-haze-related projects are completed in a timely fashion, and members are 

kept informed of all MANE-VU tasks and duties. In addition to the formal working 

committees, there are three standing workgroups of the TSC assigned by topic area: the 

Emissions Inventory Workgroup, the Modeling Workgroup, and the Monitoring/Data 

Analysis Workgroup. 

The Communications Committee is charged with developing approaches to inform the public 

about the regional haze problem and making recommendations to the MANE-VU Board to 

facilitate that goal. This committee oversees the production of MANE-VU’s newsletter and 

outreach tools, both for stakeholders and the public, regarding regional issues affecting 

MANE-VU’s members. 

3.2 Regional Consultation and the MANE-VU “Ask” 

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

Framework (Attachment B). That document set forth the principles presented in Table 3.2. 

The MANE-VU states and tribes applied these principles to the regional haze consultation and 

SIP development process. Issues addressed included regional haze baseline assessments, 

natural background levels, and development of reasonable progress goals – described at 

length in later sections of this SIP. 

 
27

Table 3.2 MANE-VU Consultation Principles for Regional Haze Planning 

1. All State, Tribal, RPO, and Federal participants are committed to continuing dialogue and 

information sharing in order to create understanding of the respective concerns and needs of the 

parties

2. Continuous documentation of all communications is necessary to develop a record for inclusion 

in the SIP submittal to EPA. 

3. States alone have the authority to undertake specific measures under their SIP. This inter-RPO 

framework is designed solely to facilitate needed communication, coordination and cooperation 

among jurisdictions but does not establish binding obligation on the part of participating agencies

4. There are two areas which require State-to-State and/or State-to-Tribal consultations (“formal” 

consultations): (i) development of the reasonable progress goal for a Class I area, and (ii) 

development of long-term strategies. While it is anticipated that the formal consultation will cover 

the technical components that make up each of these policy decision areas, there may be a need for 

the RPOs, in coordination with their State and Tribal members, to have informal consultations on 

these technical considerations. 

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

Tribes will work collectively to facilitate the consultation process through their respective RPOs, 

when feasible. 

6. Technical analyses will be transparent, when possible, and will reflect the most up-to-date 

information and best scientific methods for the decision needed within the resources available. 

7. The State with the Class I area retains the responsibility to establish reasonable progress goals. 

The RPOs will make reasonable efforts to facilitate the development of a consensus among the 

State with a Class I area and other States affecting that area. In instances where the State with the 

Class I area can not agree with such other States that the goal provides for reasonable progress, 

actions taken to resolve the disagreement must be included in the State’s regional haze 

implementation plan (or plan revisions) submitted to the EPA Administrator as required under 40 

CFR §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 the 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 the 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 designed to share information, define and document issues, 

develop a range of options, solicit feedback on options, develop consensus advice if 

possible, and facilitate informed decisions by the Class I States. 

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

to other RPOs’/States’/Tribes’ requests for comments. 
28

The following points offer a snapshot of several important ways in which MANE-VU 

member states and tribes have cooperatively addressed regional haze: 

• Prioritization: MANE-VU developed 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 committees and workgroups. In addition, its MANE-VU 

directors regularly discussed pertinent issues. 

• SIP Policy and Planning: MANE-VU states/tribes collaborated on the 

development of a regional haze SIP template and the technical aspects of the SIP 

development process. 

• Capacity Building: To educate its staff and members, MANE-VU included 

technical presentations on conference calls and organized workshops with nationally 

recognized experts. Presentations on data analysis, Best Available Retrofit Technology 

(BART) applicability, inventory topics, modeling, and control measures were effective 

education and coordination tools. 

• Routine Operations: MANE-VU staff at OTC, MARAMA, and NESCAUM 

established a coordinated approach to budget tracking, project deliverables and due 

dates, workgroup meetings, inter-RPO consultations, etc. 

The consultations among MANE-VU states and other states/tribes and provinces occurred 

through much of 2007. Documentation of consultation meetings and calls is summarized in 

Table 3.3, and further documentation is provided in Attachment C. 

Table 3.3 Summary of MANE-VU Consultations on Regional Haze Planning 

MANE-VU IntraRegional Consultation 

Meeting,

March 1, 2007:

MANE-VU members reviewed the requirements for regional haze plans, 

preliminary modeling results, the work being done to prepare the MANEVU report on reasonable progress factors, and control strategy options 

under review. 

MANE-VU Intra-State 

Consultation Meeting,

June 7, 2007:

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:

The MANE-VU states concluded discussions of statements concerning 

reasonable controls within and outside MANE-VU and agreed on the 

statements called the MANE-VU “Ask” (see Part 3.2.2 of this SIP), 

including a statement concerning controls within MANE-VU, a statement 

concerning controls outside MANE-VU, and a statement requesting a 

course of action by the U.S. EPA. Federal Land Managers also 

participated in the call. Upon approval, all statements as well as the 

statement of principles adopted on June 7 were posted and publicly 

available on the MANE-VU website. The MANE-VU Ask was 

determined to represent Vermont’s needs for meeting Regional Haze rule 

requirements and was thus adopted as the Vermont Ask. 
29

3.2.1 Vermont-Specific Consultations 

40 CFR 51.308(d)(3)(i) of the Regional Haze Rule requires the State of Vermont to consult 

with other states/tribes to develop coordinated emission management strategies. This 

requirement applies both when emissions from a state/tribe are reasonably anticipated to 

contribute to visibility impairment in Class I areas outside the state/tribe and when emissions 

from other states/tribes are reasonably anticipated to contribute to visibility impairment at 

mandatory Class I areas within a state/tribe. 

Vermont consulted with other states/tribes by participating in the MANE-VU and inter-RPO 

processes leading to the creation of coordinated strategies on regional haze. This coordinated 

effort considered the individual and aggregated impacts of states’/tribes’ emissions on Class I 

areas within and outside the states/tribes. Through the MANE-VU process, more than twenty 

states and Canadian provinces have been identified as contributing to visibility degradation in 

the Lye Brook Wilderness Area. On February 23, 2007, Vermont sent letters formally 

requesting consultation under the Regional Haze Rule to states and Canadian provinces – 

specifically, those shown via modeling to contribute at least 2 percent of visibility-impairing 

sulfates at Lye Brook and all other states located within MANE-VU. 

MANE-VU Class I 

States’ Consultation 

Open Technical Call, 

July 19, 2007: 

The MANE-VU/Vermont Ask was presented to states in other RPOs, 

RPO staff, and Federal Land Managers; and an opportunity was provided 

to request further information. This call was intended to provide 

information to facilitate informed discussion at follow-up meetings. 

MANE-VU 

Consultation 

Meeting with 

MRPO, 

August 6, 2007: 

This meeting, held at LADCO offices in Chicago, was attended by 

representatives of MANE-VU and MRPO states as well as staff. 

The meeting provided an opportunity to formally present the 

MANE-VU/ Vermont Ask to MRPO states and to consult with 

them on the reasonableness of the requested controls. Federal Land 

Manager agencies also attended the meeting. 

MANE-VU 

Consultation 

Meeting with 

VISTAS, 

August 20, 2007: 

This meeting, held at State of Georgia offices in Atlanta, was 

attended by representatives of MANE-VU and VISTAS states. The 

meeting provided an opportunity to formally present the MANEVU/Vermont Ask to VISTAS states and to consult with them on 

the reasonableness of the requested controls. Federal Land 

Manager agencies also attended the meeting 

MANE-VU / MRPO 

Consultation 

Conference Call, 

September 13, 2007: 

As a follow-up to the meeting held on August 6 in Chicago, this 

call provided an opportunity for MANE-VU to clarify further what 

was being asked of the MRPO states. The flexibility in the Ask 

was explained. MRPO and MANE-VU staff agreed to work 

together to facilitate discussion of further controls on ICI boilers 

and EGUs. 

MANE-VU Air 

Directors’ 

Consultation 

Conference Call, 

September 26, 2007: 

MANE-VU members clarified their understanding of the Ask and 

provided direction to modeling staff regarding interpretation of the 

Ask for purposes of estimating visibility impacts of the requested 

controls. 
30

To maintain consistency within MANE-VU, every MANE-VU member was requested to 

consult with Vermont. Several states outside MANE-VU were also requested to join this 

consultation in response to the findings of MANE-VU’s evaluations. Independent of the other 

MANE-VU states with Class I areas, Vermont separately identified Wisconsin as having the 

potential to impact the Lye Brook Wilderness Area based on CALPUFF regional modeling 

using the VTDEC modeling platform which predicts Wisconsin impacts on sulfate there as 

equivalent to those from Illinois, ie 4% {see page D-54 of the NESCAUM report, 

“Contributions to Regional Haze in the Northeast and Mid-Atlantic United States”, August 

2006 (Attachment A}. In addition, the Canadian Provinces of Ontario and Quebec were 

invited to join in informal consultation with Vermont, although they are under no legal 

obligation to meet U.S. requirements. Table 3.4 provides a complete listing of states, 

provinces, and regional planning organizations invited to participate in consultations with 

Vermont on measures to mitigate regional haze. Note that all MANE-VU states with Class I 

areas have similarly requested consultation with Vermont on the regional haze issue. 

Table 3.4 States (Listed by Regional Planning Organization) and Provinces Contributing to Visibility 

Impairment at Vermont’s Lye Brook Wilderness Area 

As a result of the invitation to consult, Ontario, Canada, invited representatives of Vermont 

Department of Environmental Conservation (VTDEC), New Hampshire Department of 

Environmental Services (NHDES), Maine Department of Environmental Protection 

(MEDEP), New York Department of Environmental Conservation (NYDEC), and 

NESCAUM to join the Shared Air Summit in Toronto on June 12, 2007, followed by an 

informal consultation meeting with representatives from Ontario on June 13, 2007. At these 

meetings, Ontario announced its plan to shut down all coal electrical generation and 

challenged participating states to pursue similar goals. Considerable discussion took place 

regarding trans-border air pollution transport and its affect on human health. 

Formal inter-regional consultation meetings took place on August 6, 2007, in Rosemont, 

Illinois, (for Midwestern states) and on August 20, 2007, in Atlanta, Georgia, (for Southern 

states). Consultation continues with the Midwestern states, seeking common approaches for 

reducing power plant emissions beyond the levels defined under the federal CAIR rule, 

MANE-VU VISTAS MRPO INTERNATIONAL 

Connecticut Georgia Illinois Ontario, Canada 

Delaware Kentucky Indiana Quebec, Canada 

District of Columbia North Carolina Michigan 

Maine South Carolina Ohio 

Maryland Tennessee Wisconsin 

Massachusetts Virginia 

New Jersey West Virginia 

New York 

Pennsylvania 

Rhode Island 

New Hampshire 
31

controls on industrial boilers, and cleaner-burning fuels for mobile sources. Ongoing 

consultation with MRPO focuses mainly on the health benefits of reducing ozone and small 

particulate emissions; however, the control measures being considered would also result in 

visibility improvements. 

3.2.2 The MANE-VU “Ask” 

In addition to having a set of guiding principles for consultation (as described in Table 3.2, 

above), MANE-VU needed a consistent technical basis for emission control strategies to 

combat regional haze. After much research and analysis, on June 20, 2007, MANE-VU 

adopted the following pair of documents (available in Attachment D), which 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 U.S.: 

• “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.” 

Together, these documents are known as the MANE-VU “Ask.” Because Vermont agrees in 

total to the language and substance of these documents, the MANE-VU’s Ask is also the 

Vermont Ask. The particular emission management strategies that comprise the Ask are 

described in Subparts 3.2.2.1 through 3.2.2.3, below. 

3.2.2.1 Meeting the “Ask” – MANE-VU States 

The member states of MANE-VU have stated their intention to meet the terms of the Ask in 

their individual State Implementation Plans. The Ask for member states promises that each 

state will pursue the adoption and implementation of the following emission management 

strategies, as appropriate and necessary: 

• Timely implementation of BART requirements, in accordance with 40 CFR 

51.308(e). 

• 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% sulfur by weight (500 ppm) by no later than 2012, of #4 residual 

oil to 0.25% sulfur by weight by no later than 2012, of #6 residual oil to 0.3-0.5% 

sulfur by weight by no later than 2012, and to reduce the sulfur content of distillate oil 

further to 15 ppm by 2016; 

• A low-sulfur fuel oil strategy in the outer zone states (the remainder of the 

MANE¬VU region) to reduce the sulfur content of distillate oil to 0.05% sulfur by 

weight (500 ppm) by no later than 2014, of #4 residual oil to 0.25-0.5% sulfur by 
32

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

weight by no later than 2018, and to reduce the sulfur content of distillate oil further to 

15 ppm by 2018, depending on supply availability; 

• A targeted EGU strategy for the top 100 electric generating unit (EGU) emission 

points, or stacks, identified by MANE-VU as contributing to visibility impairment at 

each mandatory Class I area in the MANE-VU region. (The combined list for all 

seven MANE-VU Class I Areas contains 167 distinct emission points. Consequently, 

this strategy is sometimes referred to as the 167-stack strategy.) The targeted EGU 

strategy calls for a ninety percent or greater reduction in sulfur dioxide (SO2) 

emissions from all identified units. If it is infeasible to achieve that level of reduction 

from specific units, equivalent alternative measures will be pursued in such state; and 

• Continued evaluation of other control measures, including improvements in 

energy efficiency, use of alternative (clean) fuels, further control measures to reduce 

SO2 and nitrogen oxide (NOX) emissions from all coal-burning facilities by 2018, and 

new source performance standards for wood combustion. These and other measures 

will be evaluated during the consultation process to determine whether they are 

reasonable strategies to pursue. 

Vermont supports the SIPs of each of its fellow MANE-VU states, provided that these 

commitments are incorporated into approvable State Implementation Plans. 

3.2.2.2 Meeting the “Ask” – Vermont 

Vermont, being a MANE-VU member state, adopted the Ask at the MANE-VU Board 

meeting on June 7, 2007. Vermont contains no BART-eligible sources, but intends to meet 

the terms of the MANE-VU agreement by pursuing the low-sulfur fuel oil strategy. Vermont 

intends to adopt a rule specifying the low sulfur fuel limits for “outer zone” MANE-VU states 

in the near future. After this rule is adopted, Vermont will submit the rule to EPA for 

approval into the Vermont SIP. Vermont will also continue investigating sources of cleaner 

energy. 

3.2.2.3 Meeting the “Ask” – States outside MANE-VU 

Vermont agrees with the MANE-VU Ask for consulting states outside the MANE-VU region. 

This Ask requests the affected states to pursue adoption and implementation of the following 

control strategies, as appropriate and necessary: 

• Timely implementation of BART requirements, as described for the MANE-VU 

states; 

• A targeted EGU strategy, as described for the MANE-VU states, for the top 167 

EGU stacks contributing the most to visibility impairment at mandatory Class I areas 

in the MANE-VU region, or an equivalent SO2 emission reduction within each state; 
33

• Installation of reasonable control measures on non-EGU sources by 2018 to 

achieve an additional 28 percent reduction in non-EGU SO2 emissions beyond current 

on-the-books/on-the-way (OTB/OTW) measures, resulting in an emission reduction 

that is equivalent to that from MANE-VU’s low-sulfur fuel oil strategy (see Section 

11.0, Long-Term Strategy); 

• Continued evaluation of other control measures, including additional reductions in 

SO2 and NOX emissions from all coal-burning facilities by 2018 and promulgation of 

new source performance standards for wood combustion. These and other measures 

will be evaluated during the consultation process to determine whether they are 

reasonable strategies to pursue. 

Vermont looks for each consulting state to address specifically, in its Regional Haze SIP, each 

element of the MANE-VU Ask. 

 

Vermont is concerned that non-MANE-VU states may be inclined not to adopt MANE-VU’s 

Ask because of the associated costs, potential conflicts, and relative lack of perceived benefits 

within their jurisdictions. On the basis of consultations held, MANE-VU members believe 

that some non-MANE-VU states will choose not to pursue reductions beyond CAIR controls 

and other measures pertaining to BART requirements. 

There are some positive exceptions, however. Many states of the MRPO are working with 

MANE-VU states to investigate the potential for widespread use of low-sulfur fuel oil and 

installation of emission controls on ICI boilers within their region. The Midwest states would 

be more likely than Southeast states to adopt a low-sulfur oil strategy because the VISTAS 

states do not have the same extent of fuel oil usage and lack the inventory infrastructure found 

in more northerly states. Both MRPO and VISTAS claim that a substantial portion of the top 

167 contributing EGU stacks will be controlled. However, instead of taking concrete actions 

on uncontrolled or under-controlled facilities, many of these states appear to be satisfied with 

meeting CAIR requirements and not looking beyond CAIR for additional emission 

reductions. Further discussion of these issues is provided in Part 3.2.4, below. 

3.2.3 Technical Ramifications of Differing Approaches 

MANE-VU states intended to develop a modeling platform that was common in terms of 

meteorology and emissions with each of the other nearby RPOs. The RPOs worked hard 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 corrections. Each 

rendition of emissions inventory improved its quality, but even a single update to one RPO’s 

emissions required each of the other RPOs to adopt the updates. With each rendition, the 

revised emissions had to be re-blended with the full set of emission files for all associated 

RPOs in the modeling domain. 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 

have contributed to SIP delays. The emission inventory conflicts have been excessively timeconsuming and caused most states to miss the official filing date of December 17, 2007. 
34

The RPOs also took differing perspectives on which version of the EGU dispatching model to 

use. At the beginning of the process, International’s Integrated Planning Model (IPM) version 

2.1.9 was available, and EPA agreed to its use for emissions preparation. Subsequently, IPM 

version 3.0 became available and was preferred by some users because of its updated fuel 

costs. MRPO adopted IPM v3.0 for its use, but VISTAS stayed with IPM v2.1.9. Rather than 

develop non-comparative datasets for its previous IPM analyses, MANE-VU opted also to 

remain with IPM v2.1.9. Therefore, for the three eastern RPOs, differing emissions 

assumptions eventually worked their way into the final set of modeling assumptions. 

 

MANE-VU’s most recent visibility projections take into account on-the-books/on-the-way 

(OTB/OTW) emissions control programs for 2018, and go further by including additional 

reasonable controls in the region, as developed through the MANE-VU Ask. It should be 

noted that other RPOs may not have included such measures in their final modeling and, as a 

result, may have been able to complete their analyses ahead of MANE-VU’s. Where that is 

the case, those states’ modeling results will be inconsistent with meeting the terms of the Ask 

– a situation that may not be adequately addressed in their individual SIPs. 

3.2.4 Consultation Issues 

40 CFR 51.308(d)(1)(iv) of the Regional Haze Rule describes another consultation 

requirement for Class I states. If a contributing state does not agree with a Class I state on its 

reasonable progress goal, the Class I state must describe in its SIP submittal the actions taken 

to resolve the disagreement. 

While states without Class I areas are required to consult at the request of states with Class I 

areas, the Regional Haze Rule does not actually require the states to agree on a common 

course of action. Instead, if agreement cannot be reached, the disagreement needs to be 

described in each state’s SIP along with a description of what actions were taken to resolve 

the disagreement. Most states willingly consulted with Vermont and took Vermont’s regional 

haze Ask under serious consideration. In fact, all of the MANE-VU states worked together to 

strategize on how to develop a common approach to meeting the Ask. All states involved in 

these discussions found that working together helped them to develop plans that would 

produce region-wide visibility and health benefits. In particular, reductions in SO2 emissions, 

because they would yield lower ambient concentrations of fine particle (PM2.5) pollution, 

would help all MANE-VU states in meeting the NAAQS and would have direct benefits to 

public health and welfare. 

Some states in the MRPO and VISTAS regions had interpretations of the requirements for 

BART and for establishing Reasonable Progress Goals which differed from those in the 

MANE-VU states. Some states claimed that CAIR alone set the standard for reasonableness. 

By this rationale, any measure more expensive than CAIR on a cost-per-ton basis would not 

be reasonable. A uniform rate of progress was all that some states felt was required; and if 

that set of conditions could be met with CAIR, then no other measures needed to be 

considered. Also a concern for Vermont is the possibility that some states may have 

performed modeling for establishment of reasonable progress goals without including the 

effects of a rigorous BART determination for the non-EGU sector. It is apparent that the 
35

various regions of the country have differing interpretations of how the Regional Haze Rule 

should be applied. 

 

In a letter to MANE-VU dated April 25, 2008 (Attachment E), VISTAS indicates that most 

actions beyond CAIR by states within this region would not be reasonable. MANE-VU takes 

a more rigorous position with respect to additional control measures – including the belief that 

controls on ICI boilers and use of low-sulfur fuels are reasonable measures and that it is not 

reasonable to assume reductions from EGUs for planning purposes unless they are explicitly 

incorporated into a State Implementation Plan. More specifically, MANE-VU believes that a 

sector-wide average of 50-percent control on coal-fired boilers and 75-percent control on oilfired boilers are reasonable targets that can be achieved cost-effectively. Also, MANE-VU 

believes that low sulfur fuels – even though they are less widely available in the Southeast 

U.S. than in the Northeast – still represent a reasonable control measure in light of the 

widespread requirement for use of such fuels throughout the MANE-VU region. The 

reasonableness of these additional controls is examined more fully in Section 10.0, 

Reasonable Progress Goals. 

During the consultation process, disagreements such as these were worked through to the 

maximum extent possible, and the results of these consultations are summarized below: 

• Situation: BART analyses and projected controls were not fully incorporated into the 

VISTAS emissions inventory provided to MANE-VU. VISTAS stated that they would 

further review BART-applicable controls. 

→ Outcome: In MANE-VU’s modeling to determine reasonable progress goals, 

MANE-VU made no adjustments to controls in the VISTAS region to reflect 

application of BART beyond the information that VISTAS provided. 

• Situation: The low-sulfur fuel oil strategy adopted by MANE-VU elicited concerns from 

MRPO and VISTAS as not being reasonable because of the limited availability of low-sulfur 

fuel oil and the historically lower usage of this fuel within their regions. 

→ Outcome: MANE-VU agreed to modify the Ask to reflect greater flexibility in 

providing for alternative measures that would produce a comparable rate of emission 

reductions. Accordingly, the Ask for non-MANE-VU states was modified to provide 

for an overall 28 percent reduction in SO2 emissions wherever they were found to be 

reasonable. In MANE-VU’s modeling to determine reasonable progress goals, SO2

emissions from non-EGU sources in non-MANE¬VU contributing states were 

reduced by this same amount. 

• Situation: MANE-VU received no response from other RPOs concerning non-EGU control 

measures that they did consider reasonable. 

→ Outcome: As a default position, MANE-VU’s modeling included emission 

adjustments for those regions based on MANE-VU’s own analyses of what constituted 

reasonable control measures from non-EGU sources (see Section 10.0, Reasonable 

Progress Goals). 
36

• Situation: The targeted EGU strategy was thought by some non-MANE-VU states to be too 

restrictive and too difficult to achieve. MANE-VU recognized that a 100¬percent compliance 

with this portion of the Ask was unlikely to occur because the CAIR trading market would 

probably dominate. However, MANE-VU had hoped that non-MANE-VU states would make 

a more concerted effort toward meeting this request. MANE-VU did receive a partial list of 

facilities that were expected to comply. 

→ Outcome: For the top contributing EGU stacks located within the MANE-VU, 

MRPO, and VISTAS regions, expected emission reductions resulting from the Ask 

were distributed among facilities on the basis of recommendations received during 

inter- and intra-regional consultations. To maintain the CAIR emissions budget as 

predicted by the modeling, excess emission reductions (also predicted by the 

modeling) were uniformly added back to EGUs in all three regions. 

While CAIR is the primary determinant of which EGUs among the top 167 stacks are to be 

fitted with emission controls, at the same time, MANE-VU recognized that these units are the 

primary sources affecting visibility in the MANE-VU states. For the initial planning, MANEVU has allowed flexibility as to how other RPOs meet the Ask. However, MANE-VU 

expects that, over time, these actual facilities will need to be controlled if significant 

improvements in visibility at affected Class I areas are to be realized. 

MANE-VU believes that the goals of the Ask will be attained only by means of binding 

obligations to EGU emission reductions beyond what CAIR was expected to provide. 

MANE-VU therefore maintains that additional federal action is needed to achieve the 

visibility benefits shown to be feasible through sensitivity modeling (see Attachment F, 

“MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, 

Pollution Apportionment, and Control Measure Benefits,” Feb. 7, 2008) and demonstrated to 

be available at reasonable cost (see Attachment H, Alpine Geophysics, LLC, “Documentation 

of 2018 Emissions from Electric Generating Units in the Eastern United States for MANEVU’s Regional Haze Modeling,” Revised Final Draft, April 28, 2008). 

MANE-VU’s position on this issue is formally expressed in its “Statement of the MidAtlantic / Northeast Visibility Union (MANE-VU) Concerning a Request for a Course of 

Action by the U.S. Environmental Protection Agency (EPA) toward Assuring Reasonable 

Progress,” adopted June 20, 2007. This statement, more commonly known as MANE-VU’s 

National Ask, is included in Attachment D. Although other RPOs did not adopt all of the 

same philosophies or processes for their regional haze SIPs, the consultation process 

maintains a central role in regional haze planning. Vermont is pleased with the significant 

opportunities identified for ongoing consultation with other states concerning long-term 

strategies not only for regional haze mitigation but also for improved air quality in general. 

Vermont and other MANE-VU states are committed to continuing consultation with states in 

the MRPO and VISTAS regions, through participation in the State Collaborative Process, in 

which new regional control strategies are discussed to reduce future emissions of multiple 

pollutants of common regional concern. 
37

3.2.5 State/Tribe and Federal Land Manager Coordination 

Vermont will continue to coordinate and consult with the Federal Land Managers 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 impairment in the 

mandatory Class I areas. 

40 CFR 51.308(i) of the Regional Haze Rule requires coordination between states/tribes and 

the Federal Land Managers (FLMs). Opportunities have been provided by MANE-VU for 

FLMs to review and comment on the technical documents developed by MANE-VU and 

included in this SIP. Vermont has identified agency contacts to the FLMs as required under 

40 CFR 51.308(i)(1). Vermont has consulted with the FLMs in the development of this plan 

and, in accordance with 40 CFR 51.308(i)(2), has provided the FLMs an opportunity for 

consultation, in person, at least 60 days prior to holding any public hearing on the SIP. 

On December 22, 2008, Vermont submitted a 12/18/08 draft of this Regional Haze SIP 

Revision to the Federal Land Management Agencies (FLMs), including the Forest Service of 

the U.S. Department of Agriculture and the National Park Service and U.S. Fish and Wildlife 

Service of the U.S. Department of the Interior (DOI) for a 60-day review and comment 

period. On January 15, 2009, Vermont submitted a slightly revised 1/15/09 draft of this 

Regional Haze SIP Revision for 30-day review and comment by the U.S. Environmental 

Protection Agency (EPA). The 1/15/09 draft was identical to the 12/18/08 draft with the 

exception that it included minor revisions to reflect the 12/23/08 D.C. Circuit Court decision 

to remand the EPA Clean Air Interstate (CAIR) Rule without vacatur. 

The 1/15/09 draft Regional Haze SIP revision was also posted on the Vermont APCD website 

at http://www.anr.state.vt.us/air/Planning/htm/DraftRegionalHazeSIP.htm and was noticed in the 

newspapers of record in Vermont on Thursday January 15, 2009. The newspaper notices and 

the APCD website provided an opportunity for public hearing to be held, if requested, on 

February 23, 2009 in Waterbury, Vermont. As no additional public comments or requests for 

a public hearing were received prior to February 17, 2009, the public hearing was cancelled. 

Vermont did receive written comments from the Forest Service and the Department of the 

Interior on February 19, 2009, and from EPA on February 24, 2009. These comments are 

included in Attachment H. Vermont has subsequently made a number of revisions which are 

incorporated into the current May 11, 2009 version of this VT Regional Haze SIP. A listing 

of the specific FLM and EPA comments and Vermont’s responses to them are summarized in 

the document entitled “Vermont Responses to FLM and EPA Comments” included in 

Attachment H. 

40 CFR 51.308(i)(4) requires procedures for continuing consultation between the states/tribes 

and FLMs on the implementation of the visibility protection program. Vermont will consult 

periodically with the FLMs as necessary on the status of the following implementation items. 

In particular, consultations will be conducted with the designated visibility protection 

program coordinators for the National Park Service, U.S. Fish and Wildlife Service, and the 

U.S. Forest Service on: 
38

1. Status of emissions strategies identified in the SIP as contributing to improvements 

in the worst-day visibility; 

2. Summary of major new source permits issued; 

3. Status of Vermont’s actions toward completing any future assessments or 

rulemakings on sources identified as probable contributors to visibility impairment, 

but not directly addressed in the most recent SIP revision; 

4. Any changes to the monitoring strategy or status of monitoring stations that might 

affect tracking of reasonable progress; 

5. Work underway for preparing the 5-year SIP review and/or 10-year SIP revision, 

including any items where the FLMs’ consideration or support is requested; and 

6. Summary of topics discussed in ongoing communications (e.g., meetings, emails, 

etc.) between Vermont and the FLMs regarding implementation of the visibility 

improvement program. 
39

4. Assessment of Baseline and Natural Visibility Conditions 

Pursuant to 40 CFR 51.308(d)(2) of the Regional Haze Rule, states must determine baseline 

and natural visibility conditions for each Class I area within their jurisdictions. This 

information allows states to assess current levels of visibility degradation and provides a basis 

for setting reasonable progress goals toward restoration of natural visibility conditions in 

Class I areas. 

The effectiveness of any plan to reduce regional haze in Class I areas is dependent on the 

availability of reliable data. The Interagency Monitoring of Protected Visual Environments 

(IMPROVE) program was established in 1985 to provide the data necessary to support the 

creation of Federal and State implementation plans for the protection of visibility in Class I 

areas. IMPROVE has made it possible to assess current visibility conditions, track changes in 

visibility, and identify the chemical species and emission sources responsible for visibility 

impairment. In particular, IMPROVE data were used to calculate baseline and natural 

conditions for MANE-VU Class I Areas. 

The IMPROVE monitors listed in Table 4.1 provide data representative of Class I Areas in 

the MANE-VU region. 

Table 4.1 IMPROVE Monitors for MANE-VU Class I Areas 

IMPROVE Site / Location Class I Area(s) Served Latitude, 

Longitude State

ACAD1 

Acadia National Park Acadia National Park 44.38, -68.26 ME 

BRIG1 

Brigantine National 

Wildlife Refuge 

Brigantine National 

Wildlife Refuge 39.47, -74.45 NJ 

GRGU1 

Great Gulf Wilderness 

Great Gulf Wilderness 

Presidential Range – Dry 

River Wilderness 

44.31, -71.22 NH 

LYBR1 

Lye Brook Wilderness Lye Brook Wilderness 43.15, -73.13 VT 

MOOS1 

Moosehorn Wilderness 

Moosehorn Wilderness, 

Roosevelt Campobello 

International Park 

45.13, -67.27 ME 

http://www.vista.circa.colostate.edu/views/ ; http://vista.cira.colostate.edu/improve/
40

4.1 Calculation Methodology 

In September 2003, EPA issued guidance for the calculation of natural background and 

baseline visibility conditions. The guidance provided a default method and described certain 

refinements that states might consider in order to tailor their estimates to any Class I areas not 

adequately represented by the default method. At that time, MANE-VU calculated natural 

visibility for each of the MANE-VU Class I Areas using the default method for the 20 percent 

best and 20 percent worst visibility days. MANE-VU also evaluated ways to refine the 

estimates. Potential refinements included 1) increasing the multiplier used to calculate 

impairment attributed to carbon, 2) adjusting the formula used to calculate the 20 percent best 

and worst visibility days, and 3) accounting for visibility impairment caused by 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 to visibility 

assessment. Therefore, default estimates were used with the understanding that this 

methodology would be reconsidered upon demonstrated improvements in the science. 

Once the technical analysis of visibility conditions was complete, MANE-VU provided an 

opportunity to comment to federal agencies and stakeholders. The proposed approach to 

visibility assessment 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 (EPRI), the Midwest Ozone Group (MOG), the Appalachian 

Mountain Club, the National Parks Conservation Association, the National Park Service, and 

the US Forest Service. 

Several comments supported the proposed approach in general; other comments were divided 

among four main topics: 1) the equation used to calculate visibility, 2) the statistical technique 

used to estimate the 20 percent best and worst visibility days, 3) the inclusion of 

transboundary effects and fires, and 4) the timing as to when new information should be 

included. All comments were reviewed and summarized by MANE-VU; and air directors 

were briefed on comments, proposed response options, and implications. Attachment J 

provides a compilation of comments received and a summary of stakeholders’ comments. 

MANE-VU’s position on natural background conditions was presented in a report issued in 

June 2004 (see Attachment I, “Natural Background Visibility Conditions: Considerations and 

Proposed Approach to the Calculation of Natural Background Visibility Conditions at 

MANE-VU Class I Areas,” June 10, 2004). The report stated, “Refinements to other aspects 

of the default method (e.g., refinements to the assumed 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 SIPs depending on the degree to 

which scientific consensus is 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 scientific basis for these 

revisions was well understood, and the Committee determined that the revisions improved the 

performance of the equation at reproducing observed visibility at Class I sites. This Revised 

IMPROVE extinction equation was presented in Section 1.7 of this document. 
41

In 2006, MANE-VU conducted an assessment of the default and alternative approaches for 

calculation of baseline and natural background conditions at MANE-VU Class I Areas. Based 

on that assessment, in December 2006, MANE-VU recommended adoption of the alternative 

reconstructed extinction equation for use in the regional haze SIPs. (See Attachment J, 

“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,” December 2006.) MANE-VU will continue to participate in 

further research efforts on this topic and will reconsider the calculation methodology as 

scientific understanding evolves. 

4.2 MANE-VU Baseline 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 System (VIEWS) operated by the regional planning 

organizations. The information can be accessed at http://vista.cira.colostate.edu/views/) and 

is summarized in Table 4.2 below. Displayed are the five-year 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 to manmade emissions, which are the focus of the Regional 

Haze Rule. 

The five-year 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 found in Attachment J. 

Table 4.2 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 

2000-2004 

Baseline 

(deciviews) 

Natural 

Conditions 

(deciviews) 

Difference 

(deciviews) 

Class I Area(s) 

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 7.7 22.8 3.7 12.0 3.9 10.8 

Lye Brook Wilderness 6.4 24.4 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 
42

4.3 Lye Brook Wilderness Baseline Visibility 

As indicated in the table above, the 2001-2004 baseline visibility for the Lye Brook 

Wilderness was 6.4 deciviews for the 20 percent best visibility days and 24.5 deciviews for 

the 20 percent worst visibility days. As described in the Section 5.0 Monitoring Strategy of 

this SIP, Vermont accepts designation of this monitoring site as representative of the Lye 

Brook Wilderness Area in accordance with 40 CFR 51.308(d)(2)(i). Tables 4.3 and 4.4 list the 

baseline visibility for the 20 percent best and 20 percent worst visibility days for each year of 

the period 2000-2004, from which the valid four-year average values in Table 4.2 were 

calculated. The averages were determined in accordance with 40 CFR 51.308(d)(2), as 

detailed in the NESCAUM Baseline and Natural Background document found in Attachment 

J of this SIP. The deciview visibility values for best and worst days were obtained from data 

included in Attachment J. 

Table 4.3 Baseline Visibility for the 20 Percent Best Days During 2000-2004 in the Lye Brook Wilderness 

Area 

Class I Area(s) Year Deciviews (dv)

2000 6.5 

2001 6.5 

2002 6.4 

2003 5.8 

2004 6.6 

Lye Brook Wilderness Area 

Average 6.4

Source: VIEWS ( http://vista.circa.colostate.edu/views ) 

Table 4.4 Baseline Visibility for the 20 Percent Worst Days During 2000-2004 in the Lye Brook 

Wilderness Area 

Class I Area(s) Year Deciviews (dv) 

2000 23.5 

2001 26.3 

2002 25.5 

2003 24.0 

2004 22.9 

Lye Brook Wilderness Area 

Average 24.4 

Source: VIEWS ( http://vista.circa.colostate.edu/views ) 
43

4.4 Lye Brook Wilderness Area – Natural Background 

Natural background refers to the visibility conditions that existed before human activities 

affected air quality in the region. Consistent with the stated visibility goals of the Clean Air 

Act, natural background is identified as the visibility target to be reached by 2064 in each 

Class I area. 

The Lye Brook Wilderness Area has an estimated natural background visibility of 2.8 

deciviews on the 20 percent best days and 11.7 deciviews on the 20 percent worst days. These 

best and worst 20 percent visibility values were calculated using the above-referenced EPA 

guidelines and approved alternative method described in NESCAUM’s Baseline and Natural 

Background document (Attachment J). This method of calculating natural background using 

the revised IMPROVE algorithm is also described in detail by Copeland et al. (2008)* and the 

calculations are available on the VIEWS website at: 

http://vista.cira.colostate.edu/Docs/IMPROVE/Aerosol/NaturalConditions/NaturalConditionsII_Format2_v2.xls.

 

* Copeland, S. A., M. Pitchford and R. Ames (2008) Regional Haze Rule Natural Level Estimates Using the 

Revised IMPROVE Aerosol Reconstructed Light Extinction Algorithm, AWMA Specialty Conference on 

Aerosol & Atmospheric Optics: Visual Air Quality and Radiation at Moab, Utah, April 2008
44

5. Monitoring Strategy 

In the mid-1980’s, the IMPROVE program (Interagency Monitoring of Protected Visual 

Environments) 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 the U.S. EPA, 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 and 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. 

5.1 IMPROVE Program Objectives and Vermont Monitoring 

Commitments 

Data collected at these sites are used by land managers, industry planners, scientists, public 

interest groups, and air quality regulators to understand and protect the visual air quality 

resource in Class I areas. Most importantly, the IMPROVE program scientifically documents 

for American citizens, the visual air quality of their wilderness areas and national parks. 

Program objectives include: 

• Establish current visibility and aerosol conditions in mandatory Class I areas, 

• Identify chemical species and emission sources responsible for existing anthropogenic 

visibility impairment, 

• Document long-term trends for assessing progress towards the national visibility goals, 

• Provide regional haze monitoring representing all visibility-protected federal Class I areas 

where practical, as required by EPA’s Regional Haze Rule. 

Section 51.308(d)(4) of EPA’s Regional Haze Rule requires a monitoring strategy for 

measuring, characterizing, and reporting regional haze visibility impairment that is 

representative of the mandatory Class I Lye Brook Wilderness Area within the State of 

Vermont. The monitoring strategy relies upon participation in the Interagency Monitoring of 

Protected Visual Environments (IMPROVE) network. 

The State/Tribe will evaluate the monitoring network periodically and make those changes 

needed to be able to assess whether reasonable progress goals are being achieved in the Lye 

Brook Wilderness Area. Vermont commits to meet the requirements under 40 CFR 

51.308(d)(4)(iv) to report to EPA visibility data for the Lye Brook Wilderness Area annually, 

via the VIEWS (Visibility Information Exchange Web Site) at: 

http://vista.cira.colostate.edu/views/ ) . 

Section 51.308(d)(4)(ii) of EPA’s Regional Haze Rule requires the inclusion of procedures by 

which monitoring data and other information are used in determining the contribution of 

emissions from within the State to regional haze visibility impairment at mandatory Class I 
45

Federal areas both within and outside the State. MANE-VU and the State of Vermont accepts 

the contribution assessment analysis completed by NESCAUM entitled, Contributions to 

Regional Haze in the Northeast and Mid-Atlantic States. See Attachment A and associated 

appendices. We agree that NESCAUM is providing quality technical information by using the 

IMPROVE program data and the VIEWS site. Information about the use of the default and 

alternative approaches to the calculation of baseline and natural background conditions can be 

found in Section 4 Assessment of Baseline, Natural and Current Conditions of this SIP. 

Section 51.308 of the Federal Regulation Haze Rule requires each state containing a 

mandatory Class I Federal area to include in its SIP a strategy for evaluating reasonably 

attributable visibility impairment (RAVI) in any such Class I Area by visual observation or 

other appropriate monitoring techniques. The plan must provide for the consideration of 

available visibility data and must provide a mechanism for its use. This requirement does not 

apply to the State of Vermont because no specific sources have been identified as subject to 

RAVI requirements. 

Section 51.308(d)(4)(v) of EPA’s Regional Haze Rule requires a statewide inventory of 

emissions of pollutants that are reasonably anticipated to cause or contribute to visibility 

impairment in mandatory Class I Federal areas within the State of Vermont. The Emissions 

Inventory Section (Section 7) of this SIP addresses this requirement. 

Section 51.308(d)(4)(vi) of EPA’s Regional Haze Rule requires the inclusion of other 

monitoring elements, including reporting, recordkeeping, and other measures, necessary to 

assess and report visibility. While the state of Vermont feels that the current 

IMPROVE network provides sufficient data to adequately measure and report progress 

toward the goals set for MANE-VU and other Class I sites that we may contribute to, 

Vermont has also found additional monitoring information useful to assess visibility and fine 

particle pollution in the region in the past. Examples of these data include results from the 

MANE-VU RAIN network, which provides continuous, speciated information on rural 

aerosol characteristics and visibility parameters; the EPA CASTNET program, which has 

provided complementary rural fine particle speciation data at non-class I sites; the 

EPA Speciation Trends Network (STN), which provides speciated, urban fine particle data to 

help develop a comprehensive picture of local and regional sources; state-operated rural and 

urban speciation sites using IMPROVE or STN methods; and the Supersites program, which 

has provided information through special studies that generally expands our understanding of 

the processes that control fine particle formation and transport in the region. Vermont will 

continue to utilize these and other data -- as they are available and fiscal realities allow -- to 

improve our understanding of visibility impairment and to document progress toward our 

reasonable progress goals under the Regional Haze Rule. 

5.2 Lye Brook Wilderness, Vermont - Monitor Location 

The IMPROVE monitor for the Lye Brook Wilderness Area (indicated as LYBR1) is located 

on Mount Equinox at the windmills in Manchester Vermont. (see Figures 5.1 through 5.3) 

The monitor is not in the Wilderness Area but is located on a mountain ridge across the valley 

to the west of the wilderness. The Wilderness Area is at high elevation in the Green 
46

Mountains and the IMPROVE site across the valley is at about the same height as the 

Wilderness Area at 1015 meters elevation, a latitude of 43.15 ̊ and a longitude of -73.13 ̊. 

5.3 Lye Brook Wilderness Monitoring Strategy 

The haze data for Lye Brook Wilderness Area is collected by an IMPROVE monitor 

(LYBR1) that is operated and maintained by the Forest Service. The State considers the 

LYBR1 site as adequate for assessing reasonable progress goals of the Lye Brook Wilderness 

Area and no additional monitoring sites or equipment are necessary at this time. Vermont 

routinely participates in the IMPROVE monitoring program by serving as the NESCAUM 

regional representativeto the IMPROVE Steering Committee. Vermont is committed to 

working with other state, regional and federal IMPROVE partners to assure that adequate 

resources are available to provide continued monitoring representative of visibility conditions 

and trends in Lye Brook and other Class 1 areas. 

Figure 5.1 Lye Brook Wilderness Area Location 

Vermont currently lacks the funding and personnel resources to support enhancements to 

existing IMPROVE visibility monitoring at Lye Brook, but would be interested in discussing 

future options, including possibilities for sharing a haze camera with multiple Class I areas, 

with the Forest Service, other states and/or other Federal Land Management agencies. 

Additional details on the Lye Brook IMPROVE monitoring site, and on use of the aerosol 

monitoring data to calculate extinction are provided in Section 1 of this Plan. 
47

Figure 5.2 Map of Lye Brook Wilderness Area and the IMPROVE Monitoring site 

Figure 5.3 Lye Brook IMPROVE Monitoring Site on Little Mt. Equinox 
48

6. Emission Inventory 

40 CFR 51.308(d)(4)(v) of EPA’s Regional Haze Rule requires a statewide emissions 

inventory of pollutants that are reasonably 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) year, and the most recent year for which data are available. 

Vermont’s baseline year is 2002,. The pollutants inventoried by Vermont include nitrogen 

oxides (NOX), sulfur dioxides (SO2), volatile organic compounds (VOCs), fine particles 

(particulate matter less than 2.5 micrometers in diameter, or PM2.5), coarse particles 

(particulate matter less than 10 micrometers in diameter, or PM10), and ammonia (NH3). The 

following source categories were included in Vermont’s emissions inventory: stationary point 

sources, stationary area sources, on-road mobile sources, non-road mobile sources, and 

biogenic sources. These emissions categories are discussed further in Subsection 7.3, Model 

Platforms. 

6.1 Baseline and Future-Year Emissions Inventories for Modeling 

40 CFR 51.308(d) (3) (iii) of EPA’s Regional Haze Rule requires that the State of Vermont 

identify the baseline emissions inventory on which emission control strategies are founded. 

The baseline inventory is intended to be used for assessing progress in making emission 

reductions. In accordance with EPA’s guidance memorandum “2002 Base Year Emission 

Inventory SIP Planning: 8-hour Ozone, PM2.5, and Regional Haze Programs,” November 18, 

2002, all of the MANE-VU states are using 2002 as the baseline year for regional haze. 

With contractor assistance, MARAMA developed a 2002 baseline modeling inventory using 

the inventories that Vermont and other states submitted to EPA to meet their SIP obligations 

and the requirements of the Consolidated Emissions Reporting Rule (CERR). To create the 

2002 baseline inventory for modeling, MARAMA and its contractor quality-assured and 

augmented states’ inventories and generated the necessary input files for the emissions 

processing model. As described in Part 6.1.1 below, work on this effort underwent several 

versions. Therefore, the 2002 baseline emissions summarized in this document may differ 

slightly from Vermont’s original 2002 baseline inventory submittal. 

Future-year inventories for 2009, 2012, and 2018 were projected from the 2002 base year. 

These future-year emissions inventories include emissions growth due to projected increases 

in economic activity as well as emissions reductions expected from the implementation of 

control measures. While the 2009 and 2012 emissions projections were originally developed 

in support of other MANE-VU states’ ozone attainment demonstrations, the inventory for 

2018 (the year targeted by the Regional Haze Rule) was developed for the specific purposes 

of regional haze SIP planning. Therefore, although the 2009 and 2012 projected inventories 

are mentioned in subsequent sections, only the 2002 baseline inventory and 2018 projected 

inventory are described below in Subsection 6.4, Summary of Emissions Inventories. 

Accurate baseline and future-year emissions inventories are crucial to the analyses required 

for the regional haze SIP process. These emissions inventories were used to drive the air 

quality modeling simulations undertaken to assess the visibility improvements that would 
49

result from possible control measures. Air quality modeling was also used to perform a 

pollution apportionment, which evaluates the contribution to visibility impairment by 

geographic region and emission source sector. 

To be compatible with the air quality modeling simulations, the baseline and future-year 

emissions inventories were processed with the Sparse Matrix Operator Kernel Emissions 

(SMOKE) emissions pre-processor for subsequent input into the CMAQ and REMSAD air 

quality models described in Subsection 7.3. Further description of the base and future-year 

emissions inventories is provided below. 

6.1.1 Baseline Inventory (2002) 

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 Consolidated 

Emissions Reporting Rule (CERR). With contractor assistance (E.H. Pechan & Associates, 

Inc.,), MANE-VU then coordinated and quality-assured the 2002 inventory data, and prepared 

it for input into the SMOKE emissions model. The 2002 emissions from non-MANE-VU 

areas within the modeling domain were obtained from other Regional Planning Organizations 

for their corresponding areas. These Regional Planning Organizations included the Visibility 

Improvement State and Tribal Association of the Southeast (VISTAS), the Midwest Regional 

Planning Organization (MRPO), and the Central Regional Air Planning Association 

(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 completed during January 2005. Work on Version 2 (covering the period of April 

through September 2005) involved incorporating revisions requested by some MANE-VU 

state/local agencies on the point, area, and on-road categories. Work on Version 3 (covering 

the period from December 2005 through April 2006) included additional revisions to the 

point, area, and on-road categories as requested by 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 mobile 

emissions model. 

Version 3 of the MANE-VU 2002 baseline 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 E.H. Pechan & Associates, Inc., 

“Technical Support Document for 2002 MANE-VU SIP Modeling Inventories, Version 3, 

November 20, 2006, also known as the Baseline Emissions Report (Attachment K). 

Emissions inventory data files are available on the MARAMA website at: 

http://www.marama.org/visibility/EI_Projects/index.html. 
50

6.1.2 Future-Year Emissions Inventories 

Future-year emissions inventories are provided in MACTEC’s technical support document, 

“Development of Emissions Projections for 2009, 2012, and 2018 for NonEGU Point, Area, 

and Nonroad Sources in the MANE-VU Region,” Final Report, February 28, 2007, also 

known as the Emission Projections Report (Attachment L). This document describes the data 

sources, methods, and modeling results for three future years, five emission source sectors, 

two emission control scenarios, seven pollutants, and eleven states plus the District of 

Columbia. The following summarizes the basic framework of the future-year inventories that 

were developed: 

• Projection years: 2009, 2012, and 2018; 

• Emission source sectors: point-source electric generating units (EGUs), point-source nonelectric generating units (non-EGUs), area sources, non-road mobile sources, and on-road 

mobile sources. 

• Emission control scenarios: 

- A combined 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 are not yet finalized but are expected to achieve 

additional emission reductions by 2009; and 

- A beyond-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. 

- 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: SO2 reductions at a set of 167 EGUs which 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 Best Available Retrofit 

Technology (BART) strategy for BART-eligible sources not controlled under other 

programs. 

 (Note: Refer to Section 11.0, Long-Term Strategy, for detailed descriptions of 

specific control strategies.) 

• Pollutants: ammonia, carbon monoxide (CO), oxides of nitrogen (NOX), sulfur dioxide 

(SO2), volatile organic compounds (VOCs), fine particulate matter (PM2.5, sum of filterable 

and condensable components), and coarse particulate matter (PM10, sum of filterable and 

condensable components). 

• States: Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New 

Jersey, New York, Pennsylvania, Rhode Island, and Vermont, plus the District of Columbia 

(all members of the MANE-VU region). 
51

6.2 Emission Processor Selection and Configuration 

The Sparse Matrix Operator Kernel Emissions (SMOKE) model was used to format the 

emissions inventories for use with the air quality models that are discussed in Subsection 7.3. 

SMOKE is primarily an emissions processing system, as opposed to a true emissions 

inventory preparation system, in which emissions estimates are simulated from “first 

principles.” This means that, with the exception of mobile and biogenic sources, SMOKE’s 

purpose is to provide an efficient, modern tool for converting emissions inventory data into 

the formatted emissions files required for a photochemical air quality model. The SMOKE 

emissions processing that was performed in support of the air quality modeling for regional 

haze is described further in Subsection 7.2. 

6.3 Inventories for Specific Source Categories 

There are five emission source classifications in the emissions inventory, as follows: 

• Stationary point, 

• Stationary area, 

• Non-road mobile, 

• On-road mobile, and 

• Biogenic. 

Stationary point sources are large sources that emit greater than a specified tonnage per 

year, as described below. Stationary area sources are those sources whose individual 

emissions are relatively small (i.e., dry cleaners, service stations, agricultural areas, fires, 

etc.), but because of the large number of these sources, their collective emissions are 

significant. Non-road mobile sources are equipment that can move but do not use the 

roadways (i.e., lawn mowers, construction equipment, railroad locomotives, marine vessels, 

aircraft, etc.). On-road mobile sources include automobiles, trucks, buses, and motorcycles 

that use the roadway system. Biogenic sources include natural sources such as trees, crops, 

grasses, and natural decay of plants. 

The subsections below give an overview of each of the source categories and the methods that 

were used to develop their corresponding baseline and future-year emissions estimates. All 

emissions data were prepared for modeling in accordance with EPA guidance. 

6.3.1 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 sourcespecific parameters. Emissions estimates for point sources are usually made on a regular 

basis, and the largest point sources are inventoried annually. Sources with emissions greater 

than or equal to 100 tons per year (tpy) of a criteria pollutant, 10 tpy of a single hazardous air 

pollutant (HAP), or 25 tpy for total HAPs are considered to be major sources. Emissions 

from smaller point sources are also calculated individually but less frequently. Point sources 

are further subdivided into EGUs and non-EGUs. 
52

6.3.1.1 Electric Generating Units (EGUs) 

The base-year inventory for EGU sources were based on 2002 continuous emissions 

monitoring (CEM) data reported to EPA in compliance with the Acid Rain Program or 2002 

state emissions inventory data. The CEM data provided actual hourly emission values used in 

the modeling of SO2 and NOx emissions from these large sources. Emissions of other 

pollutants (e.g., VOCs, CO, NH3, and PM2.5) were provided by the states in most instances. 

 

Future-year inventories of EGU emissions for 2009, 2012 and 2018 were developed using 

ICF International’s Integrated Planning Model (IPM) to forecast growth in electric demand 

and replacement of older, less efficient and more polluting power plants with newer, more 

efficient and cleaner units. This effort was undertaken by an inter-RPO workgroup. While the 

output of the IPM model predicts that a certain number of older plants will be replaced by 

newer units to meet future electric growth and state-specific NOx and SO2 caps, the 

Vermont/MANE-VU inventory did not directly rely on the closure of any particular plant in 

establishing the 2018 inventory upon which the reasonable progress goals were set. 

The IPM model results do not provide a reliable basis upon which to predict EGU closures. 

Specific plant closures in the Vermont / MANE-VU inventory are addressed in Section 11.0, 

Reasonable Progress Goals. Preliminary modeling was performed with unchanged IPM 2.1.9 

model results. However, prior to the most recent modeling, future-year EGU inventories were 

adjusted as follows: 

• First, IPM predictions were reviewed by permitting and enforcement staff of the 

MANE-VU states. In many cases, staff believed that the IPM shutdown predictions were 

unlikely to occur. In particular, many oil-fired EGUs in urban areas were predicted to be shut 

down by IPM. Similar source information was solicited from states in both VISTAS and 

MRPO. As a result of this model validation, the IPM modeling output was adjusted before the 

most recent modeling to reflect staff knowledge of specific plant status in MANE-VU, 

VISTAS, and MRPO states. Where expected EGU operating status was contrary to what was 

predicted by IPM modeling, the future-year emissions inventory was adjusted to reflect the 

expected operation of those plants. 

• Second, as a result of inter- and intra-RPO consultations, MANE-VU agreed to pursue 

certain emission control measures (see Section 3.0, Regional Planning). For EGUs, the 

agreed-upon approach was to pursue emission reductions from each of the top 167 stacks 

located in MANE-VU, MRPO, and VISTAS that contributed the most to visibility 

impairment at any Class I area in the MANE-VU region. This approach, known as the 

targeted EGU strategy, is further described in Section 11.0 of this SIP. 

6.3.1.2 Non-EGU Point Sources 

The primary basis for the 2002 baseline non-EGU emissions inventory was data reported by 

state and local agencies for the CERR. As described in Part 6.1.1, MANE-VU’s contractor, 

E.H. Pechan & Associates (Pechan), coordinated the quality assurance of the inventory and 

prepared the necessary files for input into the SMOKE emissions model. Further information 
53

on the preparation of the MANE-VU 2002 baseline point source modeling emissions 

inventory can be found in Chapter II of the Baseline Emissions Report (Attachment K). 

Projected non-EGU point source emissions were developed for the MANE-VU region by 

MACTEC Federal Programs, Inc. under contract to Mid-Atlantic Regional Air Management 

Association (MARAMA). The specific methodologies that were employed are described in 

Section 2 of the Emission Projections Report (Attachment L). MACTEC used state-supplied 

growth factor data, where available, to project future-year emissions. Where state-supplied 

data were not available, MACTEC used EPA’s Economic Growth and Analysis System, 

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 expected emissions reductions that will take place under the OTB/OTW and 

BOTW scenarios. 

6.3.2 Stationary Area Sources 

Stationary area sources include sources whose individual emissions are relatively small but, 

because the number of sources is large, their collective emissions are significant. Some 

examples include dry cleaners, service stations, and residential heating. For each area source, 

emissions are estimated by multiplying an appropriate emission factor by some known 

indicator of collective activity, such as fuel usage, 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. MANE-VU’s consultant, Pechan, 

prepared the area source modeling inventory using the CERR submittals as a starting point. 

Pechan quality-assured the inventory and augmented it with additional data, including 

MANE-VU-sponsored inventories for categories such as residential wood combustion and 

open burning. Details on the preparation of MANE-VU’s 2002 baseline area source emissions 

inventory can be found in Chapter III of the Baseline Emissions Report (Attachment K). 

In similar fashion, MACTEC prepared future-year area source emission projections for the 

MANE-VU region. The specific methodologies employed are described in Section 3 of the 

Emission Projections Report (Attachment L). MACTEC applied growth factors to the 2002 

baseline area source inventory using state-supplied data, where available, or using the EGAS 

5.0 growth factor model. MACTEC also accounted for the appropriate control strategies in 

the future year projections. 

6.3.3 Non-Road Mobile Sources 

Non-road mobile sources are equipment that can move but do not use the roadways, such as 

construction equipment, aircraft, railroad locomotives, and lawn & garden equipment. For the 

majority of non-road mobile sources, emissions are estimated using the EPA’s NONROAD 

model. Aircraft, railroad locomotives, and commercial marine vessels are not included in the 

NONROAD model; and their emissions are estimated using applicable references and 

methodologies. Again, Pechan prepared the 2002 baseline modeling inventory using the state 

and local CERR submittals as a starting point. Details on the preparation of the 2002 baseline 
54

non-road inventory are described in Chapter IV of the Baseline Emissions Report 

(Attachment K). 

 

Future-year non-road mobile source emissions were projected for the MANE-VU region by 

MACTEC. The methodologies employed are discussed in Section 4 of the Emission 

Projections Report (Attachment L). MACTEC used EPA’s NONROAD2005 non-road 

vehicle emissions model as contained in EPA’s National Mobile Inventory Model (NMIM). 

Since the calendar year is an explicit input into the NONROAD model, future-year emissions 

for non-road vehicles could be calculated directed for the applicable projection years. For the 

non-road vehicle types that are not included in the NONROAD model (i.e. aircraft, 

locomotives, and commercial marine vessels), MACTEC used the 2002 baseline inventory 

and the projected inventories that EPA developed for these categories for the Clean Air 

Interstate Rule (CAIR) to develop emission ratios and subsequent combined growth and 

control factors. Since the future years for the CAIR projections did not precisely match those 

required for the purposes of ozone, particulate matter, and regional haze analyses (i.e. 2009, 

2012, and 2018), MACTEC used linear interpolation to develop factors for the required future 

years. 

6.3.4 On-Road Mobile Sources 

The on-road emissions source category consists of vehicles that are meant to travel on public 

roadways, including cars, trucks, buses, and motorcycles. The basic methodology used for 

on-road mobile source calculations is to multiply vehicle-miles-traveled (VMT) by emission 

factors developed using the EPA’s MOBILE6 motor vehicle emission factors model. The onroad mobile category requires that SMOKE model inputs be prepared instead of the 

SMOKE/IDA emissions data format that is required by the other emission source categories. 

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 by NESCAUM for the MANEVU region for ozone, particulate matter, and regional haze SIP purposes. As with the other 

emissions source categories, projected on-road mobile inventories were developed for 

calendar years 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 years. 

Using the inputs supplied by the MANE-VU member states, NESCAUM compiled and 

generated the required SMOKE/MOBILE6 emissions model inputs. Further details regarding 

the on-road mobile source projections can be found in NESCAUM’s “Technical 

Memorandum, Development of MANE-VU Mobile Source Projection Inventories for 

SMOKE/MOBILE6 Application,” June 2006 (Attachment M). 

6.3.5 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 Biogenic Emissions Inventory System (BEIS) 

Version 3.12 as contained within the SMOKE emissions processing model. Biogenic 
55

emissions estimates were made for CO, nitrous oxide (NO) and VOCs. Further details about 

the biogenic emissions processing can be found in NYSDEC’s technical support document 

TSD-1c, “Emission Processing for the Revised 2002 OTC Regional and Urban 12 km Base 

Case Simulations,” September 19, 2006 (Appendix P), and in Chapter VI of Pechan’s 

“Technical Support Document for 2002 MANE-VU SIP Modeling Inventories,” Version 3, 

November 20, 2006 (Appendix M). Biogenic emissions were assumed to remain constant for 

the future-years analysis. 

6.4 Summary of Vermont Emissions Inventories 

Vermont’s baseline and future-year emissions inventories are summarized in Tables 

6.1 through 6.4, below. All values are reported in tons per year (tpy). 

Table 6.1 2002 Emissions Inventory Summary Vermont (tpy) 

Emission Sector VOC NOX PM2.5 PM10 NH3 SO2 

Point 1,097 787 267 304 6,194 905

Area 23,265 3,208 11,065 56,131 9,848 4,087

Mobile 17,288 20,670 483 670 934 894

Non-Road Mobile 10,548 4,217 486 530 5 372

Biogenic 118,377 1,142

TOTAL 170,574 30,024 12,300 57,634 16,981 6,258

Table 6.2 2018 OTB/OTW Emissions Inventory Summary for Vermont (tpy) 

Emission Sector VOC NOX PM2.5 PM10 NH3 SO2 

Point 1,733 571 271 322 9 1,162

Area 26,198 3,430 12,059 66,916 14,580 4,764

Mobile 4,072 4,744 144 145 936 82

Non-Road Mobile 7,566 2,262 303 331 6 13

Biogenic 118,377 1,142

TOTAL 157,946 12,149 12,777 67,714 15,531 6,020

Table 6.3 2018 BOTW Emissions Inventory Summary for Vermont (tpy) 

Emission Sector VOC NOX PM2.5 PM10 NH3 SO2 

Point 1,710 571 271 322 9 1,162

Area 26,196 3,430 12,060 66,916 14,580 4,764

Mobile 4,072 4,744 144 145 936 82

Non-Road Mobile 7,566 2,262 303 331 6 13

Biogenic 118,377 1,142

TOTAL 157,921 12,149 12,778 67,714 15,531 6,020
56

It may be noted that there is virtually no change in Vermont’s estimated emissions from the 

2018 OTB/OTW scenario to the 2018 BOTW (beyond on the way) scenario. This is because 

Vermont is currently in attainment of old (and new) NAAQS for both ozone and PM2.5 (nor is 

VT a CAIR state for ozone or PM2.5). Thus no additional emissions reductions are anticipated 

for those specific programs. 

Table 6.4 2018 Most Recent (“Updated Scenario”) Emissions Inventory Summary for Vermont (tpy) 

Emission Sector VOC NOX PM2.5 PM10 NH3 SO2 

Point 1,711 572 271 322 9 407

Area 26,197 3,430 7,214 22,585 14,580 2,990

Mobile 4,072 4,744 144 145 936 82

Non-Road Mobile 7,566 2,262 303 331 6 13

Biogenic 118,377 1,142

TOTAL 157,922 12,149 7,932 23,383 15,531 3,493
57

7. Air Quality Modeling 

Air quality modeling to assess regional haze has been performed cooperatively between 

Vermont and its regional planning organization, MANE-VU. These modeling efforts include 

emissions data processing, meteorological input analyses, and chemical transport modeling to 

perform regional air quality simulations for calendar year 2002 and several future periods, 

including the primary target date, 2018, for this SIP. Modeling was conducted in order to 

assess contributions from upwind areas as well as Vermont’s contribution to Class I areas in 

downwind states. Further, the modeling evaluated visibility benefits of specific control 

measures being considered to achieve reasonable progress goals and establish a long-term 

emissions management strategy for MANE-VU Class I Areas. 

Several modeling tools were utilized for these analyses: 

• 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 

system was used to process and format the emissions inventories for input into the air 

quality models. 

• The Community Mesoscale Air Quality model (CMAQ) was used for the primary 

SIP modeling. 

• The Regional Model for Aerosols and Deposition (REMSAD) was used during 

contribution apportionment. 

• The California Puff Model (CALPUFF) and its associated meteorological wind field 

pre-processor (CALMET) 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 adequately. The SIP-pertinent 

modeling underwent full performance testing, and the results were found to meet the 

specifications of EPA modeling guidance. Modeling using CALPUFF for the contribution 

assessment of sulfate impacts at selected Class I receptor sites involved two different 

platforms for regional scale modeling which each used the exact same source inputs but 

different meteorological inputs, one using the MM5 meteorology and the other using National 

Weather Service Data driven CALMET wind fields. The two platforms were each evaluated 

separately as described in the NESCAUM report, “Contributions to Regional Haze in the 

Northeast and Mid-Atlantic United States”, August 2006 (Attachment A). 

For more details on the regional haze modeling, refer to the NESCAUM report, “MANE-VU 

Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution 

Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment F). The 

detailed modeling approach for the most recent 2018 projections can be found in 

NESCAUM’s “2018 Visibility Projections,” May 13, 2008 (Attachment O). 
58

7.1 Meteorology 

The meteorological inputs for the air quality simulations were developed by the University of 

Maryland (UMD) using the MM5 meteorological modeling system. Meteorological inputs 

were generated for 2002 to correspond with the baseline emissions inventory and analysis 

year. The MM5 simulations were performed on a nested grid (Figure 7.1). The modeling 

domain is composed of a 36-km, 145 x 102 continental grid and a nested 12-km, 172 x 172 

grid encompassing the eastern United States and parts of Canada. In cooperation with the 

New York State Department of Conservation (NYSDEC), an assessment was made for the 

period of May-September 2002 to compare the MM5 predictions with observations from a 

variety of data sources, including: 

• Surface observations from the National Weather Service and the Clean Air Status 

and Trends Network (CASTNET), 

• Wind-profiler measurements from the Cooperative Agency Profilers (CAP) 

network, 

• Satellite cloud image data from the UMD Department of Atmospheric and Oceanic 

Science, and 

• Precipitation data from the Earth Observing Laboratory at NCAR. 

Figure 7.1 National and Northeast Regional RPO Modeling Grid Domains 

 Note: Outer (blue) domain is 36-km grid. Inner (red) domain is 12-km grid. Gridlines are shown at 180-km 

intervals (5×5 36-km cells and 15×5 12-km cells). 
59

Further details regarding the MM5 meteorological processing and the modeling domain can 

be found in NYSDEC’s technical support document TSD-1a, “Meteorological Modeling 

Using Penn State/NCAR 5th Generation Mesoscale Model (MM5),” February 1, 2006 

(Attachment P), and in the NESCAUM report, “MANE-VU Modeling for Reasonable 

Progress Goals, Model Performance Evaluation, Pollution Apportionment, and Control 

Measure Benefits,” November 27, 2007 (Attachment F

7.2 Data Preparation 

Emissions data were prepared for input into the CMAQ and REMSAD air quality models 

using the SMOKE emissions modeling system. SMOKE supports point, area, mobile (both 

on-road and non-road), and biogenic emissions. The SMOKE emissions modeling system 

uses flexible processing to apply chemical speciation as well as temporal and spatial 

allocation to the emissions inventories. SMOKE incorporates the Biogenic Emission 

Inventory System (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-ready emissions file. Examples of processed emissions outputs are shown in Fig. 7. 2. 

Further details on the SMOKE processing conducted in support of the air quality simulations 

is provided in NYSDEC’s technical support document TSD-1c, “Emission Processing for the 

Revised 2002 OTC Regional and Urban 12 km Base Case Simulations,” September 19, 2006 

(Attachment N), and in NESCAUM’s report, “MANE-VU Modeling for Reasonable Progress 

Goals, Model Performance Evaluation, Pollution Apportionment, and Control Measure 

Benefits,” February 7, 2008 (Attachment G). Additional details on the emissions inventory 

preparation can be found in Section 6.0 of this plan. 

7.3 Model Platforms 

Two regional-scale air quality models, CMAQ and REMSAD, were used for the air quality 

simulations that directly supported the regional haze SIP effort. CMAQ was developed by 

EPA and was used to perform the primary SIP-related modeling. The CMAQ modeling 

simulations were also an important tool for the 8-hour ozone SIP process. REMSAD was 

developed by ICF Consulting/Systems Applications International with support from EPA. 

REMSAD was used by NESCAUM to perform a source apportionment (contribution 

assessment) analysis. All of the air quality simulations that were used in the SIP efforts were 

performed on the 12-km eastern modeling domain shown in Figure 7.11 above. 

NYSDEC performed an extensive model performance analysis to evaluate CMAQ model 

predictions against observations of ozone, PM2.5, and other pollutant species. This model 

performance evaluation is described in detail in NYSDEC’s technical support document 

TSD¬1e, “CMAQ Model Performance and Assessment, 8-Hr OTC Ozone Modeling,” 

February 23, 2006 (Attachment Q). A model performance evaluation for PM2.5 species, 

aerosol extinction coefficient, and the haze index is provided in NESCAUM’s report, 

“MANE-VU Modeling for Reasonable Progress Goals, Model Performance Evaluation, 

Pollution Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment F). 
60

Figure 7.2 Examples of Processed Model-Ready Emissions: (a) SO2 from Point, (b) NO2 from Area, (c) 

NO2 from On-Road, (d) NO2 from Non-Road, (e) ISOP from Biogenic, and (f) SO2 from all Source 

Categories 
61

7.3.1 CMAQ 

The CMAQ air quality simulations were performed cooperatively among five modeling 

centers: 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 7.1. 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 obtained from a run of the GEOS-Chem (Goddard Earth 

Observing System) 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 in NYSDEC’s technical support document TSD-1d, “8hr 

Ozone Modeling Using the SMOKE/CMAQ System,” February 1, 2006 (Attachment R). 

Further technical details regarding the CMAQ model and its execution are also provided in 

NESCAUM’s report, “MANE-VU Modeling for Reasonable Progress Goals, Model 

Performance Evaluation, Pollution Apportionment, and Control Measure Benefits,” February 

7, 2008 (Attachment G). 

7.3.2 REMSAD 

The REMSAD modeling simulations were used to produce the contribution assessment 

required by the Regional Haze Rule. REMSAD’s species tagging capability makes it an 

important tool for this purpose. The REMSAD model simulations were performed on the 

same 12-km eastern modeling domain as shown in Figure 7.1. NESCAUM’s report, 

“MANE-VU Modeling for Reasonable Progress Goals, Model Performance Evaluation, 

Pollution Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment G), 

further describes the REMSAD model and its application to the regional haze SIP efforts. 

7.3.3 CALPUFF 

CALPUFF is a non-steady-state Lagrangian puff model that simulates the dispersion, 

transport, and chemical transformation of atmospheric pollutants. Two parallel CALPUFF 

modeling platforms were developed by the Vermont Department of Environmental 

Conservation (VTDEC) and the Maryland Department of the Environment (MDE). The 

VTDEC CALPUFF modeling platform utilized meteorological observation 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 SIPs. These two platforms were run in parallel to 

evaluate individual states’ contributions to sulfate levels at Northeast and Mid-Atlantic Class I 

areas. 

The VTDEC CALPUFF modeling effort was tailored to accurately simulate long-term 

average flow patterns over the Northeastern U.S., in areas removed from the Atlantic 

coastline. The modeling effort was carefully evaluated for bias and error, both in the base 

meteorological fields and the final air pollution dispersion calculations. This modeling was 

performed in 2003 for calendar year 2002 meteorology and emissions and utilized a ‘beta’ 
62

model version, which, in 2003, was not yet formally approved by the EPA for Air Pollution 

applications. Since then, the fundamental changes to the CALPUFF modeling system that 

were first made available in the 2003 beta model version have been largely incorporated into 

the EPA- approved version. 

 The CALPUFF modeling system is designed to allow great variety in its application. One 

example is the scale of spatial transport modeled, which may range from less than a kilometer, 

to long range transport applications on the order of 200 kilometers or more. A fundamental 

manner in which the model performance may be ‘tailored’ for a given application, involves 

the interpolation methods for various observational, and/or prognostic model outputs that the 

CALMET models interpolates to produce final wind, temperature and other fields. In the 

VTDEC CALPUFF modeling for the contribution assessment a non-regulatory setting was 

the ‘radius of influence parameter’ for interpolation of surface stations. The default 

(recommended) setting was not used for ‘radius of influence parameter’ because evaluation of 

the wind fields produced when this parameter was set at the default mode (i.e. off), revealed 

problems with the wind fields in regions where the surface wind observations were sparse. 

The CALPUFF modeling effort is described in detail in NESCAUM’s report, “Contributions 

to Regional Haze in the Northeast and Mid-Atlantic United States,” August 2006 (Attachment 

A). 

7.4 References for Section 7 

Pennsylvania State University/National Center for Atmospheric Research. Mesoscale Model 

(MM5). http://www.mmm.ucar.edu/mm5/mm5-home.html. 

Center for Environmental Modeling for Policy Development, University of North Carolina at 

Chapel Hill. Sparse Matrix Operator Kernel Emissions (SMOKE) Model. 

http://www.smoke-model.org/index.cfm. 

 

Community Modeling and Analysis System (CMAS) Center, University of North Carolina at 

Chapel Hill. Community Multiscale Air Quality (CMAQ) Modeling System. 

http://www.cmaq-model.org. 

ICF International/Systems Applications International. Regional Modeling System for 

Aerosols and Deposition (REMSAD). http://remsad.saintl.com. 

Scire, J.S., Strimaitis, D.G., and Yamartino, R.J. A User’s Guide for the CALPUFF 

Dispersion Model (Version 5). January 2000. 
63

8. Understanding the Sources of Haze-Causing Pollutants 

This section explores the origins, quantities, and roles of visibility-impairing pollutants 

emitted in the eastern United States and Canada that contribute significantly to regional haze 

at MANE-VU’s mandatory Class I areas. 

8.1 Fine-Particle Pollutants 

The pollutants primarily responsible for fine particle formation, and thus contributing to 

regional haze, include SO2, NOX, VOCs, NH3, PM10, and PM2.5. The MANE-VU 

Contribution Assessment (Attachment A), finalized in August 2006, reflects a conceptual 

model in which sulfate emerges as the most important single constituent of haze-forming fine 

particle pollution and the principle cause of visibility impairment across the Northeast region. 

Sulfate alone accounts for anywhere from 1⁄2 to 2⁄3 of total fine particle mass on the 20 percent 

haziest days at MANE-VU Class I Areas. This translates to about 2⁄3 to 3⁄4 of visibility 

extinction on those days. Organic carbon was shown to be the second largest contributor to 

haze at MANE-VU Class I sites. 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 heavily on broad-based regional SO2

control measures in the eastern United States. 

Atmospheric light extinction is a fundamental metric used to characterize air pollution 

impacts on visibility. It is the fractional loss of intensity in a light beam per unit distance due 

to scattering and absorption by the gases and particles in the air. Extinction is expressed in 

units of inverse mega-meters (Mm-1). Light extinction, light scattering, and light absorption 

can be measured by transmissometer, nephelometer and aethalometer, respectively. 

Figure 8.1 Contributions to PM2.5 Extinction at 7 Class 1 Areas 

Extinction can also be 

calculated from measurements of aerosol species 

using equations such as those 

presented on page 1-14 of 

this plan. Figure 8.1 shows 

the dominance of sulfate in 

visibility extinction calculated 

from 2000-2004 baseline data 

for seven Northeast Class I 

Areas. 

 
64

8.2 Contributing States and Regions 

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

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

contribute to visibility impairment in MANE-VU and nearby Class I areas. Based on 

estimates obtained by several evaluation methods, emissions that originated within 

MANE¬VU states contributed approximately one-fourth of the total sulfate aerosol recorded 

at in the Lye Brook Wilderness Area in 2002. More specifically, four different estimation 

methods yielded the following contribution ranges: MANE-VU, 21-32 percent; MRPO, 22-27 

percent; VISTAS, 14-19 percent; CenRAP, 2-5 percent; Eastern Canada, 6-16 percent; and all 

other regions, 19 percent (see Tables 8.1 through 8.5 of the Contribution Assessment for 

details). These findings highlight the importance of emissions from outside MANE-VU to 

visibility impairment inside the region. Note that, although there is some variation in the 

contribution estimates among the different assessment methods employed, there is a general 

consistency of results from one method to another. 

Table 8.1 displays the results of one of the methods used (the REMSAD model) to assess 

state-by-state and regional contributions to annual sulfate impacts in nine Class I areas. 

Table 8.1 Percent Contributions (Mass Basis) of Individual States and Regions to total Annual Sulfate 

Impacts at Northeast Class I Areas (REMSAD)

Mandatory Class I Area

Contributing 

State or 

Region 

Acadia 

ME

Brigantine 

NJ

Dolly 

Sods 

WV

Great Gulf & 

Presidential 

Range – Dry 

River, NH

Lye 

Brook 

VT

Moosehorn & 

Roosevelt 

Campobello 

ME

Shenandoah 

VA

Connecticut 0.76 0.53 0.04 0.48 0.55 0.56 0.08 

Delaware 0.96 3.20 0.30 0.63 0.93 0.71 0.61 

District 

of 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 

MRPO 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 

CenRAP 0.88 1.12 1.58 1.65 1.67 0.82 1.48 

Canada 8.69 7.11 3.90 14.84 12.43 7.85 4.75 

Other 33.79 16.78 12.70 23.54 18.99 44.17 12.48 
65

Figures 8.2 and 8.3, also borrowed from the Contribution Assessment, illustrate several other 

simple methods for identifying and ranking individual states’ contributions to sulfate at 

northeastern Class I areas using the 2002 emissions data and regional meteorology. Figure 8.2 

shows results from a simple technique for deducing the relative impact of emissions from 

local and upwind source areas on specific receptor sites. It involves calculating the ratio of 

annual emissions (Q) to source-receptor distance (d). The ratio (Q/d) is then multiplied by a 

factor to account for the frequency effect of prevailing winds. The use of this technique is 

explained in the Contribution Assessment (see pages 4-12 to 4-17 of Attachment A). 

Figure 8.2 Ranked state percent sulfate contributions to Northeast Class I receptors based on emissions 

divided by distance (Q/d) results 

Results from another simple source apportionment method described in the Contribution 

Assessment are displayed here in Figure 8.3. In this method, an “upwind probability field is 

calculated for each receptor site using 5 years of backward air trajectory calculations. This 

long-term, climatological upwind probability field (UP) is then multiplied by the 2002 SO2

emissions data to provide an estimate of proportionate state by state contributions to sulfate 

contributions to the northern MANE-VU Class I Areas. The use of this technique is explained 

in the Contribution Assessment (see pages 4-17 to 4-19 of Attachment B). 

Although these techniques are relatively simple, it may be noted that they generally show 

proportions and rankings of upwind contributions which are quite similar to results from the 

more sophisticated CALLPUFF and REMSAD models. See for example the comparative 

ranking results in Figure 8.4, also borrowed from the Contribution Assessment. 
66

Figure 8.3 Ranked state percent sulfate contributions to Mid-Atlantic Class I receptors based on 

emissions times upwind probability (E x UP) results 

Figure 8.4 Comparison of normalized (percent contribution) results using different techniques for 

ranking state contributions to sulfate levels at the MANE-VU Class I sites 
67

The ranking of emission contributions to visibility impairment in the MANE-VU Class I 

Areas by methods such as these has direct relevance to the consultation process described 

previously in Section 3.0, Regional Planning and Consultation. Using results from the 

REMSAD model, MANE-VU applied the following three criteria to identify states and 

regions for the purposes of consultation on regional haze: 

1. Any state/region that contributed 0.1 μg/m3 sulfate or greater on the 20 percent 

worst visibility days in the base year (2002), 

2. Any state/region that contributed at least 2 percent of total sulfate observed on the 

20 percent worst visibility days in 2002, and 

3. Any state/region among the top ten contributors on the 20 percent worst visibility 

days in 2002. 

For the purposes of deciding how broadly to consult, the MANE-VU States settled on the 

second of the three criteria: any state/region that contributed at least 2 percent of total sulfate 

observed on the 20 percent worst visibility days in 2002. 

In Figures 8.5, states and regions meeting the three listed criteria are identified graphically for 

Lye Brook. Similar results are available for other MANE-VU and nearby Class I areas 

(Shenandoah and Dolly Sods in the VISTAS region that are impacted by emissions from 

MANE-VU states) in Attachment G (MANE-VU Modeling for Reasonable Progress Goals). . 

Figure 8.5 Modeled 2002 Sulfate Contributions at Lye Brook on the 20% Worst Days 
68

Figure 8-5 has three components: 

• On the left is a single bar graph of the IMPROVE-monitored PM2.5 mass 

concentration (μg/m3) by constituent species for the baseline years 2000-2004. The 

yellow, bottom 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. 

Vermont, Connecticut, Rhode Island, 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 

days and prevention of visibility degradation on the clearest days. 

8.3 Emission Sources and Characteristics 

As previously mentioned, the major pollutants responsible for regional haze are SO2, NOX, 

VOCs, NH3, PM10, and PM2.5. 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 for the purposes of this section 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 emissions 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 Emissions Trends database (NET) and the 1999 National Emissions Inventory 

(NEI)*. Trends among the three emissions inventories – NET 1996, NEI 1999, and MANEVU 2002 – are highlighted in the text and graphics presented below. 

 

* EPA's Emission Factor and Inventory Group, Office of Air and Radiation, Office of Air Quality Planning and Standards, 

Emissions, Monitoring and Analysis Division (EMAD) prepares a national database of air emissions information with input 

from state and local air agencies, tribes, and industry. This NEI database contains information on stationary and mobile 

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, in each area of the country on an annual basis. NEI includes 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 1985 through 1999 for criteria pollutants. NEI data help support air dispersion modeling, regional strategy 

development, setting regulations, air toxics risk assessment, and tracking trends in emissions over time. For inventories prior 

to 1999, the National Emission Trends (NET) database maintained criteria pollutant emissions, and the National Toxics 

Inventory (NTI) database maintained HAP emissions. 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.
69

8.3.1 Sulfur Dioxide (SO2) 

SO2 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 days and for as much as 80 percent or more on the haziest days. Hence, 

SO2 emissions are an obvious target of opportunity 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 SO2 emissions. In fact, in 1998, a single source category – 

coal-burning power plants – was responsible for two-thirds of total SO2 emissions nationwide 

(NESCAUM, 2001a). 

Figure 8.6 shows SO2 emission trends in the MANE-VU states extracted from the NEI 

database for the years 1996, 1999, and the 2002 MANE-VU inventory (EPA, 2005). Most of 

the states (with the exception of Maryland) show declines in 2002 annual SO2 emissions 

compared with 1996 emissions. While some states show an increase in emissions in 1999 

followed by a decline in 2002, others show consistent declines throughout the entire period. 

Figure 8.6 Trends in Annual Sulfur Dioxide (SO2) Emissions, by State 

The upward trend in emissions after 1996 in several states probably reflects electricity 

demand growth during the late 1990s combined with the availability of banked emission 

allowances resulting from initial over-compliance with control requirements in Phase 1 of 

EPA’s Acid Rain Program. This situation led to relatively low market prices for allowances 

later in the decade and encouraged utilities to purchase allowances rather than implement new 

controls as electricity output expanded. The observed decline in SO2 emissions in 2002 can be 

attributed to implementation of Phase 2 of the Acid Rain program, which in 2000 further 

reduced allowable emissions and extended emission limits to a greater number of power 

plants. 
70

Figure 8.7 2002 Sulfur Dioxide (SO2) Emissions, by State Bar Graph = Percentage Fractions of Four 

Source Categories Line Graph = Total Annual Emissions (106 tpy) 

The bar graph in Figure 8.7 displays the percentage contributions from different emission 

source categories to annual SO2 emissions in the MANE-VU states in 2002. The chart shows 

that point sources – consisting mainly of stationary combustion sources for generating 

electricity, industrial power, and heat – dominate SO2 emissions in the region. Smaller 

stationary combustion sources, referred to collectively as areas sources, are another important 

source category in the MANE-VU states. These include smaller industrial, commercial, and 

institutional boilers as well as residential heating sources. By contrast, on-road and non-road 

mobile sources make a relatively minor contribution to overall SO2 emissions in the region 

(NESCAUM, 2001a). 

8.3.2 Volatile Organic Compounds (VOC) 

Existing emissions inventories generally refer to volatile organic compounds (VOCs) as 

hydrocarbons whose volatility in the atmosphere makes them particularly important to ozone 

formation. From a regional haze perspective, there is less concern with the volatile organic 

gases emitted directly to the atmosphere than with the secondary organic aerosols (SOAs) that 

VOCs form after undergoing condensation and oxidation. Thus the VOC inventory category 

is of interest primarily because of the organic matter component of PM2.5. 

Particle phase organic matter is present in the atmosphere as thousands of complex mixtures 

composed primarily of organic carbon, oxygen and hydrogen. These organic compounds may 
71

be emitted directly from emission sources as components of primary PM or that may form in 

the atmosphere as secondary pollutants. After sulfate, organic matter generally accounts for 

the next largest share of fine particle mass and particle-related light extinction at northeastern 

Class I sites. The organic matter present at Class I areas includes a mix of pollutants 

originating from anthropogenic sources such as gasoline and diesel motor vehicles, biogenic 

hydrocarbons emitted by vegetation, and wood smoke from natural or anthropogenic fires. 

Recent efforts to cut back on manmade organic carbon emissions have been undertaken 

mainly for the purpose of reducing summertime ozone formation in urban centers. Future 

efforts to make further reductions in organic carbon emissions may be driven by programs 

that address fine particles and visibility. 

Understanding the source regions and transport dynamics for organic matter in MANE-VU 

and nearby Class I areas is likely to be more complex than for sulfate. This complexity 

derives from the large number and diversity of organic carbon species, the wide variation in 

their transport characteristics, and the fact that a given species may undergo numerous 

complex chemical reactions in the atmosphere. Thus, the organic carbon contribution to 

visibility impairment at most Class I areas in the region is likely to include manmade 

pollution from nearby sources, manmade pollution transported from a distance, and biogenic 

emissions – especially terpenes from coniferous forests. 

As shown in Figure 8.8, the VOC inventory is dominated by mobile and area sources. Onroad mobile sources of VOCs include evaporative emissions from transportation fuels and 

exhaust emissions from gasoline passenger vehicles and diesel-powered, heavy-duty vehicles. 

VOC emissions may also originate from a variety of area sources (including those that use 

organic solvents, architectural coatings, and dry cleaning fluids) as well as from some point 

sources (e.g., industrial facilities and petroleum refineries). 

Biogenic VOCs may play an important role within the rural settings typical of Class I areas. 

The oxidation of hydrocarbon molecules containing seven or more carbon atoms is generally 

the most significant pathway for the formation of light-scattering organic aerosol particles 

(Odum et al., 1997). Smaller reactive hydrocarbons that may contribute significantly to urban 

smog (ozone) are less likely to play a direct role in organic aerosol formation, although it is 

noted that high ozone levels can have an indirect effect on visibility by promoting the 

oxidation of other available hydrocarbons, including biogenic emissions (NESCAUM, 

2001a). In short, further work is needed to characterize the organic carbon contribution to 

regional haze in the MANE-VU states and to develop emissions inventories that will be of 

greater value for visibility planning purposes. 
72

Figure 8.8 2002 Volatile Organic Carbon (VOC) Emissions, by State Bar Graph = Percentage Fractions 

of Four Source Categories Line Graph = Total Annual Emissions (106 tpy)

8.3.3 Oxides of Nitrogen (NOX) 

NOX emissions contribute to visibility impairment in the eastern U.S. by forming lightscattering nitrate particles. Nitrate generally accounts for a substantially smaller fraction of 

fine particle mass and related light extinction than sulfate and organic carbon at northeastern 

Class I areas. Notably, nitrate may play a more important role in urban settings and in the 

wintertime. In addition, NOX may have an indirect effect on summertime visibility by virtue 

of its role in the formation of ozone, which in turn promotes the formation of secondary 

organic aerosols (NESCAUM, 2001a). 

Since 1980, nationwide emissions of NOX from all sources have shown little change. In fact, 

emissions increased by 2 percent between 1989 and 1998 (EPA, 2000a). This increase is most 

likely due to industrial sources and the transportation sector, as power plant combustion 

sources have implemented emission reductions during the same time period. Figure 8.9 shows 

NOX emissions in 1996, 1999, and 2002 for each state in the MANE-VU region. Most states 

experienced steadily declining NOX emissions between the two outer years. The exceptions 

were Massachusetts, Maryland, New York, and Rhode Island, where NOX emissions 

increased from 1996 to 1999 before declining to below-1996 levels in 2002. 
73

Figure 8.9 Trends in Annual Nitrogen Oxide (NOX) Emissions, by State 

Power plants and mobile sources generally dominate state and national NOX emissions 

inventories. Nationally, power plants account for more than one-quarter of all NOX emissions, 

amounting to over six million tons annually. The electric sector plays an even larger role in 

parts of the industrial Midwest, where power plants contribute significantly to NOX

emissions. By contrast, mobile sources dominate the NOX inventories for more urbanized 

MANE-VU states, as shown in Figure 8.10. 

 Figure 8.10 2002 Nitrogen Oxide (NOX) Emissions, by State Bar Graph = Percentage Fractions of Four 

Source Categories Line Graph = Total Annual Emissions (106 tpy) 
74

In these states, on-road mobile sources (i.e., highway vehicles) represent the largest NOX

source category. Emissions from non-road (i.e., off-highway) mobile sources, primarily 

diesel-powered engines, also make up a substantial fraction of the inventory. 

While there are fewer uncertainties associated with NOX emissions than with other key hazerelated pollutants (especially primary fine particulate and ammonia emissions), further efforts 

could improve the quality of current NOX emission inventories in a number of areas 

(NESCAUM, 2001a). Specifically, better information on the contribution of area and nonroad mobile sources may be of most interest in the context of regional haze planning. 

Available emission estimation methodologies are weaker for these types of sources than for 

the large stationary combustion sources. Moreover, because NOX emissions must mix with 

ammonia to participate in secondary ammonium nitrate particle formation, emissions that 

occur over large areas at the surface may be more efficient in secondary fine particulate 

formation than concentrated emissions from isolated tall stacks (Duyzer, 1994). 

8.3.4 Primary Particulate Matter (PM10 and PM2.5) 

Directly emitted, or “primary,” particles (as distinct from secondary particles that form in the 

atmosphere through chemical reactions involving precursor pollutants such as SO2 and NOX) 

can also contribute to regional haze. For regulatory purposes, a distinction is made between 

particulate matter (PM) with an aerodynamic diameter less than or equal to 10 micrometers 

(PM10) and smaller particles with an aerodynamic diameter less than or equal to 2.5 

micrometers (PM2.5). 

Figures 8.11 and 8.12 show PM10 and PM2.5 emissions, respectively, for the MANE-VU states 

for the years 1996, 1999, and 2002. Note that the inventory values for PM10 are drawn from 

the 2002 NEI. Most states show a steady decline in annual PM10 emissions over this time 

period. By contrast, emission trends for primary PM2.5 are more variable. 

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. Typically, monitors estimate PM10 emissions from these types 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 types of measurement techniques and observed concentrations of 

crustal matter in the ambient air at downwind receptor sites suggest that physical or chemical 

processes remove a significant fraction of crustal material relatively quickly. As a result, it 

rarely entrains into layers of the atmosphere where it can be transported to downwind receptor 

locations. Because of this discrepancy between estimated emissions and observed ambient 

concentrations, modelers typically reduce estimates of total PM2.5 emissions from all crustal 

sources by applying a factor of 0.15 to 0.25 to the total PM2.5 emissions before including them 

in modeling analyses. 
75

Figure 8.11 Trends in Primary Coarse Particle (PM10) Emissions, by State 

Figure 8.12 Trends in Primary Fine Particle (PM2.5) Emissions, by State 
76

From a regional haze perspective, crustal material generally does not play a major role. On 

the 20 percent best visibility days during the baseline period (2000-2004), crustal PM 

accounted for six to eleven percent of particle-related light extinction at MANE-VU Class I 

sites. On the 20 percent worst visibility days, however, crustal material generally plays a 

much smaller role than other haze-forming pollutants, contributing only two to three percent 

of light extinction, Moreover, the crustal fraction includes materials 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 influenced by construction, agricultural practices, and road maintenance 

(including wintertime salting). Thus, to the extent that these types of activities are found to 

affect visibility at Northeastern Class I areas, control measures targeted at crustal material 

may prove beneficial. 

Experience from the western United States, where the crustal component has played a more 

significant role in overall particulate and regional haze levels, may be applicable to the extent 

that it is relevant to the situation in the eastern states. In addition, a few areas in the 

Northeast, such as New Haven, Connecticut, and Presque Isle, Maine, have had some 

experience with the control of dust and road-salt stemming from regulatory obligations related 

to their past non-attainment status with respect to the NAAQS for PM10. 

Current emissions inventories for the entire MANE-VU area indicate that residential wood 

combustion represents 25 percent of primary fine particle emissions in the region. This 

finding implies that rural sources can play an important role as well as contributions from the 

region’s many populous urban areas. An important consideration in this regard is that 

residential wood combustion occurs mainly in the winter months, while wild fires as well as 

managed or prescribed burning activities occur largely in other seasons. The latter category 

includes agricultural field-burning, prescribed burning of forested areas, and miscellaneous 

burning activities such as construction waste burning. Particulate emissions from many of 

these sources can be managed by limiting allowed burning activities to times when favorable 

meteorological conditions can efficiently disperse the emissions. 

Many sections of the relatively high elevation of the Lye Brook Wilderness Area - and the 

Lye Brook IMPROVE monitor - are likely to be frequently above the mixed layer during the 

winter when (lower elevation) residential wood burning emissions are greatest. Thus winter 

wood smoke may be less of an important contributor to haze at Lye Brook than it is as a 

contributor to high winter PM2.5 concentrations in more populated, lower elevation mountain 

valley locations. In a receptor modeling analysis conducted for MANE-VU by Battelle Labs 

using the Positive Matrix Factorization (PMF) model, Coutant et al (2002) identified a 

“biomass combustion” (wood smoke) source at Lye Brook (based on 1991 to 1999 

IMPROVE data). The PMF-modeled wood smoke source accounted for nearly 1/3 of the 

average fine mass at Lye Brook, although its contribution was proportionately larger on the 

cleanest days than on the haziest days. Its average concentration was higher in the summer 

than in winter, consistent with forest fires rather than residential wood combustion. 

Figure 8.13, taken from the MANE-VU Contribution Assessment, shows the trajectory-based 

incremental probability field for the highest concentrations of Lye Brook PMF wood smoke 

source. Note that it includes a Canadian area in eastern Ontario and western Quebec which 

has been periodically associated with lightening-induced forest fires. 
77

Figure 8.13 Upwind Incremental Probability for LYBR PMF Wood Smoke Source 

Figure 8.14 shows a similar incremental probability field for a wood smoke source identified 

by Unmix receptor modeling of 1989-1995 IMPROVE-like data from Underhill, VT reported 

by Poirot et al., (2001), along with the location of satellite-detected Canadian fires between 

1994 and 1997, and the locations of the massive July, 2002 Quebec fires. 

Figure 8.14 Incremental probability for 1989-1995 Underhill VT wood smoke compared with Canadian 

forest fire locations 
78

While there are occasionally large Canadian wild fire impacts at Lye Brook, these infrequent 

natural sources are not subject to regulatory controls. There are also relatively minor impacts 

from prescribed burning on visibility in MANE-VU class I areas. MANE-VU’s “Technical 

Support Document on Agricultural and Forestry Smoke Management in the MANE-VU 

Region,” September 1, 2006 (Attachment S), concluded that fire from land management 

activities was not a major contributor to regional haze in MANE-VU Class I Areas, and that 

the majority of emissions from fires were from residential wood combustion. As the costs of 

home heating fuels continue to rise, residential wood burning is likely to become a more 

important source of PM2.5 concentrations and visibility impairment in the future. 

Figures 8.15 and 8.16 show that area sources dominate primary 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 PM2.5

inventory than in the primary PM10 inventory because the crustal component of particulate 

emissions (consisting mainly of larger, or coarse, particles) contributes more to overall PM10

levels than to PM2.5 levels. At the same time, pollution control equipment commonly installed 

at large point sources is usually more efficient at capturing coarse particle emissions, than it is 

at capturing fine particles and their gaseous precursors. 

Figure 8.15 2002 Primary Coarse Particle (PM10) Emissions, by State Bar Graph = Percentage Fractions 

of Four Source Categories Line Graph = Total Annual Emissions (106 tpy) 
79

Figure 8.16 2002 Primary Fine Particle (PM2.5) Emissions, by State Bar Graph = Percentage Fractions of 

Four Source Categories Line Graph = Total Annual Emissions (106 tpy) 

8.3.5 Ammonia Emissions (NH3) 

Because ammonium sulfate ((NH4)2SO4) and ammonium nitrate (NH4NO3) 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 US ammonia emissions to the atmosphere (EPA, 2000b). 

However, improved ammonia inventory data are needed as inputs to the photochemical 

models used to simulate fine particle formation and transport in the eastern United States. 

States were not required to include ammonia in their emissions data collection efforts until 

fairly recently (see the Consolidated Emissions Reporting Rule, 67 CFR 39602, June 10, 

2002). Therefore, emissions data for ammonia do not exist at the same level of detail or 

reliability as exists for other pollutants. 

 

Ammonium ion (formed from ammonia emissions to the atmosphere) is an important 

constituent of airborne particulate matter, typically accounting for 10–20 percent of total fine 

particle mass. Reductions in ammonium ion concentrations can be instrumental to controlling 

regional haze because such reductions can yield proportionately greater reductions in fine 

particle mass. Ansari and Pandis (1998) showed that a one μg/m3 reduction in ammonium ion 

could result in up to a four μg/m3

 reduction in fine particulate matter. Decision makers, 
80

however, must weigh the benefits of ammonia reduction against the significant role it plays in 

neutralizing acidic aerosol.* 

To address the need for improved ammonia inventories, MARAMA, NESCAUM, and EPA 

funded researchers at Carnegie Mellon University (CMU) in Pittsburgh to develop a regional 

ammonia inventory (Davidson et al., 1999). This study focused on three issues with respect to 

current emission estimates: 1) a wide range of ammonia emission factors, 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, emission 

factors, and activity data that are readily accessible to the user. With this framework, users 

can obtain data in a variety of formats† and can make updates easily, allowing additional 

ammonia sources to be added or emission factors to be replaced as better information 

becomes available (Strader et al., 2000; NESCAUM, 2001b). 

Figures 8.17 and 8.18 show that estimated ammonia emissions held fairly stable across the 

1996, 1999, and 2002 inventories for MANE-VU states, with some increases observed for 

Massachusetts, New Jersey, and New York. 

Figure 8.17 Trends in Ammonia (NH3) Emissions, by State 

 

* SO2 reacts in the atmosphere to form sulfuric acid (H2SO4). 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 SO2 reductions, fine particles formed in the atmosphere will be 

substantially more acidic than those presently observed. 

† For example, the user will have the flexibility to choose the temporal resolution of the output emissions data or 

to spatially attribute emissions based on land-use data. 
81

Figure 8.18 2002 Ammonia (NH3) Emissions, by State Bar Graph = Percentage Fractions of Four Source 

Categories Line Graph = Total Annual Emissions (106 tpy) 

Area and on-road mobile sources dominate the ammonia inventory data. Specifically, 

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 other sources contributing significant emissions are wastewater treatment systems 

and gasoline exhaust from highway vehicles. 

8.4 References for Section 8 

Ansari, A. S., and Pandis, S.N., “Response of inorganic PM to precursor concentrations,” 

Environ. Sci. Technol., 32, 2706-2714, 1998. 

Davidson, C., Strader, 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. 7-Jan. 1999. 

Coutant, B., Kelly, T., Ma, J., Scott, B., Wood, B., and Main, H. 2002. Source 

apportionment analysis of air quality monitoring data: Phase I final report. Prepared for the 

Mid-Atlantic/Northeast Visibility Union and Midwest Regional Planning Organization by 

Battelle Memorial Institute and Sonoma Technology, Inc. 
82

Duyzer, J., “Dry Deposition of Ammonia and Ammonium Aerosols over Heathland,” J. 

Geophys. Res., 99(D9):18,757 – 18,763, 1994. 

NESCAUM, “Regional Haze and Visibility in the Northeast and Mid-Atlantic States,” 

January 2001a. 

 

NESCAUM, “Development of an Improved Ammonia Emissions Inventory for the United 

States,” December 2001b. 

Odum, J.R., Jungkamp, T.P.W., Griffin, R.J., Flagan, R.C., and Seinfeld, J.H., “The 

Atmospheric Aerosol-forming Potential of Whole Gasoline Vapor,” Science, 276, 96-99, 

1997. 

Poirot, R.L., P.R. Wishinski, P.K. Hopke and A.V. Polissar, Comparative application of 

multiple receptor methods to identify aerosol sources in northern Vermont, Environ. Sci. 

Technol. 35: 4622-4636 (2001). 

Strader, R., Anderson, N., and Davidson, C., Development of an Ammonia Inventory for the 

Mid-Atlantic States and New England, Progress Report, October 18, 2000, available online: 

http://marama.org/rt_center/MARAMAprogress10-18-00.pdf, 2000. 

US EPA, National Air Quality and Emission Trends Report, 1998, EPA 454/R-00-003, 

available online: http://www.epa.gov/oar/aqtrnd98/, 2000a. 

US EPA, National Air Pollutant Trends, 1900 – 1998, EPA 454/R-00-002, available online: 

http://www.epa.gov/ttn/chief/trends/trends98/trends98.pdf, 2000b. 

EPA 2005, http://www.epa.gov/ttn/chief/eiinformation.html 
83

9. Best Available Retrofit Technology (BART) 

In the Regional Haze Rule, EPA included provisions designed specifically to reduce 

emissions of visibility-impairing pollutants 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). 

The BART requirements pertain to large facilities in each of 26 source categories that meet 

certain criteria, including industrial boilers, pulp and paper mills, cement kilns, and other large 

stationary sources. The BART program applies to units installed and operated between 1962 

and 1977 with the potential to emit more than 250 tons per year of a visibility-impairing 

pollutant. Each BART-eligible unit must undergo a case-by-case analysis to determine whether 

new emission restrictions are appropriate to limit the unit’s impact on visibility at Class I areas. 

Under this part of the Regional Haze rule, Vermont is required to submit an implementation 

plan containing emission limitations representing Best Available Retrofit Technology and 

schedules for compliance with BART for each BART-eligible source that may reasonably be 

anticipated to cause or contribute to any impairment of visibility in any mandatory Class I 

area. The BART provisions of the Regional Haze Rule require states to develop an inventory 

of sources within each state that would be eligible for BART controls. The rule also: 

• Outlines methods to determine whether a source is “reasonably anticipated to cause or 

contribute to haze,” 

• Defines the methodology for conducting BART control analysis, 

• Provides presumptive limits for electricity generating units (EGUs) larger than 750 

Megawatts, and 

• Provides a justification for the use of the Clean Air Interstate Rule (CAIR) as meeting 

BART requirements for CAIR-affected electrical generating units (EGUs). (Note: 

Vermont (along with many other states) has always held that CAIR requirements are 

not source-specific and therefore should not, in the general case, be considered 

equivalent to BART requirements, which are source-specific.) 

Beyond the specific elements listed above, EPA has allowed the states a great deal of 

flexibility in implementing the BART program. Because of the collective importance of 

BART sources to the management of regional haze, the MANE-VU Board decided, in June 

2004, that a BART determination would be made by the member states for each BARTeligible source, without exception. However, as indicated in the MANE-VU Reports 

“Assessment of Control Technology Options for BART-Eligible Sources” (Attachment V), 

and “Five-Factor Analysis on BART-Eligible Sources” (Attachment T), there are no BARTeligible sources in Vermont. 

Many facilities in the MANE-VU region are relatively small emission sources with potential 

emissions exceeding the BART applicability threshold of 250 tons per year of haze-causing 

pollutants but whose actual emissions are well below 250 tons in any year. Some of these 
84

facilities may have accepted an enforceable permit limitation restricting their emissions to less 

than 250 tons per year. Any otherwise BART-eligible facility may be allowed to “cap-out” of 

BART by accepting enforceable permit limits. In addition, some BART-eligible facilities 

may have permanently shut down. Because there are no BART-eligible sources in Vermont, no

BART-eligible facilities capped out or permanently shut down to avoid BART in Vermont.

As provided in 40 CFR 51.308(e)(1)(ii)(C) of the Regional Haze Rule, a state is not required 

to make a BART determination for either SO2 or NOX if a BART-eligible source has the 

potential to emit less than 40 tons per year of these pollutants, or for PM10 if a BART-eligible 

source emits less than 15 tons per year of this pollutant. In Vermont no BART-eligible 

sources have been exempted from the BART determination process. 

9.1 Bart-Eligible EGUs and the Role of CAIR 

The BART-eligible EGUs in MANE-VU (and in the Midwest RPO and VISTAS regions) 

represent the largest potential for emission reductions among the various BART-eligible 

source categories. The population of BART-eligible EGUs within the MANE-VU domain 

was geographically divided into three groups. 

• CAIR states (year-round): EGUs in states eligible to participate in the (CAIR) 

program on a year-round basis (Delaware, District of Columbia, Maryland, New 

Jersey, New York, and Pennsylvania, for SO2 and NOX); 

• CAIR states (seasonal): EGUs in states eligible to participate in the seasonal CAIR 

program only (Connecticut and Massachusetts, for summertime NOX); and 

• Non-CAIR states: EGUs in states not eligible to participate in the CAIR annual or 

seasonal programs (Maine, New Hampshire, Rhode Island, and Vermont). 

Under 40 CFR 51.308(e)(4), EPA established that a state’s participation in the CAIR program 

will satisfy BART requirements for BART-eligible EGUs that are also subject to CAIR. This 

provision could affect all BART-eligible EGUs in Pennsylvania, Delaware, Maryland, New 

Jersey, New York, the District of Columbia, and those EGUs located in Connecticut and 

Massachusetts that are also included in the CAIR program, but only with respect to their 

emissions of ozone-season NOX. 

The original purpose of BART was to require source-specific controls on BART-eligible units. 

Vermont has always maintained that the location of BART-eligible EGUs and their impacts 

on visibility in Class I areas should be addressed as the BART rule intended. MANE-VU 

assessments have determined that allowing EGUs with the largest impacts on Class I areas to 

purchase allowances under the CAIR emissions trading program will produce less visibility 

benefit than intended by the BART rule. Accordingly, MANE-VU developed a targeted EGU 

strategy in order to recapture some of the lost benefit. (The targeted EGU strategy is discussed 

at length in Sections 10 and 11). 
85

10. Reasonable Progress Goals 

40 CFR 51.308(d)(1) of the Regional Haze Rule requires that Vermont establish reasonable 

progress goals (RPGs) toward achieving natural visibility conditions for the Lye Brook 

Wilderness Area. On June 1, 2007, the U.S. Environmental Protection Agency (EPA) 

released final guidance to be used by states in setting reasonable progress goals. The goals 

must provide for visibility improvement on the days of greatest visibility impairment and 

ensure no visibility degradation on the days of least visibility impairment for the duration of 

the State Implementation Plan (SIP) period. 

As provided in 40 CFR 51.308 (d)(1)(iv), the state must consult with other states in the setting 

of reasonable progress goals. The rule states: 

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

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

Federal area. In any situation in which the State cannot agree with another such State or group of 

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

actions taken to resolve the disagreement. In reviewing the State’s implementation plan submittal, 

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

visibility improvement provides for reasonable progress towards natural visibility condition.” 

Vermont consulted with states found to contribute to visibility impairment at Lye Brook. In 

addition, Vermont worked closely with the other MANE-VU states to ensure consistency of 

approach in setting reasonable progress goals. Accordingly, Vermont agrees with the 

reasonable progress goals established by Maine, New Hampshire, and New Jersey. A 

description of the consultation process is found in Section 3.0, Regional Planning and 

Consultation. 

The Regional Haze Rule also requires each Class I state to consider four factors in setting 

reasonable progress goals: cost, time needed for compliance, energy and non-air quality 

environmental impacts, and remaining useful life. In addition, the state must show that it 

considered the uniform rate of improvement and the emission reduction measures needed to 

achieve it for the period covered by the implementation plan. If the state proposes a rate of 

progress slower than the uniform rate of progress, the state must assess the number of years it 

would take to attain natural conditions if visibility improvement continues at the rate 

proposed. 

10.1 Calculation of Uniform Rate of Progress 

As a benchmark to aid in developing reasonable progress goals, MANE-VU compared 

baseline visibility conditions to natural visibility conditions at each MANE-VU Class I area. 

The difference between baseline and natural visibility conditions for the 20 percent worst days 

was used to determine the uniform rate of progress that would be needed during each 

implementation period in order to attain natural visibility conditions by 2064. Table 10.1 

presents baseline visibility, natural visibility, and required uniform rate of progress for each 
86

MANE-VU Class I area. Visibility values are expressed in deciviews (dv), where each 

single-unit deciview decrease would represent a barely perceptible improvement in visibility. 

Table 10.1 Uniform Rate of Progress Calculation (all values in deciviews) 

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 

Moosehorn 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 

Brigantine Wilderness 29.0 12.2 3.9 16.8 0.280 

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.* 

The reasonable progress goals established for MANE-VU’s Class I Areas, described later in 

Subsection 10.3, are expected to provide visibility improvements in excess of the uniform 

rates of progress shown above. 

10.2 Identification of (Additional) Reasonable Control Measures 

Vermont and the other MANE-VU states have identified specific emission control measures – 

beyond those which individual states or RPOs had already made commitments to implement – 

that would be reasonable to undertake as part of a concerted strategy to mitigate regional 

haze. The proposed additional control measures were incorporated into the regional strategy 

adopted by MANE-VU on June 20, 2007, to meet the reasonable progress goals established in 

this SIP. The basic elements of this strategy are described in the Vermont/MANE-VU “Ask” 

(see Part 3.2.2 in Section 3.0, Regional Planning and Consultation). 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, West Virginia and Wisconsin.† 

In addition to including proposed emission controls in the eastern United States, MANE-VU 

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 

 

* “Baseline and Natural Visibility Conditions, Considerations and Proposed Approach to the Calculation of Baseline and 

Natural Visibility Conditions at MANE-VU Class I Areas,” NESCAUM, December 2006. 

†

 Independently from other MANE-VU modeling and assessments, Vermont CALPUFF modeling identified Wisconsin as a 

significant contributor to visibility impairment at the Lye Brook Wilderness Class I Area (See Section 3.2.1).
87

conducted before and during the consultation process (see description of relevant consultations 

in Part 3.2.1). Specifically, the modeling accounts for six coal-burning electric generating 

units (EGUs) in Canada having a combined output of 6,500 MW that are scheduled to be shut 

down and replaced by nine natural gas turbine units equipped with selective catalytic 

reduction (SCR) by 2018. 

The process of identifying reasonable measures and setting reasonable progress goals is 

described in the subsections which follow. Further elaboration on the reasonable measures 

which make up the Vermont/MANE-VU long-term strategy is provided in Section 11.0 of this 

SIP. Under this plan, the affected states will have a maximum of 10 years to implement 

reasonable and cost-effective control measures to reduce primarily SO2 and NOX emissions. 

For a description of how proposed emission control measures were modeled to estimate 

resulting visibility improvements, see Subsection 10.4, Visibility Effects of (Additional) 

Reasonable Control Measures. 

10.2.1 Rationale for Determining Reasonable Controls 

40 CFR 51.308(d)(1)(i)(A) of EPA’s Regional Haze Rule requires that, in establishing 

reasonable progress goals for each Class I area, the state must consider the costs of 

compliance, the time necessary for compliance, the energy and non-air quality environmental 

impacts of compliance, and the remaining useful life of any potentially affected sources. The 

SIP must include a demonstration showing how these factors were taken into consideration in 

setting the RPGs. These factors are sometimes termed the “four statutory factors,” since their 

consideration is required by the Clean Air Act. 

Focus on SO2: MANE-VU conducted a Contribution Assessment (Attachment B) and 

developed a conceptual model that showed the dominant contributor to visibility impairment 

at all MANE-VU Class I areas during all seasons in the base year was particulate sulfate 

formed from emissions of SO2. While other pollutants, including organic carbon, will need to 

be addressed in order to achieve the national visibility goals, MANE-VU’s contribution 

assessment suggested that an early emphasis on SO2 would yield the greatest near-term 

benefit. Therefore, it is reasonable to conclude that the additional measures considered in 

setting reasonable progress goals require reductions in SO2 emissions. 

Contributing Sources: The MANE-VU Contribution Assessment indicates that emissions 

from within MANE-VU in 2002 were responsible for approximately 25 percent of the sulfate 

at MANE-VU Class I Areas. Sources in the Midwest and Southeast regions were responsible 

for about 15 to 25 percent each. Point sources dominated the inventory of SO2 emissions. 

Therefore, MANE-VU’s long-term strategy includes additional measures to control sources of 

SO2 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 responsible for 

visibility degradation at MANE-VU Class I Areas. As described in Section 11, Long-Term 

Strategy, 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 SO2 emissions were identified for further study. 
88

These efforts led to production of the MANE-VU report by MACTEC Federal Programs, 

Inc., “Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas,” 

Final, July 9, 2007, otherwise known as the Reasonable Progress Report (Attachment U). 

This report provides an analysis of the four statutory factors for five major source categories: 

electrical generating units (EGUs); industrial, commercial, and institutional (ICI) boilers; 

cement and lime kilns; heating oil combustion; and residential wood combustion. Table 10.2 

summarizes the results of MANE-VU’s four-factor analysis for the source categories 

considered. 

Table 10.2 Summary of Results from Four-Factor Analysis of Different Source Categories 

Source 

Category 

Primary 

Regional 

Haze 

Pollutant 

Control Measure(s) 

Average Cost in 

2006 dollars 

(per ton of 

pollutant 

reduction) 

Compliance 

Timeframe 

Energy and NonAir Quality 

Environmental 

Impacts 

Remaining 

Useful Life

Electric 

Generating 

Units 

SO2 Switch to a low-sulfur coal 

(generally <1% sulfur); switch to 

natural gas (virtually 0% sulfur); 

coal cleaning; flue gas 

desulfurization (FGD), including 

wet, spray-dry, or dry. 

$775-$1,690 

based on IPM® 

v.2.1.9 * 

$170-$5,700 based 

on available 

literature 

2-3 years 

following SIP 

submittal 

Fuel supply issues, 

possible permitting 

issues, reduced 

electricity 

production 

capacity, 

wastewater issues 

50 years or 

more 

Industrial, 

Commercial, 

Institutional 

Boilers 

SO2 Switch to a low-sulfur coal 

(generally <1% sulfur); switch to 

natural gas (virtually 0% sulfur); 

switch to a lower-sulfur oil; coal 

cleaning; combustion controls; 

flue gas desulfurization (FGD), 

including wet, spray-dry, or dry. 

$130-$11,000 

based on available 

literature; 

dependent on size. 

2-3 years 

following SIP 

submittal 

Fuel supply issues, 

potential 

permitting issues, 

control device 

energy 

requirements, 

wastewater issues 

10-30 years

Cement and 

Lime Kilns 

SO2 Fuel switching; flue gas 

desulfurization (FGD), including 

wet, spray-dry, or dry; advanced 

flue gas desulfurization (FGD). 

$1,900-$73,000 

based on available 

literature; 

dependent on size. 

2-3 years 

following SIP 

submittal 

Control device 

energy 

requirements, 

wastewater issues 

10-30 years

Heating Oil SO2 Switch to lower-sulfur fuel 

(varies by state) 

$550-$750 based 

on available 

literature; high 

degree of 

uncertainty with 

this cost estimate 

Currently feasible; 

capacity issues 

may influence 

timeframe for 

implementation of 

new fuel standards 

Increased 

furnace/boiler 

efficiency, reduced 

furnace/boiler 

maintenance 

requirements 

18-25 years

Residential 

Wood 

Combustion 

PM State implementation of NSPS, 

ban on resale of uncertified 

devices, installer training 

certification or inspection 

program, pellet stoves, EPA 

Phase II certified RWC devices, 

retrofit requirement, accelerated 

changeover requirement or 

inducement 

$0-$10,000 based 

on available 

literature 

Several years, 

depending on 

mechanism for 

emission 

reductions 

Increased 

efficiency of 

combustion 

device, reduced 

greenhouse gas 

emissions 

10-15 years

* Integrated Planning Model® CAIR versus CAIR plus analysis conducted for MARAMA/MANE-VU by ICF Consulting, L.L.C.
89

The MANE-VU states reviewed the four-factor analyses presented in the Reasonable Progress 

Report, consulted with one another about possible control measures, and concluded by 

adopting the statements known as the MANE-VU Ask. These statements identify the control 

measures that would be pursued toward improving visibility in the region. The following 

discussions focus on the four basic control strategies chosen by MANE-VU and included in 

the modeling to establish the reasonable progress goals: 

1. Best Available Retrofit Technology (BART), 

2. Low-sulfur fuel oil requirements, 

3. Emission reductions from specific EGUs, and 

4. Additional measures determined to be reasonable. 

10.2.2 Best Available Retrofit Technology Controls 

The MANE-VU states have identified approximately 100 BART-eligible sources in the 

region. Most of these facilities are already controlling emissions in response to other federal 

or state air programs or are likely to install emission controls under new programs. 

(Previously, EPA had determined that CAIR fulfilled the BART requirement for all EGUs in 

participating CAIR states.) A complete compilation of BART-eligible sources in the MANEVU region is available in Appendix A of MANE-VU’s “Assessment of Control Technology 

Options for BART-Eligible Sources,” March 2005, also known as the BART Report 

(Attachment V). 

To assess the benefits of implementing BART in the MANE-VU region, NESCAUM 

estimated emission reductions for twelve BART-eligible sources in MANE-VU states that 

would probably be controlled as a result of BART requirements alone. These sources include 

one EGU and eleven non-EGUs. The affected sources were identified by a survey of states’ 

staff members, who furnished data on the potential control technologies and expected control 

levels for these sources under BART implementation. The twelve sources are listed in Table 

10.3 along with their 2002 baseline and 2018 estimated emissions. Information on these 

sources was incorporated into the 2018 emissions inventory projections that were used in the 

modeling to set reasonable progress goals. 

Best Available Retrofit Technology is Reasonable: BART controls are part of the strategy 

for improving visibility at MANE-VU Class I Areas. MANE-VU prepared reports to provide 

states with information about available control technologies (e.g., MANE-VU’s BART Report 

referenced above), estimated cost ranges, and other factors associated with those controls. 

The reasonable progress goals established in this regional haze SIP assume that states whose 

emissions affect Class I areas in Vermont and elsewhere in MANE-VU will make 

determinations demonstrating the reasonableness of BART controls for sources in their states. 
90

Table 10.3 Estimated Emissions from BART-Eligible Facilities in MANE-VU States (Facilities Likely to 

be Controlled as a Result of BART Alone) 

State Facility Name Unit 

Name SCC Code

Plant ID 

(MANE-VU 

Inventory)

Point ID 

(MANE-VU 

Inventory)

Facility Type 

2002 

SO2

Emissions 

(tons) 

2018 

SO2

Emissions 

(tons) 

MD EastAlco 

Aluminum 28 30300101 021-0005 28 Metal 

Production 1,506 1,356 

MD Eastalco Aluminum 29 30300101 021-0005 29 Metal 

Production 1,506 1,356 

MD Lehigh Portland 

Cement 39 30500606 013-0012 39 Portland 

Cement 9 8 

MD Lehigh Portland 

Cement 16 30500915 021-0003 16 Portland 

Cement 1,321 1,189 

MD Lehigh Portland 

Cement 17 30500915 021-0003 17 Portland 

Cement 9,76 8,78 

MD Westvaco Fine 

Papers 2 10200212 001-0011 2 Paper and 

Pulp 8,923 1,338 

ME Wyman Station Boiler 3 10100401 2300500135 004 EGU 616 308 

ME SAPPI Somerset Power 

Boiler 1 10200799 2302500027 001 Paper and 

Pulp 2,884 1,442 

ME Verso 

Androscoggin LLC 

Power 

Boiler 1 10200401 2300700021 001 Paper and 

Pulp 2,964* 1,482 

ME Verso 

Androscoggin LLC 

Power 

Boiler 2 10200401 2300700021 002 Paper and 

Pulp 3,086* 1,543 

NY Kodak Park 

Division U00015 10200203 8261400205 U00015 Chemical 

Manufacturer 23,798 14,216 

NY Lafarge Building 

Materials, Inc 41000 30500706 4012400001 041000 Portland 

Cement 14,800 4,440 

Note: Many additional sources in MANE-VU are BART-eligible but are expected to be controlled as a result of other 

emission reduction programs (e.g., state-specific multi-pollutant programs, CAIR-successor legislation, etc.). 

*Data for 1999 baseline year. 

10.2.3 Low-Sulfur Fuel Strategy 

The MANE-VU region, especially the Northeast, is heavily reliant on distillate oil for home 

space heating, with more than 4 million gallons used, according to 2006 estimates from the 

Energy Information Administration*. Likewise, the heavier residual oils are widely used by 

non-EGU sources and, to a lesser extent, the EGU sector. The sulfur content of distillate fuels 

currently averages above 2,000 ppm (0.2 percent). Although the sulfur content of residual 

oils varies by source and region, it can exceed 2.0 percent. Combustion of distillate and 

residual fuel in the MANE-VU states resulted in SO2 emissions totaling approximately 

380,000 tons in 2002.

As the second component of MANE-VU’s long-term strategy, the member states agreed to 

pursue measures that would require the sale and use of fuel oils having reduced sulfur content. 

This strategy would be implemented in two phases: 

 

* U.S. Department of Energy, EIA, Table F3a, at http://www.eia.doe.gov/emeu/states/sep_fuel/html/fuel_use_df.html 
91

• Phase 1 would require reducing the sulfur content in distillate (#1 and # 2) fuel oils 

from current levels of 2,000 to 2,300 ppm (0.20 to 0.23 percent) to a maximum of 500 

ppm (0.05 percent) by weight. It would also restrict the sale of heavier blends of 

residual (# 4, #5, and # 6) fuel oils that have sulfur content greater than 2,500 ppm 

(0.25 percent) and 5,000 ppm (0.5 percent) by weight, respectively. 

• Phase 2 would require further reducing the sulfur content of the distillate fraction from 

500 ppm (0.05 percent) to 15 ppm (0.015 percent) while keeping the sulfur limits on 

residual oils at first-phase levels. 

The two phases are to be introduced in sequence with slightly different timing for an inner zone 

of MANE-VU states* and the remainder of MANE-VU states. While all MANE-VU states 

have agreed to pursue implementation of both phases to full effect by the end of 2018, it is 

possible that not every state can make a firm commitment to these measures today. States are 

expected to review the situation by the time of the first regional haze SIP progress report in 

2012 and to seek alternate, equivalent reductions if necessary. 

Reductions in sulfur dioxide emissions will occur as a direct consequence of the low-sulfur 

fuel strategy. For both phases combined, it is estimated that SO2 emissions in the MANE-VU 

region will decline from 2002 levels by 168,222 tons per year for combustion of light 

distillates and by 42,875 tons per year for combustion of the heavier fuels. Together, these 

reductions represent a 35 percent decrease in the projected 2018 SO2 emissions inventory for 

non-EGU sources in the region. 

NESCAUM analyzed the two program phases separately for MANE-VU, but it is the 

combined benefit of implementing both phases that is relevant to the question of visibility 

improvement by 2018. To estimate the effects of the low-sulfur fuel strategy, MANE-VU 

applied the expected sulfur dioxide emission reductions to all non-EGU sources burning #1, 

#2, #4, #5, or #6 fuel oil. These emission reductions would result directly from the lowering 

of fuel sulfur content from original levels to 0.015 percent for #1 and #2 oil, to 0.25 percent 

for #4 oil, and to 0.5 percent for #5 and #6 oil. 

The reduction in SO2 emissions by 2018 will yield corresponding reductions in sulfate 

aerosol, the main culprit in fine-particle pollution and regional haze. The full benefit of 

MANE-VU-s low-sulfur fuel strategy is represented in Figure 10.1, which displays the 

estimated average reductions in 24-hr PM2.5 concentration as calculated by the CMAQ model 

for the combined first and second phases of the program. 

Low-Sulfur Fuel Oil Requirements are Reasonable: The MANE-VU Contribution Assessment 

documented source apportionment analyses that linked visibility impairment in MANE-VU 

Class I Areas with SO2 emissions from sources burning fuel oil. The reasonable assumption 

underlying the low-sulfur fuel oil strategy is that refiners can, by 2018, produce home heating 

and fuel oils that contain 50 percent less sulfur for the heavier grades (#4 and #6 residual oil), 

and 75 to 99.25 percent less sulfur in #2 fuel oil (also known as home heating oil, distillate, or 

diesel fuel) at an acceptably small increase in price to the consumer. 

 

* The inner zone includes New Jersey, Delaware, New York City, and possibly portions of eastern Pennsylvania.
92

Figure 10.1 Average Change in 24-hr PM2.5 Due to Low-Sulfur Fuel Strategy (Phases I and 2 Combined) 

Relative to OTB/OTW (values in μg/m3

) 

Four-Factor Analysis – Low-Sulfur Fuel Oil Strategy: The MANE-VU Reasonable 

Progress Report discussed the four factors as they apply to low-sulfur fuel use for ICI boilers 

and residential heating systems. MANE-VU’s Reasonable Progress Report identified 

switching to a lower-sulfur fuel oil as an available SO2 control option that would achieve 50 

to 90 percent reductions in SO2 emissions from ICI Boilers. The report also noted that home 

heating oil use generates an estimated 100,000 tons of SO2 emissions in the Northeast each 

year and that SO2 emissions would decline in proportion to reductions in fuel sulfur content. 

The following discussion summarizes information concerning the four factors for the lowsulfur fuel strategy. 

1) Low-Sulfur Fuel Oil Strategy – Costs of Compliance: The MANE-VU Reasonable 

Progress report noted that because of requirements for motor vehicle fuels, refineries have 

already performed the capital investments required for the production of low-sulfur diesel 

(LSD) and ultra-low sulfur diesel (ULSD). The report estimated a cost per ton of SO2

removed by switching to lower-sulfur fuel would range from $554 to $734 per ton (converted 

from 2001 to 2006 dollars using a conversion factor of 1.1383). In some seasons and some 

locations, low-sulfur diesel is actually cheaper than regular diesel fuel. (See Chapter 8 of the 

MANE-VU Reasonable Progress Report.) 
93

The sulfur content of #4 and #6 fuels can also be cost-effectively reduced. Residual oil is 

essentially a byproduct of the refining process and is produced in several grades that can be 

blended to meet a specified fuel sulfur content limit. New York Harbor residual fuel prices 

for the week ending March 21, 2008, ranged from a low of $71.38 a barrel for 2.0 and 2.2 

percent sulfur fuel to a high of $91.38 per barrel for 0.3 percent sulfur fuel*. 

While the costs of achieving the projected emissions reductions with the low-sulfur fuel 

strategy are somewhat uncertain, they are believed to be reasonable in comparison with the 

costs of controlling other sectors. Some MANE-VU states are proceeding with low-sulfur oil 

requirements much sooner than 2018; however, all of the MANE-VU states concur that a lowsulfur oil strategy is both reasonable and achievable within the MANE-VU region by no later 

than 2018. MANE-VU has concluded that the cost of requiring the use of lower-sulfur fuels 

is reasonable. 

2) Low-Sulfur Fuel Oil Strategy – Time Necessary for Compliance: MANE-VU’s Reasonable 

Progress Report indicated that furnaces and boilers would not have to be retrofit and would 

not require expensive control technologies to burn ULSD distillate fuel oil. Therefore, the 

time necessary for compliance would be determined by the availability of the fuel. 

The MANE-VU Reasonable Progress Report notes that, on a national scale, more ULSD is 

produced than both LSD and high-sulfur fuel, and concludes that the United States has the 

infrastructure to produce adequate stocks of these fuels. NESCAUM’s report, “Low Sulfur 

Heating Oil in the Northeast States: An Overview of Benefits, Costs, and Implementation 

Issues,” December 2005 (Attachment W) observes that the federal rules for heavy duty 

highway diesel fuel are flexible, so that if there is a shortage of 15 ppm fuel, the 15 to 500 

ppm fuel could be used to relieve the shortage. With this flexibility, the report concludes that 

the likelihood of a fuel shortage in the short term due to use of ULSD for heating oil is 

diminished. The volatile nature of heating supply and demand presents unique challenges to 

the fuel oil industry. The success of a low-sulfur fuel oil program is predicated on meeting 

these challenges. The Northeast states are assessing a variety of business strategies and 

regulatory approaches that could be used to minimize any potential adverse supply and price 

impacts that could result from a regional 500 ppm sulfur standard for heating oil. Suppliers 

can increase pre-season reserves of low-sulfur product. Blending domestically produced 

biodiesel into heating oil offers opportunity to reduce imports, stabilize supplies and minimize 

supply-related price spikes. 

Potential supply disruptions and price spikes for residual fuels are a particular concern for 

several northern MANE-VU states. Maine, New Hampshire, and Massachusetts receive a 

significant percentage of their residual fuel supplies from offshore sources during the winter 

months, when barge traffic from New York Harbor is interrupted because of severe weather. 

At these times, residual oil is often imported directly from foreign sources (e.g., Venezuela 

and Russia), and stakeholders have expressed concerns that the supply of low-sulfur residual 

fuels may be insufficient to satisfy demand during these periods. While the potential for 

 

*

 During this same period, low-pour (low-temperature, reduced viscosity) residual fuel oil with a 0.5 percent sulfur content 

sold for $80.83 per barrel. Residual oil with a fuel sulfur content limit of 0.7 percent and 1.0 percent traded at $75.13 and 

$72.63, respectively. 
94

disruptions in the supply of residual fuels is greater than that for distillate oil, these 

disruptions would affect only a limited number of states during extreme weather events. 

MANE-VU has identified several mechanisms that could be implemented to address 

disruptions, including seasonal averaging and emergency waivers. A seasonal averaging 

approach would reduce potential supply constraints by allowing the use of higher-sulfur fuel 

during periods of peak demand (and limited supply), and then requiring the increased sulfur 

content of these fuels to be offset through the use of a lower-sulfur fuel at other times. This 

approach would provide regulatory certainty and greater flexibility during the winter months 

when fuel supplies may be subject to weather-related disruptions, but at a cost of increased 

recordkeeping and compliance monitoring. Since many states already have statutory 

authority to waive fuel sulfur limits in an emergency, states could also utilize their 

discretionary powers to address short-term supply disruptions. 

The strategy adopted by Vermont and the other MANE-VU states proposes to phase in the 

required use of lower-sulfur fuels over the next 10 years, providing adequate time for full 

implementation. 

3) Low-Sulfur Fuel Oil Strategy – Energy and Non-Air Quality Environmental Impacts of 

Compliance: According to MANE-VU’s Reasonable Progress Report, reducing the sulfur 

content of fuel oil would have a variety of beneficial consequences for boilers and furnaces 

using this fuel. Low-sulfur distillate fuel is cleaner burning and emits less particulate matter, 

thereby reducing the rate of fouling of heating units and allowing longer time intervals 

between cleanings. The MANE-VU report cites a study by the New York State Energy 

Research and Development Authority (NYSERDA) that showed that boiler deposits are 

reduced by a factor of two by lowering the fuel sulfur content from 1,400 ppm to 500 ppm. 

The use of low-sulfur oil could extend the useful life of a source by reducing the maintenance 

required because low-sulfur oil is less damaging to the combustion equipment. The report 

also notes that decreasing sulfur levels in fuel would enable manufacturers to develop more 

efficient furnaces and boilers by using more advanced condensing equipment that recovers 

energy normally lost to the heating of water vapor in the exhaust gases. 

Furthermore, SO2 controls would have beneficial environmental impacts by reducing acid 

deposition and helping to decrease ambient concentrations of PM2.5. Reductions in PM2.5

resulting from use of low-sulfur fuels could help nonattainment areas meet health-based 

National Ambient Air Quality Standards. 

4) Low-Sulfur Fuel Oil Strategy – Remaining Useful Life of Any Potentially Affected 

Sources: Residential furnaces and boilers have finite life spans, but they do not need to be 

replaced to burn low- or ultra-low-sulfur fuel oil. The Energy Research Center estimates that 

the average life expectancy of a residential heating oil boiler is 20-25 years. As noted above, 

use of low-sulfur fuel is less damaging to equipment and could therefore extend the useful life 

of an oil-fired residential furnace or boiler. 

Available information on the remaining useful life of ICI boilers indicates a wide range of life 

expectancies, depending on unit size, capacity factor, and level of maintenance performed. 
95

(Capacity factor is defined as the actual amount of energy a boiler generates in one year 

divided by the total amount it could generate if it ran full time at full capacity.) The typical 

life expectancy of an ICI boiler ranges from 10 years to more than 30 years. As in the case of 

residential units, use of lower-sulfur fuels could extend the life span of an ICI boiler. 

10.2.4 Targeted EGU Strategy for SO2 Reduction 

Electrical generating units (EGUs) are the single largest sector contributing to visibility 

impairment at MANE-VU’s Class I Areas. SO2 emissions from power plants continue to 

dominate the emissions inventory. Sulfate formed through atmospheric processes from SO2

emissions are responsible for over half the mass and approximately 70-80 percent of visibility 

extinction on the days of worst visibility (see NESCAUM’s Contribution Assessment, 

Attachment B). 

To ensure that EGU control measures are targeted at those units having the greatest impact on 

visibility at MANE-VU Class I Areas, a modeling analysis was conducted to identify the 

individual sources responsible for the highest contributions to visibility degradation. 

Accordingly, MANE-VU developed lists of the 100 EGU emission points (stacks) having the 

largest impacts at each MANE-VU Class I Area during 2002. The combined list for all seven 

MANE-VU Class I Areas identified a total of 167 distinct emission points. These 167 stacks 

are spread across the Northeast, Southeast, and Midwest (Figure 10.2). 

After consultations with its member states and with other RPOs, MANE-VU requested a 90-

percent reduction in SO2 emissions from the top 167 stacks by no later than 2018 (see the 

MANE-VU “Ask”). NESCAUM’s preliminary modeling for MANE-VU showed that SO2

emission reductions of this magnitude from the targeted facilities would produce substantial 

improvements in ambient 24-hour PM2.5 concentrations. Assuming a control level equal to 10 

percent of the 2002 baseline emissions (i.e., 90-percent emission reduction), NESCAUM used 

CMAQ to model sulfate concentrations in 2018 after implementation of controls. The modeled 

sulfate values were then converted to estimates of PM2.5 concentration. Figure 10.3 displays the 

predicted average change in 24-hr PM2.5. 

The map illustrates the reductions in fine-particle pollution in the Eastern U.S. that would result 

from implementation of the targeted EGU strategy for SO2. Improvements in PM2.5 levels 

would occur throughout the MANE-VU region and portions of the VISTAS and MRPO 

regions, especially along the Ohio River Valley. 
96

Figure 10.2 Location of 167 EGU Stacks Contributing the Most to Visibility Impairment at MANE-VU 

Class I Areas 

Note: Some facilities have more than one stack. 

Although the reductions would be both advantageous and potentially large, MANE-VU 

determined, after further consultation with affected states, that it was unreasonable to expect 

that the full 90-percent reduction in SO2 emissions would be achieved by 2018. Therefore, 

additional modeling was conducted to assess the more realistic scenario in which emissions 

would be controlled by the individual facilities and/or states to levels already projected to take 

place by that date. At some facilities, the actual emission reductions are anticipated to be 

greater or less than the 90 percent benchmark. For details, see Alpine Geophysics’ report for 

MARAMA entitled, “Documentation of 2018 Emissions from Electric Generating Units in 

the Eastern United States for MANE-VU’s Regional Haze Modeling, Revised Final Draft,” 

April 28, 2008 (Attachment G).
97

Figure 10.3 Preliminary Estimate of Average Change in 24-hr PM2.5 Resulting from a 90-Percent 

Reduction in SO2 Emissions from the Top 167 EGU Stacks Affecting MANE-VU Class I Areas 

Targeted EGU SO2 Reduction Strategy Controls are Reasonable: MANE-VU identified 

specific EGU stacks that were significant contributors to visibility degradation at MANE-VU 

Class I Areas in 2002 based on CALPUFF modeling analyses documented in the Contribution 

Assessment. MANE-VU obtained information about existing and planned controls on 

emissions from those stacks. These analyses and information on proposed EGU controls are 

presented in MANE-VU’s Reasonable Progress Report and the Contribution Assessment as 

well as in Section 6.0, Emissions Inventory, and Section 11.0, Long-Term Strategy section of 

this SIP. 

 

Based on information gathered from the states and regional planning organizations, MANEVU anticipated that emissions from many of the targeted EGU stacks will be subject to EPA’s 

Clean Air Interstate Rule (CAIR). However, because CAIR is a cap-and-trade program that has 

been remanded to EPA, it is not possible to predict with certainty which of the 167 stacks will 

be controlled under CAIR (or its replacement) in 2018. 

Four-Factor Analysis – Targeted EGU SO2 Reduction Strategy: The following discussion 

addresses each of the four factors with respect to the strategy of controlling specific EGUs. 

Information is taken primarily from the MANE-VU Reasonable Progress Report (Attachment 

U) and MANE-VU BART Report (Attachment V). 
98

1) Targeted EGU SO2 Reduction Strategy – Costs of Compliance: Technologies to control 

the precursors of regional haze are commercially available today. Because EGUs are the most 

significant stationary source of SO2, NOX, and PM, they have been subject to extensive 

federal and state regulations to control all three pollutants. The technical feasibility of control 

technologies has been successfully proven for a substantial number of small (e.g., 100 MW) 

to very large (over 1,000 MW) boilers burning different types of coal. Over the last few 

years, the cost data clearly indicate that many technologies provide substantial and costeffective emission reductions.

Both wet and dry scrubbers are in wide commercial use in the U.S. for controlling SO2

emissions from coal-fired power plants. The capital costs for new or retrofit wet or dry 

scrubbers are higher than the capital costs for NOX and PM controls. Capital costs for 

scrubbers ranged from $180/kW for large units (greater than 600 MW) to as high as $350/kW 

for small units (200 to 300 MW). (See pages 2-22 through 2-25 of the BART Report, 

Attachment V). However, the last few years have seen a general trend of declining capital 

costs attributable to vendor competition and technology maturation. Also, the costeffectiveness (in dollars per ton of emissions removed) is very attractive because the high 

sulfur content of the coal burned results in very large amounts of SO2 removed by the control 

devices. The typical cost is in the range of 200 to 500 dollars per ton of SO2 removed, 

although the cost rises steeply for small units burning lower-sulfur coal and operating at low 

capacity factors. For any plant, overall cost-effectiveness depends mainly on the baseline precontrolled SO2 emission rate (or fuel sulfur content), size and capacity factor of the unit, and 

capital costs of flue gas desulfurization (generally ranging from $150 to $200/kW). 

The MANE-VU Reasonable Progress Report reviewed options for controlling coal-fired EGU 

boilers, including switching to lower-sulfur coal, switching to natural gas, coal cleaning, and 

flue gas desulfurization (FGD). The most effective control option (but not necessarily 

appropriate for all installations) is FGD, which can achieve up to 95 percent reduction in SO2

emissions. The costs of different technologies vary considerably among units and were 

estimated to range from as low as $170/ton to as high as $5,700/ton. Table 10.4 summarizes 

the estimated costs of controlling SO2 emissions, expressed in dollars per ton of SO2 removed. 

To predict future emissions and further evaluate the costs of emission controls for electric 

generating units, MANE-VU and other RPOs have followed the example of the US 

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

integrated economic and emissions model for EGUs. This model projects electricity supplies 

based on various assumptions while at the same time developing least-cost solutions to 

electrical generating needs within specified emissions targets. IPM also provides estimates of 

the costs of complying with various policy requirements. 
99

Table 10.4 Estimated Cost Ranges for SO2 Control Options for Coal-Fired EGU Boilers (2006 dollars per 

ton of SO2 removed)

EPA developed IPM version 2.1.9 and used this model to evaluate the impacts of CAIR and 

the Clean Air Mercury Rule (CAMR). (Note that CAMR was vacated by the federal courts 

and is no longer in effect.) Recently, EPA updated their input data and developed IPM v.3.0. 

However, because of time constraints, all MANE-VU runs were based on EPA IPM v.2.1.9 

with changes made to the input assumptions. 

The RPOs collaborated with one another to update the inputs to IPM v.2.1.9 using more 

current data on the EGUs and more realistic fuel prices. The resulting IPM run is called 

VISTAS PC_1f. This IPM run serves as the basis for regional air quality modeling for ozone 

and haze SIPs in MANE-VU and the OTC. 

MANE-VU, through MARAMA, contracted with the consulting firm ICF Resources, L.L.C. 

to prepare two new IPM runs, as documented in “Comparison of CAIR and CAIR Plus 

Proposal using the Integrated Planning Model (IPM®),” Final Draft Report, May 30, 2007 

(Attachment X). The first run, known as the MARAMA CAIR Base Case run (also known as 

MARAMA_5c), was based on the VISTAS PC_1f run and underlying EPA IPM v.2.1.9 with 

some updated information on fuel prices, control constraints, etc. The second run, called the 

MARAMA CAIR Plus run (also known as MARAMA_4c), was similarly based on VISTAS 
100

PC_1f run and the underlying EPA IPM v.2.1.9. The MARAMA CAIR Plus run included 

updated information used in the VISTAS run but assumed lower NOX emission caps and 

higher SO2 retirement ratios. 

Based on the modeling results, MANE-VU estimates that the marginal cost of SO2 emission 

reductions (the cost of reducing one additional ton of emissions) ranges from $640/ton in 

2008 to $1,392/ton in 2018 (see Table 6, “Allowance Prices (Marginal Costs) of Emissions 

Reductions...,” in Attachment X). 

Costs will vary for individual plants to reduce emissions by 90 percent, as recommended in 

the Vermont/MANE-VU Ask. However, this strategy provides states with flexibility to 

pursue controls on specific sources as appropriate and to control emissions from alternative 

sources, if necessary, to meet the 90 percent target established in the Ask. 

Given the importance of SO2 emissions from specific EGUs to visibility impairment in 

MANE-VU Class I Areas, the MANE-VU Commissioners, after weighing all factors – the 

availability of technology to reduce emissions, the estimated costs of controls, the costs of 

alternative measures, the flexibility to achieve alternative reductions if necessary, etc. – 

concluded that the costs of the targeted EGU strategy are reasonable. Vermont agrees with 

this conclusion. 

2) Targeted EGU SO2 Reduction Strategy – Time Necessary for Compliance: MANE-VU’s 

Reasonable Progress Report indicates that, generally, sources are given a 2- to 4-year phase-in 

period to comply with new rules. Under Phase I of the NOX SIP call, EPA provided a 

compliance date of about 31⁄2 years from the SIP submittal date. Most MACT standards allow 

a 3-year compliance period. Under Phase II of the NOX SIP Call, EPA provided for 2-year 

compliance period from the SIP submittal date. Vermont concludes that there is more than 

sufficient time between 2008 and 2018 for affected states to adopt requirements and for 

affected sources to install necessary controls.

3) Targeted EGU SO2 Reduction Strategy – Energy and Non-Air Quality Environmental 

Impacts of Compliance: The MANE-VU Reasonable Progress Report identified several 

energy and non-air quality impacts from additional EGU controls. Large-scale fuel switching 

could potentially impact fuel supplies. Flue gas desulfurization systems may generate 

wastewater and sludge (which is sometimes recycled as a useful byproduct). On the other 

hand, SO2, NOX, and ammonia controls would have beneficial environmental impacts by 

reducing acid deposition and nitrogen deposition to water bodies and natural land areas. 

Emission reductions for these pollutants would also produce decreases in ambient levels of 

PM2.5 and result in corresponding health benefits. Similarly, mercury emissions may be 

reduced by the addition of controls for other pollutants. Vermont concludes that the energy 

and non-air quality impacts of additional EGU controls are reasonable. 

4) Targeted EGU SO2 Reduction Strategy – Remaining Useful Life of Any Potentially 

Affected Sources: As noted in the MANE-VU Reasonable Progress Report, remaining useful 

life estimates of EGU boilers indicate a wide range of operating lifetimes, depending on unit 

size, capacity factor, and level of maintenance performed. Typical life expectancies range to 

50 years or more. Additionally, implementation of air pollution regulations over the years has 
101

necessitated emission control retrofits that have increased the expected life spans of many 

EGUs. The lifetime of an EGU may be extended through repair, re-powering, or other 

strategies if the unit is more economical to run than to replace with power from other sources. 

Extending facility lifetime may be particularly likely for a unit serving an area with limited 

transmission capacity to bring in other power. 

10.2.5 Non-EGU SO2 Emissions Reduction Strategy for Non-MANE-VU 

States 

In addition to the measures described above (i.e., BART, low-sulfur fuel, and targeted EGU 

controls), Vermont asked states in neighboring regional planning organizations to consider 

further non-EGU emission reductions comparable to those achieved by MANE-VU states 

through application of MANE-VU’s low-sulfur fuel strategy. Previous modeling indicated 

that the MANE-VU low-sulfur fuel strategy would achieve a greater than 28- percent 

reduction in non-EGU SO2 emissions by 2018. After consultation with other states and 

consideration of comments received, MANE-VU decided to include, in the latest modeling 

for the VISTAS and MRPO regions, implementation of control measures capable of achieving 

SO2 emission reductions equivalent to MANE-VU’s 28-percent reduction in non-EGU SO2

emissions in 2018. 

To model the effects of this strategy on visibility at MANE-VU Class I Areas, MANE-VU 

had to make reasonable assumptions about where the requested emission reductions would 

occur in the VISTAS and MRPO states without knowing precisely how those reductions 

would be realized. As a way to represent approximately a 28-percent reduction in non-EGU 

SO2 emissions, the following reductions were modeled: 

• For control measures in VISTAS and MRPO states: 

− Coal-fired ICI boilers: SO2 emissions were reduced by 60 percent. 

− Oil-fired ICI boilers: SO2 emissions were reduced by 75 percent. 

− ICI boilers lacking fuel specification: SO2 emissions were reduced by 50 percent. 

• For additional controls only in the VISTAS states: SO2 emissions from other oil-fired 

area sources were reduced by 75 percent (based on the same SCCs identified in 

MANE-VU’s oil strategies list). 

This modeling scenario represents just one example of realistic strategies that states outside of 

MANE-VU could employ to meet the non-EGU SO2 emissions reductions requested by 

MANE-VU. 

Vermont acknowledges that a number of non-MANE-VU states have not included, or may not 

include, the requested 28-percent reduction in non-EGU SO2 emissions in their State 

Implementation Plans at the present time. Vermont expects these states to revisit the MANEVU Ask in the course of future regional haze SIP revisions and to make commitments to this 

request where feasible. Vermont will continue to monitor other states’ actions with respect to 

regional haze planning. In time, actual reductions could turn out to be greater or less than the 

MANE-VU Ask. If necessary, Vermont will adjust its reasonable progress goals and long-
102

term strategy at a later date to be consistent with programs implemented by the non-MANEVU states. Any such adjustments would be incorporated into Vermont’s first regional haze 

SIP revision in 2012. 

Non-EGU SO2 Emission Reduction Measures Outside MANE-VU are Reasonable: After 

EGUs, ICI boilers are the next largest class of SO2 emitters. ICI boilers are thus a logical 

choice among non-EGU sources for consideration of additional SO2 control measures. 

ICI Boiler Control Options: Air pollution reduction and control technologies for ICI boilers 

have advanced substantially over the past 25 years. However, according to a 1998 survey of 

industrial boilers by EPA (2004), only 2 percent of gas-fired boilers and 3 percent of oil-fired 

boilers had installed any kind of air pollution control device. A larger percentage of coalfired boilers had installed air pollution controls: specifically, 47 percent had installed some 

type of control device, mainly to control particulate matter (PM). Post-combustion SO2

controls were used by less than one percent of industrial boilers in 1998, with the exception of 

boilers firing petroleum coke (2 percent of boilers using this fuel had acid scrubbers). A small 

percentage of industrial boilers had combustion controls in place in 1998, although additional 

low-NOX firing systems may have been installed since that date. 

Almost all SO2 emission control technologies fall into the category of reducing SO2 after its 

formation as opposed to minimizing its formation during combustion. The method of SO2

control appropriate for any individual ICI boiler is dependent upon the type of boiler, type of 

fuel, capacity utilization, and the types and staging of other air pollution control devices. 

However, cost-effective emission reduction technologies for SO2 are available and are 

effective in reducing emissions from the exhaust gas stream of ICI boilers. Post-combustion 

SO2 control is accomplished by reacting the SO2 in the gas with a reagent (usually calcium- or 

sodium-based) and removing the resulting product (a sulfate/sulfite) for disposal or 

commercial use, depending on the particular technology. SO2 reduction technologies are 

commonly referred to as flue gas desulfurization (FGD) and are usually described in terms of 

the process conditions (wet versus dry), byproduct utilization (throwaway versus saleable) 

and reagent utilization (once-through versus regenerable). 

The exceptions to the nearly universal use of post-combustion controls are found in fuel 

switching, coal cleaning, and fluidized bed boilers, in which limestone is added to the fuel in 

the combustion chamber. Both pre- and post-combustion SO2 emission control alternatives 

for ICI boilers are outlined in Table 10.5. Further description of these technology options is 

available in Chapter 4 of the MANE-VU Reasonable Progress Report (Attachment U). 

The SO2 removal efficiency of these controls varies from 20 to 99+ percent depending on the 

fuel type and control technology. For coal-fired boilers, options include switching to lowsulfur coal, coal cleaning, wet FGD, dry FGD, and spray dryers. The overall SO2 reductions 

vary from a low of 20 to 25 percent for fuel switching to a high of 60 to 95 percent for wet 

FGD and spray dry FGD. The majority of control strategies, however, are capable of 

achieving a 60 percent or greater reduction. Thus, assuming that coal-fired ICI boilers adopt 

varying levels of controls, with most choosing a 50- to 70- percent reduction strategy and 

fewer choosing either the 20-percent or the 90-percent reduction strategy, the region-wide 

average would be likely to fall in the vicinity of a 60- percent reduction in SO2 emissions. 

This assumption is validated by data showing that wet FGD systems represent 85 percent of 
103

the FGD systems in use in the United States and that these systems have an average SO2

removal efficiency of 78 percent. MANE-VU’s modeling of a 60-percent reduction in SO2

emission from coal-fired ICI boilers is therefore reasonable. 

Table 10.5 Available SO2 Control Options for ICI Boilers 

For oil-fired boilers, options include switching to a lower-sulfur fuel (e.g., oil or natural gas), 

dry FGD, and spray dryers. The overall SO2 reductions vary from a low of 40 to 60 percent 

for dry FGD to a high of 60 to 95 percent for spray dry FGD. For comparison, the MANEVU low-sulfur fuel strategy assumes a 50- to 90- percent reduction in SO2 emissions from oilfired ICI boilers. Assuming a normal distribution of control strategies chosen by the sources, 

MANE-VU’s modeling of an average 75-percent reduction in SO2 emission from oil-fired ICI 

boilers is reasonable. 

 

For ICI boilers in which a fuel was not specified, a 50-percent reduction in SO2 emissions was 

assumed. ICI boilers in this category include those outside the MANE-VU region for which 

the current inventory did not specify the type of fuel burned. Because a response from the 

MRPO was not received, this assumption also encompasses some of the uncertainty regarding 

Technology Description Applicability Performance 

Flue Gas Desulfurization 

(FGD) - Dry

Powdered lime or other 

suitable sorbent is injected 

directly into flue gas

Applicable primarily for 

boilers currently firing low 

to medium sulfur fuels

40-60% reduction in SO2 

emissions

Flue Gas Desulfurization 

(FGD) - Spray Dry

A fine mist containing lime or 

other suitable sorbent is 

injected directly into flue gas

Applicable primarily for 

boilers currently firing low 

to medium sulfur fuels

60-95%+ reduction in SO2 

emissions 

Flue Gas Desulfurization 

(FGD) - Wet

SO2 is removed from flue 

gas by dissolving it in a lime 

or limestone slurry. (Other 

alkaline chemical are 

sometimes used) 

Applicable to all coal-fired 

ICI boilers

30-95%+ reduction in SO2 

emissions 

Combustion Control A reactive material, such as 

limestone or bi-carbonate, is 

introduced into the 

combustion chamber along 

with the fuel

Applicable to pulverized 

coal-fired boilers and 

circulating fluidized bed 

boilers 

40%-85% reductions in SO2 

emissions

Coal Cleaning Coal is washed to remove 

some of the sulfur and ash 

prior to combustion 

Potential control measure 

for all coal-fired ICI boilers 

20-25% reduction in SO2 

emissions

Switch to a Lower Sulfur Oil Replace higher-sulfur 

residual oil with lower-sulfur 

distillate oil. Alternatively, 

replace medium sulfur 

distillate oil with ultra-low 

sulfur distillate oil

Potential control measure 

for all oil-fired ICIs 

currently using higher 

sulfur content residual or 

distillate oils 

50-80% reduction in SO2 

emissions by switching to a 

lower-sulfur oil 

Switch to Natural Gas 

(virtually 0% sulfur)

Replace coal combustion 

with natural gas

Potential control measure 

for all coal-fired ICIs 

Virtually eliminate SO2 

emissions by switching to 

natural gas 

Switch to a Low Sulfur Coal 

(generally <1% sulfur)

Replace high-sulfur 

bituminous coal combustion 

with lower-sulfur coal

Potential control measure 

for all coal-fired ICIs 

currently using coal with 

high sulfur content 

50-80% reduction in SO2 

emissions by switching to a 

lower-sulfur coal
104

the implementation of MANE-VU’s non-EGU Ask. Given the paucity of data, a lower 

reduction in SO2 emissions (50 percent) was assumed for this category than for coal- or oilfired ICI boilers. Implementation of one or more of the suggested SO2 control options to 

achieve, on average, a 50-percent reduction in SO2 emissions at these sources is a reasonable 

assumption. 

For emissions from other area oil-combustion sources in the VISTAS region, an SO2 

reduction of 75 percent was assumed. This reduction is equal to the reduction that would 

result from implementing the MANE-VU low-sulfur fuel strategy for this sector. The fourfactor analysis for the low-sulfur fuel strategy was described in Part 10.2.3 of this section. 

Four-Factor Analysis – Non-EGU SO2 Emission Reduction Measures Outside MANE-VU: 

Based on the survey of available technologies outlined above and the four-factor analyses 

summarized below, MANE-VU concludes that each of the strategies assumed for modeling 

purposes to meet the Vermont/MANE-VU Ask of a 28-percent reduction in non-EGU SO2

emissions is reasonable. States should have no difficulty in meeting this benchmark in light 

of the control efficiencies that are attainable at reasonable costs with retrofit technologies that 

are available for ICI boilers today. 

1) Non-EGU SO2 Emission Reduction Measures outside MANE-VU – Costs of 

Compliance: Industrial boilers have a wider range of sizes than EGUs and often operate over 

a wider range of capacities. Thus, cost estimates for the same technologies will generally 

span a relatively larger range, and costs for an individual boiler will depend on the capacity of 

the boiler and typical operating conditions. In general, cost-effectiveness increases as boiler 

size and capacity factor (a measure of boiler utilization) increases. 

MANE-VU’s Reasonable Progress Report (Attachment U) provides emission control cost 

estimates for ICI boilers in the range of $130 to $11,000 per ton of SO2 removed, a very wide 

spread due to the variability of sources and control options in this category. All costs 

presented below for emission controls on ICI boilers are borrowed from this report. Dollar 

amounts originated from EPA publications cited in the report and are restated in 2006 dollars 

using appropriate adjustment factors found at www.inflationdata.com. 

◊ Cost of Fuel Switching: Although fuel switching can be a very effective means of 

controlling SO2 emissions (reductions of 50 to 99.9 percent are possible), burning low-sulfur 

fuel may not be technically feasible or economically practical as an SO2 control option for 

every coal-fired boiler. Factors impacting applicability include the characteristics of the plant 

and the particular type of fuel change being considered. Additionally, switching to a lowersulfur coal can affect fuel handling systems, boiler performance, PM control effectiveness, 

and ash handling systems. Oil-fired boilers switching to a lower-sulfur fuel of the same grade 

(e.g., switching from #6 fuel oil at 2.0% S to #6 fuel oil at 0.5% S) do not typically encounter 

these issues. (See Part 10.2.3 for a discussion of the costs and issues associated with switching 

to low-sulfur fuel oil.) 

The costs of coal fuel switching, including substitution or blending with a low-sulfur coal, can 

be attributed to two main factors: the cost of low-sulfur coal compared to higher-sulfur coal 

(including consideration of the coal’s heating value), and the cost of necessary boiler or coal-
105

handling equipment modifications. Many plants will be able to switch from high-sulfur to 

low-sulfur bituminous coal without serious difficulty, but switching from bituminous to subbituminous coal may require potentially significant investments and modifications to an 

existing plant. Even if a lower-sulfur fuel is available, it may not be cost competitive if it 

must be supplied in small quantities or transported long distances from the supplier. It also 

may be more cost-effective to burn a higher-sulfur fuel supplied by nearby suppliers and to 

use a post-combustion control device. 

Switching from coal combustion to natural gas combustion virtually eliminates SO2

emissions. It is technically feasible to switch from coal to natural gas, but it is currently 

uneconomical to consider this option for large ICI boilers because of the fuel quantity 

necessary and the price of natural gas. Natural gas is roughly seven times the price of coal in 

terms of heating value (price per million Btus). 

◊ Cost of Coal Cleaning: The World Bank, an organization which assists with economic and 

technological needs in developing countries, reports that the cost of physically cleaning coal 

varies from $1 to $10 per ton of coal cleaned, depending on the coal quality, the cleaning 

process used, and the degree of cleaning desired. In most cases, the costs were found to be 

between $1 and $5 per ton of coal cleaned. Coal cleaning typically results in a 20- to 25-

percent reduction in SO2 emissions and increases the heating value of the fuel by a small 

amount. 

◊ Cost of Combustion Controls: Dry sorbent injection (DSI) systems have lower capital and 

operation costs than post-combustion FGD systems because of the simplicity of the DSI 

design, lower water use needs, and smaller land area requirements. Table 10.6 presents the 

estimated costs of adding DSI-based SO2 emission controls to ICI boilers for different boiler 

sizes, fuel types, and capacity factors. 

Table 10.6 Estimated Costs of Dry Sorbent Injection (DSI) for ICI Boilers (2006 dollars) 

Cost-Effectiveness ($/ton of SO2 removed) 

Fuel 

SO2

Reduction 

(%) 

Capacity 

Factor 

(%) 100 MMBtu/hr 250 

MMBTU/hr 

1,000 

MMBTU/hr 

14 4,686 3,793 2,979 

2%-Sulfur Coal 40 50 1,312 1,062 834 

83 772 624 490 

14 2,732 2,212 1,737 

3.43%-Sulfur Coal 40 50 765 619 486 

83 450 364 286 

14 2,205 1,786 1,402 

2%-Sulfur Coal 85 50 617 500 392 

83 363 294 231 

14 1,286 1,040 818 

3.43%-Sulfur Coal 40 50 360 291 229 

83 212 171 134 
106

Cost of FGD: Installation of post-combustion SO2 controls in the form of FGD has several 

impacts on facility operations, maintenance, and waste handling procedures. FGD systems 

generally require substantial land area for construction of the absorber towers, sorbent tanks, 

and waste handling equipment. Facility costs therefore depend on cost and availability of 

space for construction of the FGD system. In addition, significant quantities of waste material 

may be generated that require disposal. The costs may be mitigated, however, by utilization 

of a forced oxidation FGD process that produces commercial-grade gypsum, which may be 

sold as a raw material for other commercial processes. 

Table 10.7 presents the total estimated cost-per-ton of adding FGD-based SO2 emission 

controls to ICI boilers for different boiler sizes, fuel types, and capacity factors. There is no 

indication that these cost data include possible revenues from gypsum sales, which would 

partially offset the costs of FGD controls. Carbon dioxide is also emitted as a byproduct of 

FGD; therefore, the impacts of increased carbon emissions associated with this technology 

would need to be considered. CO2 emissions will become more of an issue in the future if they 

are limited under climate change mitigation strategies. Given the uncertainty of such future 

strategies, costs related to increased carbon emissions from FGD cannot yet be assessed. 

MANE-VU’s request for a 28-percent reduction in non-EGU SO2 emissions allows states 

flexibility in determining which sources to control, so that the most cost-effective control 

measures can be adopted and implemented over the next 10 years. Given the wide range of 

control options and costs available for this purpose, MANE-VU has concluded that the 

request for a 28-percent reduction in non-EGU SO2 emissions is reasonable. Vermont concurs 

with this conclusion. 

Table 10.7 Estimated Costs of Flue Gas Desulfurization for ICI Boilers (2006 dollars) 

Cost-Effectiveness ($/ton of SO2 removed) 

Fuel Technology 

SO2

Reduction 

(%) 

Capacity 

Factor 

(%) 100 MMBtu/hr 250 

MMBTU/hr 

1,000 

MMBTU/hr 

14 3,781 2,637 1,817 

50 1,379 1,059 828 High-Sulfur 

Coal FGD (dry) 40 

83 1,006 814 676 

14 4,571 3,150 2,119 

50 1,605 1,207 928 Lower-Sulfur 

Coal FGD (dry) 40 

83 1,147 906 744 

14 4,183 2,786 1,601 

Coal 50 1,290 899 567 FGD 

(spray dry) 85 

83 843 607 407 

14 3,642 2,890 1,909 

50 1,116 875 601 High-Sulfur 

Coal 

FGD 

(spray dry) 85 

83 709 563 398 

14 4,797 3,693 2,426 

50 1,415 1,106 751 Lower-Sulfur 

Coal FGD (wet) 40 

83 892 705 492 

14 10,843 8,325 5,424 

Oil FGD (wet) 40 50 2,269 1,765 1,184 

83 1,371 1,079 740 
107

2) Non-EGU SO2 Emission Reduction Measures outside MANE-VU – Time Necessary for 

Compliance: For pre- and post-combustion SO2 emission controls, engineering and 

construction lead times will vary between 2 and 5 years, depending on the size of the facility 

and specific control technology selected. Generally, sources are given a 2- to 4- year phase-in 

period to comply with new rules, as previously described, and states generally have a 2-year 

period for compliance with RACT rules. 

For the purposes of this review, it is assumed that a 2-year period after SIP submittal is 

adequate for pre-combustion controls (fuel switching or cleaning), and a 3-year period is 

adequate for the installation of post-combustion controls. MANE-VU has therefore 

concluded that there is sufficient time between 2008 and 2018 for affected states to adopt 

emission control requirements and for affected sources to install the necessary controls to 

meet MANE-VU’s requested SO2 emission reductions from non-EGU sources. Vermont 

concurs with this conclusion. 

3) Non-EGU SO2 Emission Reduction Measures Outside MANE-VU – Energy and NonAir Quality Environmental Impacts of Compliance: The primary energy impact of pre- or 

post-combustion control alternatives is a potential increase in electricity usage. Fuel 

switching and cleaning do not significantly affect the efficiency of the boiler itself, but require 

additional energy to clean or blend coal. FGD systems typically operate with high-pressure 

drops across the control equipment and therefore consume significant amounts of electricity 

to operate blowers and circulation pumps. In addition, some combinations of FGD 

technology and plant configuration may require flue gas reheating to prevent physical damage 

to equipment, resulting in higher fuel usage. 

The primary non-air environmental impacts of fuel switching derive from transportation of 

the fuel. Secondary environmental impacts derive from waste disposal and material handling 

operations (e.g. fugitive dust). For FGD systems, the generation of wastewater and sludge 

from the SO2 removal process is a consideration. Wastewater from the FGD systems will 

increase sulfate, metals, and solids loading at the receiving wastewater treatment facility, 

resulting in potential impacts to operating cost, energy requirements, and effluent water 

quality. Processing of the wastewater sludge can require energy for stabilization and/or 

dewatering, and transporting the dewatered sludge to a landfill has additional environmental 

implications. 

Fuel switching to a low-sulfur distillate fuel oil has a variety of beneficial consequences for 

ICI boilers. Low-sulfur distillate fuel is cleaner burning and emits less particulate matter, 

which reduces the rate of fouling of heating units substantially and permits longer time 

intervals between cleanings. According to a study conducted by NYSERDA (reference 10 in 

Attachment W), boiler deposits are reduced by a factor of two by lowering the fuel sulfur 

content from 1,400 ppm to 500 ppm. These reductions in buildup of deposits result in longer 

service intervals between cleanings. 

Reducing SO2 emissions from ICI boilers would have positive environmental and health 

impacts. SO2 controls would reduce acid deposition, helping to preserve aquatic life, forests, 

and crops as well as buildings and sculptures made of acid-sensitive materials. These 
108

emission reductions would also help to decrease ambient levels of PM2.5, a significant 

contributor to premature morbidity and illness in individuals with heart or lung conditions. 

MANE-VU has concluded that the energy and non-air environmental impacts of controlling 

SO2 emissions from ICI boilers are justified in light of the beneficial impacts on regional haze, 

fine particulate air pollution, acid rain, and equipment operation, as described above. 

Vermont concurs with this conclusion. 

4) Non-EGU SO2 Emission Reduction Measures Outside MANE-VU – Remaining Useful 

Life of Any Potentially Affected Sources: Available information for remaining useful life 

estimates of ICI boilers indicates a wide range of life expectancies, depending on unit size, 

capacity factor, and level of maintenance performed. Typical life spans range from about 10 

years to over 30 years. However, the remaining useful life of a specific source is highly 

variable; and older units are not likely to be retrofitted with expensive emission controls. 

Given the typical range of life expectancies of ICI boilers, the technical options available, and 

the flexibility that non-MANE-VU states would have to meet the Ask, MANE-VU has 

concluded that a 28-percent reduction in non-EGU SO2 emissions is reasonable. Vermont 

concurs with this conclusion. 

10.3 Reasonable Progress Goals for Class I Areas in the State 

As required under 40 CFR 51.308(d)(1), this regional haze SIP establishes reasonable 

progress goals (RPGs) for the Lye Brook Wilderness in Vermont for the 10-year period of the 

implementation plan ending in 2018. These RPGs are determined from modeling based on 

implementation of the proposed reasonable measures included in MANE-VU’s long-term 

strategy. Table 10.8 provides a summary of the reasonable progress goals, in deciviews, for 

the Lye Brook Wilderness. 

Table 10.8 Reasonable Progress Goals for Lye Brook Wilderness (in deciviews) 

Visibility Condition

Natural 

Visibility

2000-2004 

Baseline 

Visibility

RPG

(Visibility 

Expected by 

2018)

Visibility 

Improvement 

Expected by 

2018

20 Percent Worst Days 

(Average) 11.7 24.4 20.9 3.5

20 Percent Best Days 

(Average) 2.8 6.4 5.5 0.9

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. (See Attachment J, “Baseline and Natural Visibility Conditions: 

Considerations and Proposed Approach to the Calculation of Baseline and Natural Visibility 

Conditions at MANE-VU Class I Areas,” December 2006.) Future progress toward the 2018 

visibility target will be calculated in a nationally consistent manner based on 5-year averages 

in accordance with EPA’s “Guidance for Tracking Progress Under the Regional Haze Rule” 
109

(EPA-454/B-03-004, September 2003) with adjustments for the alternative method as 

recommended by the IMPROVE Steering Committee. 

40 CFR 51.308(d)(1)(vi) requires that reasonable progress goals represent at least the 

visibility improvement expected from implementation of other Clean Air Act programs during 

the applicable planning period. The modeling that formed the basis for reasonable progress 

goals for MANE-VU Class I Areas included estimation of the effects of all other programs 

required by the Clean Air Act. MANE-VU’s modeling also included the specific control 

measure assumptions described previously in Subsection 10.2. Additional information may 

be found in Section 6.0, Emissions Inventory, and Section 11.0, Long-Term Strategy, as well 

as in the documentation for the MANE-VU modeling. 

In setting the reasonable progress goals to improve visibility at MANE-VU Class I Areas, 

Vermont recognizes that contributing states will have flexibility to submit SIP revisions and 

implement various control measures to meet these goals between now and 2018. The overall 

approach to reducing and preventing emissions that contribute to regional haze allows each 

state up to 10 years to implement reasonable SO2 and NOX control measures as appropriate 

and necessary. 

10.4 Visibility Effects of (Additional) Reasonable Control Measures 

MANE-VU’s evaluations included modeling to estimate the effects on visibility of the 

Vermont/MANE-VU Ask. The results of this work are summarized below. 

NESCAUM performed preliminary modeling as described in the report entitled “MANE-VU 

Modeling for Reasonable Progress Goals, Model Performance Evaluation, Pollution 

Apportionment, and Control Measure Benefits,” February 7, 2008 (Attachment G). 

NESCAUM also conducted more recent, revised modeling to assess the effects of all haze 

reduction strategies combined. The latter modeling is described in NESCAUM’s “2018 

Visibility Projections,” May 13, 2008 (Attachment O). 

The NESCAUM modeling demonstrates that significant visibility benefits will accrue from 

implementation of the additional reasonable control measures described in Subsection 10.2, 

above. Figures 10.4 and 10.5 describe the results of this modeling. In the first of the two 

figures, the light yellow bars represent expected visibility at MANE-VU Class I Areas in 

2018. Comparison of these values with the 2018 “glide slope” values (the plum-colored bars) 

shows that all areas are expected to experience visibility improvements that meet or exceed 

the uniform rate of progress calculated for each area. The second figure shows that, for the 20 

percent of days having best visibility, expected visibility in 2018 will be better than it is today 

at all locations. 

While the MANE-VU states agree that these modeled 2018 visibility changes result from 

required and reasonable control measures, it should be noted that source-specific VISTAS and 

MRPO RPOs projected 2018 emissions are similar to but different from those requested in the 

MANE-VU Ask, and consequently the future impacts on Lye Brook visibility may be 

different from what has been projected here. See sections 3.2, and 10.2 for additional detail. 
110

In conclusion, the reasonable control measures proposed by Vermont and the other MANEVU states are found to be consistent with the stated national goals of preventing further 

visibility degradation while making measurable progress toward achieving natural visibility 

conditions in national parks and wilderness areas by 2064. 

Figure 10.4 Demonstration of Required and Reasonable Visibility Progress for 20 Percent Worst 

Visibility Days 

Visibility Progress for 20% Worst Days 

0

5

10

15

20

25

30

35

Acadia Brigantine Great Gulf Lye Brook Moosehorn

Visibility (deciviews)

2002 Baseline 2018 Glideslope 2018 Projected Progress Natural

(Visibility Improvements Must be Made at Reasonable Rate)

Figure 10.5 Demonstration of Required Maintenance or Improvement of Visibility for 20 Percent Best 

Visibility Days 

Visibility Progress For 20% Best Days

0

2

4

6

8

10

12

14

16

Acadia Brigantine Great Gulf Lye Brook Moosehorn

Visibility (deciviews)

2002 Baseline 2018 Projected Progress

(Baseline Visibility Must be Maintained or Improved)
111

10.5 References for Section 10 

U.S. Environmental Protection Agency, National Emission Standards for Hazardous Air 

Pollutants for Industrial/ Commercial/Institutional Boilers and Process Heaters, http://cascade.epa.gov/RightSite/dk_public_collection_detail.htm?ObjectType=dk_docket_collection&cid=OAR

-2002-0058&ShowList=items&Action=view (Accessed Feb. 25, 2004)
112

11. Long-Term Strategy 

40 CFR 51.308(d)(3) of the Regional Haze Rule requires each state listed in 40 CFR 

51.300(b)(3) to submit a long-term strategy that addresses regional haze visibility impairment 

for all mandatory Class I federal areas within and outside the state that may be affected by 

emissions from within the state. There are seven designated Class 1 areas within the MANEVU region: Lye Brook Wilderness, Great Gulf Wilderness, Presidential Range - Dry River 

Wilderness, Acadia National Park, Moosehorn Wilderness, Roosevelt Campobello 

International Park, and Brigantine Wilderness. As presented in Section 3.0, Regional 

Planning and Consultation, Vermont consulted with other states to develop the coordinated 

emission management strategies contained in this SIP. The following describes how Vermont 

meets the long-term strategy requirements of the Regional Haze Rule. 

Vermont’s long-term strategy includes enforceable emission limitations, compliance 

schedules, and other measures necessary to achieve the reasonable progress goals described in 

Section 10.0. Additional measures may be reasonable to adopt at a later date after further 

consideration and review. In developing this long-term strategy, Vermont also considered the 

requirements of the Clean Air Act, Section 110 (a)(2)(D)(i)(II), pertaining to interstate and 

international transport of pollutants. More specifically, Section 110 (a)(2)(D)(i)(II) requires 

states to include provisions in their implementation plans to prohibit any source or activity 

from emitting air pollutants in amounts that would interfere with another state’s ability to 

prevent significant deterioration of air quality and visibility. The long-term strategy presented 

herein is designed to protect visibility in Vermont as well as areas downwind from Vermont. 

As noted in Chapter 2 of this SIP, Vermont emissions contributed less than half of 1 percent 

of annual average sulfate in any class I area outside of VT. 

11.1 Overview of Strategy Development Process 

The regional strategy development process identified reasonable measures that would reduce 

emissions contributing to visibility impairment at Class I areas by 2018 or earlier. The 

process of identifying potential emission reduction measures and the technical basis for the 

long-term strategy are discussed in this section. As a MANE-VU member and participant, 

Vermont supported several technical analyses undertaken to assist the MANE-VU states in 

deciding which regional haze control measures to pursue. These analyses are documented in 

the following reports: 

• NESCAUM, “Contributions to Regional Haze in the Northeast and Mid-Atlantic 

United States,” August 2006, otherwise known as the Contribution Assessment 

(Attachment B). 

• ICF Resources, L.L.C., “Comparison of CAIR and CAIR Plus Proposal Using the 

Integrated Planning Model®,” Final Draft Report, May 30, 2007, otherwise known as 

the CAIR Plus Report (Attachment X); 

• MACTEC Federal Programs, Inc., “Assessment of Reasonable Progress for Regional 

Haze in MANE-VU Class I Areas,” Final, July 9, 2007, otherwise known as the 

Reasonable Progress Report (Attachment U); 
113

• NESCAUM, “Five-Factor Analysis of BART-Eligible Sources: Survey of Options for 

Conducting BART Determinations,” June 1, 2007 (Attachment T); and 

• NESCAUM, “Assessment of Control Technology Options for BART-Eligible 

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

Facilities,” March 2005, otherwise known as the BART Report (Attachment V). 

MANE-VU reviewed a wide range of potential control measures aimed at reducing regional 

haze by the 2018 milestone. The process of choosing a set of control measures started in late 

2005. OTC selected a contracting firm to assist with the analysis of ozone and regional haze 

control measure options and 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 Measures Workgroup, the contractor narrowed the list of 

regional haze control measures for further consideration by MANE-VU. 

MANE-VU then developed an interim short list of possible control measures for regional 

haze. The identified control measures can be divided into three general categories: 

• Beyond- CAIR sulfate reductions and related control measures targeted at specific 

electrical generating units (EGUs) in the eastern United States, 

• Low-sulfur heating oil for industrial, commercial, institutional (ICI) boilers and 

residential sources (i.e., boilers and furnaces), and 

• Emission controls on ICI boilers (both coal- and oil-fired); lime and cement kilns; 

residential wood stoves; and outdoor burning (including outdoor wood boilers). 

The next step was to further refine this list, with the aid of several of the reports named above. 

The CAIR Plus Report documents MANE-VU’s assessment of the costs of CAIR and 

provides a cost analysis for additional SO2 and NOX controls at power plants in the eastern 

United States. The Reasonable Progress Report documents the assessment of control 

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

provided in the second of the two NESCAUM documents referenced above pertaining to Best 

Available Retrofit Technology (BART) controls.

The beyond-CAIR strategy for EGUs rose to the top of the list because the Contribution 

Assessment showed that EGU sulfur emissions have, by far, the largest impact on visibility in 

the MANE-VU Class I Areas. Similarly, a low-sulfur oil strategy gained traction after a 

NESCAUM-initiated conference with refiners and fuel-oil suppliers concluded that such a 

strategy could realistically be implemented within the next 10 years. Thus, the low-sulfur 

heating oil option for the residential and commercial sectors and the control measures option 

for the oil-fired ICI boiler sector merged into an overall strategy requiring the use of lowsulfur oil. Under this strategy, low-sulfur oil would be required for all residential and 

commercial heating units and all ICI boilers burning #2, #4, or #6 fuel oils. 

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

the interim list of control measures to make additional refinements. States determined, for 

example, that there may be too few coal-fired ICI boilers in MANE-VU for these sources to 

be included in a regional strategy, but that they could be covered in programs adopted by 
114

individual states. The member states also decided that lime and cement kilns, of which there 

are few in the MANE-VU region, are most likely to be handled via the BART determination 

process. Residential wood burning and outdoor wood-fired boilers remained on the list for 

those states where localized visibility impacts are a consideration even though emissions from 

these sources are primarily organic carbon and direct particulate matter. Finally, it was 

decided that the issue of outdoor wood-fired boilers should be examined further on a state-bystate basis because of concerns related to enforcement and penetration of existing state 

regulations. 

11.2 Technical Basis for Strategy Development 

40 CFR 51.308(d)(3)(iii) requires Vermont to document the technical basis for the state’s 

apportionment of emission reductions necessary to meet reasonable progress goals in each 

Class I area affected by Vermont’s emissions. Vermont relied on technical analyses 

developed by MANE-VU to demonstrate that Vermont’s emission reductions, when 

coordinated with those of other states and tribes, are sufficient to achieve reasonable progress 

goals in Class I areas located in Vermont and in other Class I areas affected by emissions 

originating in Vermont. 

The emission reductions necessary to meet reasonable progress goals in Class I areas affected 

by Vermont and other MANE-VU states are described in the following documents: 

• NESCAUM, “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,” December 2006 (Attachment J); 

• NESCAUM, “The Nature of the Fine Particle and Regional Haze Air Quality 

Problems in the MANE-VU Region: A Conceptual Description,” Final, November 2, 

2006 (Attachment Y); 

• NESCAUM, “Contributions to Regional Haze in the Northeast and Mid-Atlantic 

United States,” August 2006, otherwise known as the Contribution Assessment 

(Attachment B). 

• ICF Resources, L.L.C., “Comparison of CAIR and CAIR Plus Proposal Using the 

Integrated Planning Model®,” Final Draft Report, May 30, 2007, otherwise known as 

the CAIR Plus Report (Attachment X); 

• MACTEC Federal Programs, Inc., “Assessment of Reasonable Progress for Regional 

Haze in MANE-VU Class I Areas,” Final, July 9, 2007, otherwise known as the 

Reasonable Progress Report (Attachment U); 

• NESCAUM, “Five-Factor Analysis of BART-Eligible Sources: Survey of Options for 

Conducting BART Determinations,” June 1, 2007 (Attachment T); 

• NESCAUM, “Assessment of Control Technology Options for BART-Eligible 

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

Facilities,” March 2005, otherwise known as the BART Report (Attachment V); 
115

• NESCAUM, “MANE-VU Modeling for Reasonable Progress Goals: Model Performance 

Evaluation, Pollution Apportionment, and Control Measure Benefits,” February 7, 2008 

(Attachment G); and 

• NESCAUM, “2018 Visibility Projections,” May 13, 2008 (Attachment O). 

As described in Subsection 11.1, above, Vermont worked with other members of the Ozone 

Transport Commission and MANE-VU to evaluate a large number of potential emission 

reduction strategies covering a wide range of sources of SO2 and other pollutants contributing 

to regional haze. 40 CFR 51.308(d)(3)(v) requires states to consider several factors in 

developing their long-term strategies. Operating within this framework and using available 

information about emissions and potential impacts, the MANE-VU Reasonable Progress 

Workgroup selected the following source categories for detailed analysis: 

• Coal and oil-fired electric generating units (EGUs); 

• Point and area source ICI boilers; 

• Cement kilns and lime kilns; 

• Sources capable of using low-sulfur heating oil; and 

• Residential wood combustion and open burning. 

These efforts led to the selection of the emission reduction strategies presented in this SIP. 

11.3 Existing Commitments to Reduce Emissions 

40 CFR Section 51.308(d)(3)(v)(A) requires Vermont to consider emission reductions from 

ongoing pollution control programs. In developing its long-term strategy, Vermont 

considered air pollution programs being implemented between the 2002 baseline year and 

2018. The emission reduction programs described in Parts 11.3.1, 11.3.2, and 11.3.3, below, 

represent commitments already made by Vermont 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 very same measures that were included in the 

2018 emissions inventory and used in the modeling. While these control measures were not 

designed 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 already in place as well as emission controls that are not yet finalized but are likely to 

achieve additional emission reductions by 2018. The BOTW inventory was developed based 

on the MANE-VU 2002 Version 3.0 inventory and the MANE-VU 2018 on-the-books/on-theway (OTB/OTW) inventory. Inventories used for other RPOs reflect anticipated emissions 

controls that will be in place by 2018. The inventory is termed BOTW because it includes 

control measures that were developed for ozone SIPs that were not yet on the books in some 

states. For some states, BOTW also included controls that were under consideration for 

regional haze SIPs that have not yet been adopted. More information may be found in the 

following documents: 
116

• MACTEC Federal Programs, Inc., “Development of Emissions Projections for 2009, 

2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU 

Region,” Final Report, February 28, 2007, otherwise known as the Emission 

Projections Report (Attachment L); 

• Alpine Geophysics, LLC, “Documentation of 2018 Emissions from Electric 

Generating Units in the Eastern United States for MANE-VU’s Regional Haze 

Modeling, Revised Final Draft, April 28, 2008 (Attachment G); 

• NESCAUM, “MANE-VU Modeling for Reasonable Progress Goals: Model 

Performance Evaluation, Pollution Apportionment, and Control Measure Benefits,” 

February 7, 2008 (Attachment G); and 

• NESCAUM, “2018 Visibility Projections,” May 13, 2008 (Attachment O). 

11.3.1 Controls on EGUs Expected by 2018 

The following EGU emission reduction programs were included in the modeling used to 

develop the reasonable progress goals. These programs represent the greatest opportunities 

for reducing SO2 emissions and their resulting particulate matter sulfate impacts at Class I 

areas in the MANE-VU region and serve as the starting point for MANE-VU’s long-term 

strategy to mitigate regional haze. For Vermont’s Class I area in particular, because of the 

very large percentage of visibility impairing sulfate impacts at that area caused by sulfur 

oxide emissions originating outside Vermont, it is important that EGU SO2 emission 

reduction programs of at least the scope identified here be implemented during this first 10-

year planning period. Vermont does not have sulfur oxide emitting EGUs in-state and 

therefore has no regulatory authority of its own to require control of individual EGU SO2

emissions that contribute to haze impacts in Vermont. 

Clean Air Interstate Rule (CAIR): As promulgated, this major federal rule would have 

imposed permanent emissions caps on sulfur dioxide (SO2) and nitrogen oxides (NOX) in the 

eastern United States by 2015. When fully effective, CAIR would have reduced SO2

emissions in the CAIR region by up to 70 percent. To predict future emissions from EGUs 

after implementation of CAIR, MANE-VU used the Integrated Planning Model (IPM)*. 

Adjustments to the IPM output were made to provide a more accurate representation of 

anticipated controls at specific EGU sources as documented in the Alpine Geophysics report 

listed above. In making these adjustments, emission controls originating from the following 

state and regional programs were considered: 

Connecticut EGU Regulations: Connecticut adopted the following regulations governing 

EGU emissions: 

 

* The IPM model runs also anticipated the implementation of EPA’s Clean Air Mercury Rule (CAMR), which was recently 

vacated by the courts. However, MANE-VU believes that the adjustments made to the predicted SO2 emissions from 

electric generating units (EGUs) will have a larger effect on the air quality modeling analysis conducted for this SIP than 

will the vacatur of the CAMR rule. The emission adjustments were based on states’ comments on the actual levels of SO2 

controls expected to be installed in response to state-specific regulations and EPA’s CAIR rule. MANE-VU believes these 

adjustments improve the reliability of both the emissions inventory and modeling results.
117

• Regulations of Connecticut State Agencies (RCSA), section 22a-174-19a, limiting the 

SO2 emission rate to 0.33 lb/MMBtu for fossil-fuel-fired EGUs greater than 15 MW 

that are also Title IV sources (effective, 2007). 

• RCSA, section 22a-174-22, limiting the non-ozone seasonal NOX emission rate to 0.15 

lb/MMBtu for fossil-fuel-fired EGUs greater than 15 MW (effective, 2007). 

• RCSA, section 22a-199, limiting the mercury (Hg) emission rate to 0.0000006 

lb/MMBtu for all coal-fired EGUs or alternatively coal-fired EGUs can meet a 90% 

Hg emission reduction (effective, 2008). 

Delaware EGU Regulations: Delaware adopted the following regulations governing EGU 

emissions: 

• Reg. 1144, Control of Stationary Generator Emissions, requiring emission controls for 

SO2, PM, VOC, and NOX state-wide, effective January 2006. 

• Reg. 1146, Electric Generating Unit (EGU) Multi-Pollutant Regulation, requiring SO2

and NOX emission controls state-wide, effective December 2007. SO2 reductions will 

be more than regulation specifies 

• Reg. 1148, Control of Stationary Combustion Turbine Electric Generating Unit 

Emissions, requiring SO2, NOX, and PM2.5 emission controls state-wide, effective 

January 2007. 

Delaware estimates that these regulations will result in the following emission reductions for 

affected units: SO2 emissions of 32,630 tons in 2002 will decline to 8,137 tons in 2018 (a 75-

percent reduction); NOX emissions of 8,735tons in 2002 will decline to 3,740 tons in 2018 (a 

57-percent reduction). Also, Delaware anticipates the following reductions resulting from the 

consent decree with Valero Refinery Delaware City, DE (formerly Motiva, Valero 

Enterprises): SO2 emissions of 29,747 tons in 2002 will decline to 608 tons in 2018 (a 98-

percent reduction); NOX emissions in 1,022 in 2002 will decline to 102 tons in 2018 (a 90-

percent reduction). 

Maine EGU Regulations: Chapter 145, NOX Control Program, limits the NOX emission rate 

to 0.22 lb/MMBtu for fossil-fuel-fired units greater than 25 MW built before 1995 with a heat 

input capacity between 250 and 750 MMBtu/hr, and also limits the NOX emission rate to 0.15 

lb/MMBtu for fossil-fuel-fired units greater than 25 MW built before 1995 with a heat input 

capacity greater than 750 MMBtu/hr (effective, 2007). 

Massachusetts EGU Regulations: Based on the Massachusetts Department of Environmental 

Protection’s 310 CMR 7.29, Emissions Standards for Power Plants, adopted in 2001, six of 

the largest fossil-fuel-fired power plants in Massachusetts must comply with emissions 

limitations for NOX, SO2, Hg, and CO2. These regulations will achieve an approximately 50-

percent reduction in NOX emissions and a 50- to 75-percent reduction in SO2 emissions. 

Depending on the compliance paths selected, the affected facilities will meet the output-based 

NOX and SO2 standards between 2004 and 2008. This regulation also limits the six 

grandfathered EGUs to a CO2 emission rate of 1,800 lb/MWh. 
118

New Hampshire EGU Regulations: New Hampshire adopted the following regulations 

governing EGU emissions: 

• Chapter Env-A 2900, Multiple Pollutant Annual Budget Trading and Banking 

Program, capping NOX emissions at 3,644 tons per year, SO2 emissions at 7,289 tons 

per year, and CO2 emissions at 5,425,866 tons CO2 per year for all existing fossil-fuelfired steam units by December 31, 2006. 

• Chapter Env-A 3200, NOX Budget Trading Program, limiting ozone season NOX

emissions on all fossil-fuel-fired EGUs greater than 15 MW to 0.15 lb/MMBtu, 

effective November 2, 2007. 

New Jersey New Source Review Settlement Agreements: The New Jersey settlement 

agreement with PSEG required the following actions for specific EGUs: 

• Bergen Unit #2: Repower to combined cycle by December 31, 2002. 

• Hudson Unit #2: Install dry FGD or approved alternative technology by Dec. 31, 

2006, to control SO2 emissions and operate the control technology at all times the unit 

operates to limit SO2 emissions to 0.15 lb/MMBtu; install SCR or approved alternative 

technology by May 1, 2007, to control NOX emissions and operate the control 

technology year-round to limit NOX emissions to 0.1 lb/MMBtu; and install a 

baghouse or approved alternative technology by May 1, 2007, to control and limit PM 

emissions to 0.015 lb PM/MMBtu. 

• Mercer Unit #1: Install dry FGD or approved alternative technology by Dec. 31, 

2010, to control SO2 emissions and operate the control technology at all times the unit 

operates to limit SO2 emissions to 0.15 lb/MMBtu; and install SCR or approved 

alternative technology by 2005 to control NOX emissions and operate the control 

technology during ozone season only in 2005 and year-round by May 1, 2006, to limit 

NOX emissions to 0.13 lb/MMBtu. 

• Mercer Unit #2: Install dry FGD or approved alternative technology by Dec. 31, 

2012, to control SO2 emissions and operate the control technology at all times the unit 

operates to limit SO2 emissions to 0.15 lb/MMBtu; and install SCR or approved 

alternative technology by 2004 to control NOX emissions and operate the control 

technology during ozone season only in 2004 and year-round by May 1, 2006, to limit 

NOX emissions to 0.13 lb/MMBtu. 

The New Jersey settlement also requires that units operating an FGD use coal having a 

monthly average sulfur content no greater than 2 percent.

New York EGU Regulations: New York adopted the following regulations governing EGU 

emissions: 

• Title 6 NYCRR Parts 237, Acid Deposition Reduction NOX Budget Trading Program, 

limits NOX emissions on all fossil-fuel-fired EGUs greater than 25 MW to a nonozone season cap of 39,908 tons in 2007. 
119

• Title 6 NYCRR Parts 238, Acid Deposition Reduction SO2 Budget Trading Program, 

limits SO2 emissions from all fossil-fuel-fired EGUs greater than 25 MW to an annual 

cap of 197,046 tons per year starting in 2007 and an annual cap of 131,364 tons per 

year starting in 2008. 

North Carolina Clean Smokestacks Act: Enacted in 2002, this legislation requires that coalfired EGUs achieve a 77-percent cut in NOX emissions by 2009 and a 73-percent cut in sulfur 

dioxide SO2 emissions by 2013. This act also established annual caps on both SO2 and NOX

emissions for the two primary utility 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 effects of the following consent agreements 

in the VISTAS states were reflected in the emissions inventories 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/SO2/NOX emissions; comply with system-wide annual PM/SO2/NOX emissions 

limits; agree not to buy, sell, or trade SO2/NOX allowances allocated to Santee Cooper 

System as a result of this agreement; and to comply with emission unit limits of this 

agreement. 

• TECO: Under a settlement agreement, by 2008, Tampa Electric in the state of Florida 

will install permanent emission control equipment to meet stringent pollution limits; 

implement a series of interim pollution reduction measures to reduce emissions while 

the permanent controls are designed and installed; and retire pollution emission 

allowances that Tampa Electric or others could use, or sell to others, to emit additional 

NOX, SO2, and PM.

• VEPCO: Virginia Electric and Power Co. agreed to spend $1.2 billion by 2013 to 

eliminate 237,000 tons of SO2 and NOX emissions each year from eight coal-fired 

electricity generating plants in Virginia and West Virginia. 

• Gulf Power 7: A 2002 agreement calls for Gulf Power to upgrade its operation to cut 

NOX emission rates by 61 percent at its Crist 7 generating plant by 2007 with major 

reductions beginning in early 2005. The Crist plant is a significant source of NOX

emissions in the Pensacola, Florida, area. 
120

11.3.2 Controls on Non-EGU Point Sources Expected by 2018 

For non-EGU sources within MANE-VU, Vermont relied on MANE-VU’s Version 3.0 

Emission Inventory for 2002. MACTEC conducted an analysis of various control measures 

as documented in the Emission Projections Report (Attachment L). Control factors were 

applied to the 2018 MANE-VU inventory for non-EGUs to represent the following national, 

regional, or state control measures: 

• NOX SIP Call Phase I (NOX Budget Trading Program) (except ME, NH, VT); 

• NOX SIP Call Phase II (except ME, NH, VT); 

• NOX RACT in 1-hour Ozone SIPs (already included in the 2002 inventory); 

• NOX OTC 2001 Model Rule for ICI Boilers; 

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

• Combustion Turbine and RICE MACT (NOX co-benefits were not included and 

assumed to be small); 

• Industrial Boiler/Process Heater MACT*; and 

• Refinery Enforcement Initiative (Fluid catalytic cracking units and fluid coking units, 

process heaters and boilers, flare gas recovery, leak detection and repair, and benzene 

(wastewater)). 

In addition, states provided control measure information about specific non-EGU sources or 

regulatory programs in their states. MANE-VU used the state-specific data to the extent it 

was available. For example, several states developed additional control measures in the 

course of their planning efforts to reduce ozone within the Ozone Transport Region (OTR). 

These control measures were included by MANE-VU in the inventories used for regional 

haze modeling. (The affected states may or may not have committed to adopting these 

measures in their ozone SIPs.) For specific states, the ozone-reduction strategies included in 

the modeling would reduce NOX emissions from the following non-EGU point sources: 

• Asphalt production plants in Connecticut, New Jersey, New York, and the District of 

Columbia; 

• Cement kilns in Maine, Maryland, New York, and Pennsylvania; and 

• Glass and fiberglass furnaces in Maryland, Massachusetts, New Jersey, New York, 

and Pennsylvania. 

For other regions, MANE-VU used emission inventory data developed by the RPOs for those 

regions, including VISTAS’s Base G2, MRPO’s Base K, and CenRAP’s emissions inventory. 

Non-EGU source controls incorporated into the modeling include those required under the 

following consent agreements as reflected in the VISTAS inventory: 

 

* The inventory was prepared before the MACT for Industrial Boilers and Process Heaters was vacated. Control efficiency 

was assumed to be 4 percent for SO2 and 40 percent for PM. The overall effects of including these reductions in the 

inventory are estimated to be minimal. 
121

• Dupont: A 2007 agreement calls for E. I. Dupont Nemours & Co.’s James River plant 

to install dual absorption pollution control equipment by September 1, 2009, resulting 

in SO2 emission reductions of approximately 1,000 tons annually. The James River 

plant is a non-EGU located in the state of Virginia. 

• Stone Container: A 2004 agreement calls for the West Point Paper Mill in Virginia 

owned by Smurfit/Stone Container to control SO2 emissions from its #8 Power Boiler 

by using a wet scrubber. This control device should result in reductions of over 3,500 

tons of SO2 in 2018. 

11.3.3 Controls on Area Sources Expected by 2018 

For area sources within MANE-VU, Vermont relied on MANE-VU’s Version 3.0 Emissions 

Inventory for 2002. In general, MANE-VU developed the 2018 inventory for area sources by 

applying growth and control factors to the 2002 Version 3.0 inventory. Area source control 

factors were developed for the following national or regional control measures: 

• The Ozone Transport Commission’s VOC Model Rules, in OTC states where 

appropriate (for consumer products, architectural and industrial maintenance coatings, 

portable fuel containers, mobile equipment repair and refinishing, and solvent 

cleaning); 

• Stage I vapor recovery systems at vehicle refueling stations in Vermont and Stage II 

vapor recovery systems at Vermont vehicle refueling stations any gasoline dispensing 

facility with an annual gasoline throughput of 400,000 gallons or more; 

• New Jersey post-2002 area source controls; and 

• Residential woodstove NSPS. 

The following additional control measures were included in the 2018 analysis to reduce NOX

and VOC emissions for the following area source categories for some (identified) states: 

• NOX control measures for combustion of coal; natural gas; and #2, #4, and #6 fuel oils 

(CT, NJ, and NY only); 

• VOC control measures for adhesives and sealants (all MANE-VU states except New 

Jersey* and VT); 

• VOC control measures for emulsified and cutback asphalt paving (all MANE-VU states 

except ME and VT); 

• VOC control measures for consumer products (all MANE-VU states except VT); and 

• VOC control measures for portable fuel containers (all MANE-VU states except VT). 

As noted above, inventory data for other regions were obtained from those regions’ RPOs. 

 

* New Jersey’s emission reductions from control measures for adhesives and sealants apply only to area sources. No reductions 

for point sources (SCC 4-02-0007-xx) were included to avoid inventory double-counting.
122

Some of the area-source control measures listed above may have been developed by states for 

the primary purpose of reducing ozone within the Ozone Transport Region (OTR) – see Part 

11.3.2 for information on other measures included in states’ ozone SIPs. 

11.3.4 Controls on Mobile Sources Expected by 2018 

For the on-road mobile source emission inventory, Vermont relied on MANE-VU’s Version 

3.0 emission inventory, which included the following emission control measures for Vermont: 

• Vermont’s Low Emission Vehicle Regulations, which incorporate by reference 

California’s emissions standards for motor vehicles; 

• An enhanced motor vehicle emissions inspection and maintenance (IM) program 

including an anti-tampering inspection for 1995 and older vehicles, and an on-board 

diagnostics (OBD) inspection for 1996 and newer vehicles. 

• Federal On-Board Refueling Vapor Recovery (ORVR) Rule; 

• Federal Heavy-Duty Diesel Engine Emission Standards for Trucks and Buses; and 

• Federal Emission Standards for Large Industrial Spark-Ignition Engines and 

Recreational Vehicles. 

Similar programs in other MANE-VU states were included in the on-road mobile source 

emission inventory, where applicable. The last three items listed above are federal programs, 

briefly described here: 

On-Board Refueling Vapor Recovery (ORVR) Rule: The 1990 Clean Air Act (CAA) 

Amendments contain provisions that require passenger cars to capture refueling emissions. In 

1994, EPA published the ORVR Rule establishing standards for refueling emissions controls 

for passenger cars and light trucks. The onboard controls were required to be phased in for all 

new car production by 2000 and for all light trucks by 2006. The rule established a refueling 

emission standard of 0.20 grams per gallon of dispensed fuel, which was expected to yield a 

95 percent reduction of VOC emissions over uncontrolled levels. The CAA authorizes EPA 

to allow state and local agencies that are not in the ozone transport region (OTR) to phase out 

Stage II programs, even in the worst nonattainment areas, once EPA has determined that 

onboard systems are in widespread use. Additional requirements apply under section 

184(b)(2) of the CAA to states in the OTR. 

Heavy-Duty Diesel Engine Emission Standards for Trucks and Buses: EPA set a PM 

emissions standard of 0.01 grams per brake-horsepower-hour (g/bhp-hr) for new heavy-duty 

diesel engines in trucks and buses, to take full effect in the 2007 model year. This rule also 

includes standards for NOX and non-methane hydrocarbons (NMHC) of 0.20 g/bhp-hr and 

0.14 g/bhp-hr, respectively. These NOX and NMHC standards will be phased in together 

between 2007 and 2010. Sulfur in diesel fuel must be lowered to enable modern pollutioncontrol technology to be effective on the trucks and buses that use this fuel. EPA will require a 
123

97-percent reduction in the sulfur content of highway diesel fuel from its current level of 500 

parts per million (low-sulfur diesel) to 15 parts per million (ultra-low sulfur diesel).

Emission Standards for Large Industrial Spark-Ignition Engines and Recreational 

Vehicles: EPA has adopted new standards for emissions of NOX, hydrocarbons (HC), and 

carbon monoxide (CO) from several groups of previously unregulated non-road engines. 

Included are large industrial spark-ignition engines and recreational vehicles. The affected 

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 variety of farm and construction applications. Non-road recreational vehicles 

include snowmobiles, off-highway motorcycles, and all-terrain vehicles. These rules were 

initially effective in 2004 and will be fully phased-in by 2012. 

11.3.5 Controls on Non-Road Sources Expected by 2018 

For non-road emission sources, Vermont used Version 3.0 of the MANE-VU 2002 Emissions 

Inventory. Because the NONROAD Model used to develop the non-road source emissions 

did not include aircraft, commercial marine vessels, and locomotives, MANE-VU’s 

contractor, MACTEC, developed the inventory for these sources. Non-road mobile source 

emissions for the 2018 emission inventory were calculated with EPA’s NONROAD2005 

emissions model as incorporated into the NMIM2005 (National Mobile Inventory Model) 

database. The NONROAD model accounts for emissions benefits associated with federal 

non-road emission control requirements 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. 

As noted above, inventory data for other regions were obtained from those regions’ RPOs. 

11.4 Additional Reasonable Measures 

As required under 40 CFR 51.308(d)(1)(i)(A), Vermont and the other MANE-VU states 

applied four-factor analysis to potential control measures for the purpose of establishing 

reasonable progress goals (see Subsection 10.2 for detailed description). Reasonable 

measures include those that the affected states have already committed themselves to 

implementing, as described in Subsection 11.3, above. In addition, the MANE-VU states 

have identified other control measures that were found to be reasonable and were included in 
124

the modeling that was used to set reasonable progress goals. (These additional measures 

surpass the “beyond-on-the-way” emission controls and inventories.) All of the control 

measures – those embodied in the states’ commitments to existing or planned programs and 

the additional reasonable control measures described below – comprise the long-term strategy 

for improving visibility at MANE-VU Class I Areas. 

Specifically, the Vermont/MANE-VU long-term strategy relies on the following additional 

measures to reduce pollutants that cause regional haze. 

• Timely implementation of BART requirements in all states with BART eligible 

sources. 

• A low-sulfur fuel oil strategy in the inner-zone MANE-VU states (New Jersey, New 

York, Delaware, and Pennsylvania, or portions thereof) to reduce the sulfur content of: 

− #2 distillate oil to 0.05 percent (500 ppm) sulfur, by weight, by no later than 2012; 

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

− #6 residual oil to 0.3-0.5 percent sulfur, by weight, by no later than 2012; 

− Further reduction of the sulfur content of distillate oil to 15 ppm by 2016. 

• A low-sulfur fuel oil strategy in the outer-zone MANE-VU states (the remainder of the 

MANE-VU region) to reduce the sulfur content of: 

− #2 distillate oil to 0.05 percent (500 ppm) sulfur, by weight, by no later than 2014; 

− #4 residual oil to 0.25-0.50 percent sulfur, by weight, by no later than 2018; 

− #6 residual oil to 0.5 percent sulfur or less, by weight, by no later than 2018; 

− Further reduction of the sulfur content of distillate oil to 15 ppm by 2018, 

contingent on supply and availability. 

• A 90-percent or greater reduction in sulfur dioxide (SO2) emissions from each of the 

EGUs identified by MANE-VU as reasonably anticipated to cause or contribute to 

impairment of visibility in any mandatory Class I area in the MANE-VU region. (This 

requirement affects 167 point sources, or stacks, at EGU facilities in the eastern 

United States.) If it is infeasible to achieve this level of SO2 reductions from specific 

EGUs, equivalent alternative measures will be pursued in the affected states. 

• Continued evaluation of other control measures, including energy efficiency, 

alternative clean fuels, other measures to reduce SO2 and nitrogen oxide (NOX) 

emissions from all coal-burning facilities by 2018, and new source performance 

standards for wood combustion. 

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 

I states (Maine, New Hampshire, Vermont, and New Jersey) are asking states outside the 

MANE-VU region that contribute to visibility impairment inside the region to pursue similar 

measures. The control measures that non-MANE-VU states choose to pursue may be directed 
125

toward the same emission source sectors identified by MANE-VU for its own emission 

reductions, or they may be equivalent measures targeting other source sectors. Under MANEVU’s long-term strategy, states will be allowed up to ten years to pursue adoption and 

implementation of proposed control measures. 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. 

11.4.1 BART 

Vermont has no BART-eligible sources. However, Vermont considers the implementation of 

the BART provisions of the Regional Haze Rule (40 CFR 51.308(e)) – in other MANE-VU 

states and in other upwind RPOs - as one of the important reasonable strategies included in 

this SIP. For electrical generating units, EPA determined that CAIR fulfilled BART 

requirements for this sector. Although CAIR has been remanded to EPA, Vermont assumes 

that EPA will either promulgate an interstate rule to replace CAIR that will achieve EGU 

emissions reductions of a magnitude as least as large as would have been required under 

CAIR, or will require specific emissions controls on all BART-eligible EGU sources if an 

alternative interstate rule is not promulgated. 

To assess the benefits of implementing BART controls for MANE-VU’s non-EGU sectors, 

NESCAUM included in the final 2018 CMAQ modeling analysis anticipated emission 

reductions for the region’s BART-eligible facilities, as described previously in Part 10.2.2 of 

this SIP. It is anticipated that twelve units at eight BART-eligible sources in MANE-VU 

would be controlled as a result of BART requirements alone (see Table 10.3). 

Note that additional emission reductions will occur at many other BART-eligible facilities 

within MANE-VU as a result of controls achieved by other programs that serve as BART but 

are not specifically identified as such (e.g., RACT control measures). While not specifically 

identified as being attributable to BART, these additional emission reductions were fully 

accounted for in the 2018 CMAQ modeling. 

Further visibility benefits are likely 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 I Areas that would be likely to accrue from such measures. 

11.4.2 Low-Sulfur Oil Strategy 

The important assumption underlying MANE-VU’s low-sulfur fuel oil strategy is that refiners 

can, by 2018, produce sufficient quantities of home heating and other fuel oils with lower 

sulfur content than current fuel supplies at only a small increase in price to the end user. The 

expected reductions in sulfur content range from 50 percent for the heavier grades (#4 and #6 

residual) to a minimum of 75 percent and maximum of 99.25 percent for #2 fuel oil (also 

known as home heating oil, distillate, or diesel fuel). As much as three-fourths of the total 

sulfur reductions achieved by this strategy will come from using low-sulfur #2 distillate for 

space heating in the residential and commercial sectors. The costs of these emissions 

reductions are estimated at $550 to $750 per ton, as documented in the MANE-VU 
126

Reasonable Progress Report. While the costs of the low-sulfur fuel oil strategy remain 

somewhat uncertain, they appear to be reasonable when measured against the costs of 

controlling other sectors. 

Currently there are logistical issues in supplying large quantities of low-sulfur oils to the 

PADD1B (northern New England region). This oil is supplied by PADD1A and barged into 

the region in quantities that allow for blending with high-sulfur fuels to produce 1-percent 

sulfur fuels. Current capacities are limited by Federal restrictions that prevent large ships 

from transferring fuels between two U.S. ports. The states of this region intend to build full 

capacity for 0.5-percent-sulfur #6 fuel oil by 2018. 

The MANE-VU states agree that a low-sulfur oil strategy is reasonable to pursue in the next 

ten years. Vermont will review the details of this strategy in five years, coincident with 

Vermont’s first regional haze SIP progress report, to ascertain that requiring the use of lowsulfur fuel remains viable for implementation by 2018. 

11.4.3 Targeted EGU Strategy 

MANE-VU has identified emissions from the top 167 EGU emission points that contribute 

the most to visibility impairment at MANE-VU Class I Areas (see Figure 10.2). Controlling 

emissions from these contributing facilities is crucial to mitigating haze pollution in 

wilderness areas and national parks of the Northeast states. 

MANE-VU’s agreed regional approach for the EGU source sector is to pursue a 90-percent 

control level on SO2 emissions from the 167 identified stacks by 2018. MANE-VU has 

concluded that pursuing this level of sulfur reduction is both reasonable and cost-effective. 

Even though current wet scrubber technology can achieve sulfur reductions greater than 95 

percent, an overall 90-percent sulfur reduction level would include the effects of lower 

average reduction rates from dry scrubbing technology, consistent with historical experience. 

The costs of SO2 emission reductions will vary by unit. MANE-VU’s Reasonable Progress 

Report (Attachment U) summarizes the available control methods and costs, which range 

from $170 to $5,700 per ton (2006 dollars), depending on site-specific factors such as size of 

unit, combustion technology used, and type of fuel burned. 

Several other states within and outside the MANE-VU region have implemented state-specific 

EGU emission reduction programs that will help MANE-VU meet visibility improvement 

goals. Many of the state programs that will contribute to meeting the targeted EGU strategy 

are identified in Part 11.3.1 of this section. Listed below are other state programs not 

previously identified that will also contribute to meeting this strategy. These other programs 

may yield additional benefits by controlling emissions at certain EGUs not listed among the 

top 167 EGU stacks. The listed programs represent existing commitments by the states and, 

as such, were included in MANE-VU’s most recent modeling. 

Maryland Healthy Air Act: Maryland adopted the following requirements governing EGU 

emissions: 

• For NOX: 

− Phase I (2009) sets unit-specific annual caps totaling 20,216 tons and ozone-
127

season caps totaling 8,900 tons. 

− Phase II (2012) sets unit-specific annual caps totaling 16,667 tons and ozoneseason caps totaling 7,337 tons. 

• For SO2: 

− Phase I (2010) sets unit-specific annual caps totaling 48,818 tons. 

− Phase II (2013) sets unit-specific annual caps totaling 37,235 tons. 

• For mercury: 

− Phase I (2010) requires a 12-month-rolling-average minimum removal 

efficiency of 80 percent. 

− Phase II (2013) requires a 12-month-rolling-average minimum removal 

efficiency of 90 percent. 

The specific EGUs included 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 of 

emission allowances, no inter-company trading of allowances, and no banking of allowances 

from year to year were included in the analyses. 

New Jersey Mercury MACT Rule: Under this rule all coal-fired EGUs in New Jersey will 

have a mercury removal efficiency of 90 percent. (Some SO2 reductions may occur as a cobenefit of mercury emission controls.) 

New Hampshire RSA 125-O, Multiple Pollutant Reduction Program: 

• Merrimack Station Unit MK-1: 8,799 tons (90%) SO2 reduction by 2013.

• Merrimack Station Unit MK-21: 18,812 tons (90%) SO2 reduction by 2013.

• Newington Station Unit NT-1: 2,613 tons (50%) SO2 reduction by 2018

Consent Agreements in the VISTAS region: The following consent agreements in the 

VISTAS states were reflected in the emissions inventories used for those states: 

• East Kentucky Power Cooperative: A July 2, 2007, consent agreement between EPA 

and East Kentucky Power Cooperative (EKPC) requires the utility to reduce its SO2

emissions by 54,000 tons per year and its NOX emissions by 8,000 tons per year, by 

installing and operating selective catalytic reduction (SCR) technology; low-NOX

burners, and PM and mercury continuous emissions monitors at the utility’s Spurlock, 

Dale, and Cooper Plants. According to the 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. 

• American Electric Power: Under this agreement, American Electric Power (AEP) will 

spend $4.6 billion dollars for emission controls at sixteen plants located in Indiana, 
128

Kentucky, Ohio, Virginia, and West Virginia. These control measures will eliminate 

72,000 tons of NOX emissions each year by 2016 and 174,000 tons of SO2 emissions 

each year by 2018 from the affected facilities.

11.5 Source Retirement and Replacement Schedules 

40 CFR Section 51.308(d)(3)(v)(D) of the Regional Haze Rule requires Vermont 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 previously in Subsection 10.3, Reasonable Progress Goals for Class I Areas in the 

State. See also Table B-5 in the Emission Projections Report (Attachment L). 

11.6 Measures to Mitigate the Impacts of Construction Activities 

40 CFR 51.308(d)(3)(v)(B) of the Regional Haze Rule requires Vermont to consider measures 

to mitigate the impacts of construction activities on regional haze. MANE-VU’s 

consideration of control measures for construction activities is documented in “Technical 

Support Document on Measures to Mitigate the Visibility Impacts of Construction Activities 

in the MANE-VU Region,” Draft, October 20, 2006,” (Attachment Z). 

MANE-VU’s Contribution Assessment (Attachment B) found that, from a regional haze 

perspective, crustal material generally does not play a major role. On the 20 percent bestvisibility days during the 2000-2004 baseline period, crustal material accounted for 6 to 11 

percent of particle-related light extinction at MANE-VU Class I Areas. On the 20 percent 

worst-visibility days, however, the ratio was reduced to 2 to 3 percent. Furthermore, the 

crustal fraction is largely made up of pollutants of natural origin (e.g., soil or sea salt) that are 

not targeted under the Regional Haze Rule. Nevertheless, the crustal fraction at any given 

location can be heavily influenced by the proximity of construction activities; and 

construction activities occurring in the immediate vicinity of MANE-VU Class I Areas could 

have a noticeable effect on visibility. 

For this regional haze SIP, Vermont considered additional measures to mitigate the impacts of 

construction activities but decided to defer evaluation of further controls. Future deliberations 

on potential control measures for construction activities and their possible implementation 

will be documented in the first regional haze SIP progress report in 2012. 

11.7 Agricultural and Forestry Smoke Management 

40 CFR 51.308(d)(3)(v)(E) requires Vermont to consider smoke management techniques 

related to agricultural and forestry management in developing the long-term strategy. 

MANE-VU’s analysis of smoke management in the context of regional haze is documented in 

“Technical Support Document on Agricultural and Forestry Smoke Management in the 

MANE-VU Region, September 1, 2006,” (Attachment S). 

As that report notes, fires used for resource benefits are of far less significance to the total 

inventory of fine-particle pollutant emissions than other sources of wood smoke in the region. 
129

The largest MANE-VU wood smoke source categories, with respect to PM2.5 emissions, are 

residential wood combustion (73 percent); open burning (15 percent); and industrial, 

commercial, and institutional wood combustion (9 percent). Unwanted fires involving 

buildings and wild lands make up only a minor fraction of wood burning emissions and 

cannot be reasonably addressed in a SIP. Fires that are covered under smoke management 

plans, including agricultural and prescribed forest burning, constitute less than one percent of 

total wood smoke emissions in MANE-VU. 

Wild fire emissions within Vermont and other MANE-VU states are also relatively small and 

infrequent contributors to regional PM emissions. However, Lye Brook and other MANE-VU 

class 1 areas are occasionally impacted by wild fire smoke emissions from other regions, such 

as from the lightning-induced forest fires in Quebec Province in July 2002. These natural 

wild fire smoke emissions occasionally impair visibility at Lye Brook, but are not considered 

manmade or controllable – and in fact are part of “natural background” conditions. 

Vermont will continue to review the impacts from agricultural use of fire and prescribed fire 

for forest or ecosystem management. If those impacts become important for maintaining 

reasonable progress in the future, revisions to the regional haze SIP will include a smoke 

management plan. Vermont will continue to consult with the US Forest Service regarding 

potential impacts of prescribed fire on visibility in the Lye Brook Wilderness. 

11.8 Estimated Effects of Long-Term Strategy on Visibility 

40 CFR 51.308(d)(3)(v)(G) requires Vermont to consider, in developing its long-term 

strategy, the anticipated net effect on visibility due to projected changes in point, area, and 

mobile source emissions over the period addressed by the long-term strategy. NESCAUM 

conducted modeling to evaluate the expected improvements to visibility at affected Class I 

areas by 2018 as a consequence of implementing MANE-VU’s long-term strategy. Those 

visibility improvements will result, in part, from the efforts identified in this SIP to reduce 

emissions that originate in Vermont and other MANE-VU states. 

All Class I states affected by emissions originating in Vermont have (or will have) established 

reasonable progress goals for 2018 for each of their Class I areas. The control measures 

included in this SIP represent the reasonable efforts of Vermont, in conjunction with efforts of 

other MANE-VU states, toward achieving the reasonable progress goals established by the 

affected states. 

Based on the most recent MANE-VU modeling, the proposed control measures will reduce 

sulfate levels at affected Class I areas by about one-third on the worst visibility days and by 

6 to 31 percent on the best visibility days by 2018. Nitrate and elemental carbon levels will 

also show substantial reductions across all areas for both best and worst days, while smaller 

reductions in organic carbon levels will occur. Small increases are predicted for the fine soil 

component of regional haze. There is a possibility that the predicted increases in this 

component are not real but, rather, related to structural differences in the data sets used in the 

modeling for the baseline and future years. (Specifically, the fire emissions inventory used in 

VISTAS for the base year relied on an earlier version of fire emissions data than the one used 

for the 2018 inventory.) No changes are predicted for sea salt because the model does not 
130

track this component. 

The 2000-2004 visibility readings at affected Class I areas provide the baseline against which 

future visibility readings will be measured to assess progress deriving from implementation of 

Vermont’s regional haze SIP and those of the other MANE-VU states. To determine baseline 

visibility for affected Class I areas, Vermont used the 2000-2004 IMPROVE monitoring data 

to calculate the average deciview values for the 20 percent best visibility days and the 20 

percent worst visibility days over that period. Thus, the 20 percent best day and 20 percent 

worst day values represent average visibility conditions for the top and bottom quintiles. 

To create the series of visibility graphs which follow, 2018 visibility estimates were made in 

accordance with EPA modeling guidance. First, 2002 daily average baseline concentrations 

were multiplied by their corresponding relative reduction factors to obtain 2018 projected 

concentrations for each day. The 2018 projected concentrations were then used to derive 

daily visibility in deciviews. As a final step, the deciview values for the 20 percent of days 

having best visibility were averaged, and the process repeated for the 20 percent of days 

having worst visibility. The resulting averages represent the projected upper and lower 

quintiles of visibility in 2018. 

The following is provided to assist with interpretation of the line graphs in Figures 11.1 and 

Figures 11.3 through 11.6. Note that lower deciview values indicate better visibility. 

• The irregular blue line (~) represents the 20 percent best visibility average value as 

determined from monitoring data for each year of the period 2001-2005. 

• The irregular red line (~) represents the 20 percent worst visibility average value as 

determined from monitoring data for each year of the period 2001-2005. 

• The straight orange line (▬) represents the 20 percent best visibility average value as 

determined from monitoring data for the 5-year period of 2000-2004. (This line 

represents the 20 percent best visibility baseline condition.) 

• The straight blue line (▬) represents the 20 percent worst visibility average value as 

determined from monitoring data for the 5-year period of 2000-2004. (This line 

represents the 20 percent worst visibility baseline condition.) 

• The straight broken line (▪▪▪) is a continuation of the 20 percent best visibility baseline, 

representing the 20 percent best visibility condition as it would be with no further 

degradation or improvement. 

• The straight green line (▬) represents the 20 percent worst visibility values that 

establish the uniform rate of progress for the period 2004-2064. (This line is 

sometimes referred to as the uniform progress line, or “glide slope.” It was created by 

linear interpolation between the 20 percent worst visibility baseline value in 2004 and 

the 20 percent worst visibility value under natural conditions in 2064. If visibility 

improvements match this rate of progress, actual visibility will return to natural 

conditions in 2064.) 

• The light-green dash (▬) shown at 2064 represents the theoretical 20 percent best 

visibility value under natural conditions (i.e., no anthropogenic emissions). 

• The purple star (1⁄4) represents the 20 percent best visibility value in 2018 after 

implementation of MANE-VU’s long-term strategy, as predicted by the CMAQ model. 
131

(This value is a reasonable progress goal.) 

• The blue star (1⁄4) represents the 20 percent worst visibility value in 2018 after 

implementation of MANE-VU’s long-term strategy, as predicted by the CMAQ model. 

(This value is a reasonable progress goal.) 

Figure 11.1 illustrates predicted visibility improvements at Lye Brook Wilderness. Observe 

that the blue star lies below the green line, indicating that, by 2018, the long-term strategy of 

this SIP will result in visibility improvements surpassing the uniform rate of progress on days 

of worst visibility. Similarly, the position of the purple star below the dashed line indicates 

that visibility requirements will be met, i.e., there will be no further degradation from baseline 

conditions on days of best visibility. Figure 11.2 presents bar graphs depicting expected 

improvements in haze-causing pollutant levels at the Lye Brook Wilderness. The graph on 

the left shows concentrations of visibility-impairing pollutants on days of best visibility for 

the 2000-2004 baseline period, 2018 modeled year, and natural background condition. The 

graph on the right is a similar plot for days of worst visibility. The graphs show that almost 

all of the expected improvements will result from reductions in sulfate concentrations. If the 

states adhere to MANE-VU’s reasonable progress goals, sulfate levels (as a fraction of the 

total pollutant burden) will fall from about 60 percent in 2000-2004 to no more than 50 

percent in 2018 and to less than 10 percent (natural conditions) in 2064. 

Figures 11.3 through 11.6 are line graphs showing anticipated visibility improvements for the 

other MANE-VU Class I Areas. All locations are projected to meet or exceed their uniformrate-of-progress goals for 2018. In addition, all areas are expected to see improvements in 

best-day visibility relative to baseline values. 

Figure 11.1 Expected Visibility Improvement at Lye Brook Wilderness Based on Most Recent Projections 

0

5

10

15

20

25

30

19851990199520002005201020152020202520302035204020452050205520602065

Year

Decivews

20% Worst Observed

20% Best Observed

20% Worst Baseline

20% Best Baseline

Uniform Progress

No Degradation

CMAQ 20% Worst

CMAQ 20% Best

20% Best 'Natural'
132

Figure 11.2 Expected Improvements in Pollutant Concentrations at Lye Brook Wilderness on Best and 

Worst Days 

Figure 11.3 Expected Visibility Improvement at Acadia National Park Based on Most Recent Projections 

0

5

10

15

20

25

30

19851990199520002005201020152020202520302035204020452050205520602065

Year

Decivews

20% Worst Observed

20% Best Observed

20% Worst Baseline

20% Best Baseline

Uniform Progress

No Degradation

CMAQ 20% Worst

CMAQ 20% Best

20% Best 'Natural'
133

Figure 11.4 Expected Visibility Improvement at Brigantine National Wildlife Refuge Based on Most 

Recent Projections 

0

5

10

15

20

25

30

35

19851990199520002005201020152020202520302035204020452050205520602065

Year

Decivews

20% Worst Observed

20% Best Observed

20% Worst Baseline

20% Best Baseline

Uniform Progress

No Degradation

CMAQ 20% Worst

CMAQ 20% Best

20% Best 'Natural'

Figure 11.5 Expected Visibility Improvement at Great Gulf Wilderness Based on Most Recent 

Projections* 

0

5

10

15

20

25

30

19851990199520002005201020152020202520302035204020452050205520602065

Year

Decivews

20% Worst Observed

20% Best Observed

20% Worst Baseline

20% Best Baseline

Uniform Progress

No Degradation

CMAQ 20% Worst

CMAQ 20% Best

20% Best 'Natural'

 

* The visibility improvement estimate for Great Gulf Wilderness also serves as an estimate for Presidential Range - Dry 

River Wilderness.
134

Figure 11.6 Expected Visibility Improvement at Moosehorn National Wildlife Refuge Based on Most 

Recent Projections*

0

5

10

15

20

25

19851990199520002005201020152020202520302035204020452050205520602065

Year

Decivews

20% Worst Observed

20% Best Observed

20% Worst Baseline

20% Best Baseline

Uniform Progress

No Degradation

CMAQ 20% Worst

CMAQ 20% Best

20% Best 'Natural'

11.9 Vermont’s Share of Emission Reductions 

40 CFR 51.308(d)(3)(ii) of the Regional Haze Rule requires Vermont to demonstrate that its 

implementation plan includes all measures necessary to obtain its share of emission 

reductions needed to meet the reasonable progress goals. The modeling analyses referenced 

in Subsection 11.8, above, demonstrate that the Vermont/MANE-VU long-term strategy is 

sufficient to meet these visibility goals. 

As demonstrated in Section 2 of this plan, Vermont sulfur emissions, in total, currently contribute 

less than 1 percent of sulfate in the Lye Brook Wilderness Area and less than half of 1 percent of 

sulfate in any other Class 1 area. These contributions will be even smaller as Vermont complies 

with the MANE-VU low-sulfur fuel oil strategy, as nearly 85% of Vermont’s SO2 emissions 

originate from ICI boilers and residential heating units which would be reduced 

significantly by 2018 by the MANE-VU (outer zone states) low sulfur fuel strategy. 

The basis for the long-term strategy is a statement adopted by MANE-VU on June 20, 2007 

(see Part 3.3.3, The MANE-VU “Ask”). This document provides that each state will have up 

to 10 years to pursue adoption and implementation of reasonable control measures for NOX

and SO2 emission reductions. Vermont’s regional haze SIP is wholly consistent with this 

long-term strategy. To meet its obligation, Vermont agrees to pursue the following general 

and specific emission reduction measures: 

 

* The visibility improvement estimate for Moosehorn Wilderness also serves as an estimate for Roosevelt/Campobello 

International Park.
135

• Participation in a regional low-sulfur fuel oil strategy that will result in SO2 emission 

reductions from ICI boilers and residential heating units across the state; 

• Continued evaluation of other possible control measures for haze-causing emissions. 

11.10 Vermont Commitments to Specific Regulatory Changes That Will 

Further Protect Visibility 

The MANE-VU regional long-term strategy for reaching reasonable progress goals for 

visibility established at Class I areas in the MANE-VU region implies no large scale sulfur 

emissions reductions from existing sources in Vermont except for the sulfur-in-fuel limitations 

to be implemented on a regional market basis (see Section 11.9 above). Nevertheless, 

Vermont intends to establish a secondary welfare standard for particulate matter measures as 

sulfate ion and a significance level for single source impact relative to regional haze at Lye 

Brook Wilderness Area. These regulatory changes will further limit the potential for impacts 

from both new and existing Vermont sources of sulfur oxides or particulate matter emissions 

that contribute (however slightly) to haze in the Lye Brook Wilderness Area. 

The setting of an ambient sulfate standard and the incorporation of a significance level for 

ambient sulfate impact will also establish in the Vermont SIP a level of significance of impact 

relative to regional haze at Lye Brook Wilderness Area that is consistent with the assumptions 

made by MANE-VU in identifying the most significant large stationary sources impacting on 

visibility at Class I areas in MANE-VU. Vermont intends to revise its current Air Pollution 

Control Regulation §5-312 “Sulfates – Secondary Ambient Air Quality Standard” which is a 

standard applicable to maximum 24-hour ambient concentration and summer seasonal mean 

ambient concentration in Lye Brook Wilderness Area and other areas of Vermont Sensitive to 

Acidic Deposition (lands above 2500 feet elevation). It is likely that the two standards will 

remain at their current levels (2 ug/m3), however the sulfate ion concentration will be 

identified as the relevant measure of ambient impact considered to be in violation if exceeded. 

Based on data relevant to all the planning for this regional haze plan, it is already well 

established that both of these standards are violated by sulfate particulate matter transported 

into Vermont from outside the state. The new regulation is expected to be adopted within the 

next year (by 2010) and will be submitted as part of the long-term strategy portion of this 

Vermont Regional Haze SIP. 

In conjunction with the minor changes to existing regulation §5-312, Vermont intends to 

revise the level of significant impact for sulfate ion which is currently contained in Vermont 

Air Pollution Control Regulation TABLE 3 “Levels of Significant Impact for Nonattainment 

Areas”. Currently, the regulation establishes a significance level for seasonal (April thru 

September 6 month average) “sulfates” at 0.2 ug/m3

 as well as a 24-hr maximum significance 

level for “sulfates” at 2.0 ug/m3

. Both of these significance levels are used in New Source 

Review (or evaluation of an existing source’s impact potential) to identify whether a single 

source is significantly impacting on the current violations of the Vermont Secondary Ambient 

Air Quality Standards for Sulfates. Both of the current significance levels will be reduced by 

at least an order of magnitude. As currently being drafted, a summer seasonal sulfate level of 

0.004 ug/m3

 and a 24-hour maximum of 0.10 ug/m3 will be specified as representing 

significant sulfate impacts from individual sources. The revision of these significance levels 
136

will establish in Vermont regulation, new significance levels for sulfate ion that are consistent 

with the MANE-VU criteria for identifying single EGU stacks that were included in the list of 

“Top 167 EGU Stacks Affecting MANE-VU Class I Areas”, which is a major component of 

the MANE-VU long-term strategy. It is Vermont’s intention to use these revised “levels of 

significant impact” to determine whether newly proposed (or existing) sources, located within 

Vermont (or in upwind states), are significantly contributing to exceedances of Vermont’s 

sulfate standard, and therefore significantly contributing to Lye Broook visibility impairment. 

When this SIP has been approved by EPA, Vermont assumes that sources exceeding this 

significance level will be considered by EPA to be interfering with Vermont’s ability to 

assure reasonable progress toward the Clean Air Act §169 national visibility goal. 

The significance levels being considered currently to replace the existing ones are on a par 

with the EPA 9/21/07 Federal Register Proposal for PM2.5 Increments, Significant Impact 

Levels (SILs) and Significant Monitoring Concentrations (SMCs). Under the EPA proposal, 

the SILs for annual and 24-hr maximum PM2.5 for Class I areas suggest levels close to the 

levels Vermont is considering. The proposal will not be finalized for several months but after 

public hearing and comment is expected to be adopted as revisions to the Vermont Air 

Pollution Control Regulations by 2010. These revised regulations will be submitted to EPA 

for inclusion in Vermont’s Regional Haze SIP as part of its long-term strategy for restoration 

of natural visibility in Lye Brook Wilderness Area. 

11.11 Emission Limitations and Compliance Schedules 

40 CFR 51.308(d)(3)(v)(C) requires Vermont to establish emission limitations and 

compliance schedules to meet reasonable progress goals. Emission limitations and 

compliance schedules are already in place for the Vermont and other state programs outlined 

in Subsection 11.3 of this section. For the additional reasonable control measures described 

in Subsection 11.4, certain emission limitations like the MANE-VU low sulfur fuel strategy 

and any additional measures deemed to be necessary may need to be established by law 

through revisions to VT Statutes Title 10 Chapter 23 (Air Pollution Control) and/or 

amendments to Vermont’s Air Pollution Control Regulations. 

Vermont will continue to evaluate all measures included in the long-term strategy to ascertain 

whether they remain reasonable to implement by 2018 and will formalize that determination 

in the first regional haze SIP progress report, due in 2012. Vermont intends to adopt all 

reasonable control measures as expeditiously as practicable, in a manner consistent with state 

law, so that they may be in place by the end of the ten-year planning period. 

11.12 Enforceability of Emission Limitations and Control Measures 

40 CFR 51.308(d)(3)(v)(F) requires Vermont to consider the enforceability of emissions 

limitations and control measures in developing its long term strategy. All control measures 

incorporated into law or codified in administrative rules will be enforceable. Any facility 

subject to state or federal permit requirements, including Title V facilities, will be required to 

comply with the specific permit conditions that reference the applicable provisions of those 

laws and rules. 
137

The key statutory provisions that allow for the enforceability of emissions limitations and 

control measures related to regional haze are: 

• 10 VSA chapter 23, Air Pollution Control (see e.g., 10 VSA § 554, which authorizes 

the adoption and amendment of rules; 10 VSA § 556, which authorizes a permitting 

program for the construction or modification of air contaminant sources; 10 VSA § 

556a, which authorizes a permitting program for the operation of air contaminant 

sources; 10 VSA § 558,which authorizes the establishment of emission control 

requirements that may be necessary to prevent, abate, or control air pollution; 10 VSA 

§ 567, which authorizes rules to control emissions from motor vehicles; and 10 VSA § 

568, which provides for penalties for the violation of 10 VSA chapter 23 or any rules 

adopted thereunder); 

• 10 VSA chapter 201, Administrative Environmental Law Enforcement, which 

authorizes enforcement of 10 VSA chapter 23; 

• 3 VSA § 2822(j)(1), which establishes fees for air pollution control permits and 

registrations issued under 10 VSA chapter 23 

Provisions of the Vermont Air Pollution Control Regulations of particular relevance to the 

regional haze SIP are: 

• § 5-221(1) Prohibition of Potentially Polluting Materials in Fuel (Sulfur limitation in 

fuel); 

• § 5-312 Sulfates - Secondary Ambient Air Quality Standards; 

• Subchapter V: Review of New Air Contaminant Sources; 

• Subchapter X: Operating Permits; and 

The Vermont Air Pollution Control Regulations rules provide for enforceable emission control 

measures and compliance schedules to meet the applicable requirements of the Clean Air Act 

and rules promulgated by EPA. The Vermont rules also define the permit program and fee 

structure for stationary sources, to ensure that national ambient air quality standards are 

achieved. 

In order to comply with and implement the MANE-VU low-sulfur oil strategy, Vermont 

commits to revising the § 5-221(1) of the Vermont Air Pollution Control Regulations, which 

currently specifies a sulfur limitation in fuel of 2% sulfur by weight to limit the sulfur content 

of distillate oil to 0.05% sulfur by weight (500 ppm) by no later than 2014, of #4 residual oil 

to 0.25-0.5% sulfur by weight by no later than 2018, and of #6 residual oil to no greater than 

0.5 % sulfur by weight by no later than 2018, and to reduce the sulfur content of distillate oil 

further to 15 ppm by 2018, depending on supply availability. 
138

Ultimately, Vermont’s Regional Haze SIP is dependent on the implementation of enforceable 

emission limitations and control measures, both within the state and in other states identified 

as contributing to visibility impairment at Vermont’s Lye Brook Wilderness Area. Because 

Vermont has no jurisdiction over other states, the attainment of regional progress goals will, 

to a large extent, be predicated on the good-faith efforts of contributing upwind states to meet 

their fair share of emission reductions through implementation of their own enforceable 

control measures. While Vermont can provide assurances regarding the implementation of instate emission controls, the bulk of regional-haze-causing pollutants in the Lye Brook 

Wilderness will continue to come from out-of-state sources. 

11.13 Prevention of Significant Deterioration 

In Subchapter 5 of Vermont’s Air Pollution Control Regulations, the permit review 

requirements for new major stationary sources or major modifications (emitting > 50 tons of 

any air contaminant) require in § 5-502 (4) an Air Quality Impact Evaluation that 

demonstrates the new allowable emissions will not result in an exceedance of the remaining 

increments for SO2, NO2 or PM10 in any Class 1 area (i.e. Lye Brook). The applicant must 

also demonstrate “that the increase in allowable emissions will not cause an adverse impact 

on visibility in any sensitive area or in any Class I Federal area and will not interfere with 

reasonable progress toward the remedying of existing man-made visibility impairment in a 

sensitive area. Said demonstration shall be submitted to the Agency and the appropriate 

Federal Land Manager at least 60 days prior to the close of the public comment period on the 

source or modification” (where Sensitive Area is defined as “any portion of the area 

comprising Lye Brook Wilderness Area and all other terrain in Vermont at or above the 

elevation of 2500 feet above mean sea level”). In this manner, new major sources and 

existing sources making major modifications will be constructed and operated in a manner 

that will not degrade air quality or visibility. The PSD permitting program is an integral part 

of Vermont’s long-term strategy for meeting its regional haze goals.