# V ERMONT 

# S TATE 

# I MPLEMENTATION 

# P LAN 

# (SIP)

R EVISION



# R EGIONAL 

# H AZE

S TATE OF 

## V ERMONT



## D EPARTMENT OF 

## E NVIRONMENTAL 

## C ONSERVATION



## J UNE 

## 2009ii T ABLE OF C ONTENTS

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 G ENERAL B ACKGROUND / H ISTORY OF F EDERAL V ISIBILITY R ULES ..........................................................1

1.2 T HE 1999 R EGIONAL H AZE R ULE ...............................................................................................................2

1.3 R EGIONAL H AZE P LANNING AFTER THE V ACATUR OF CAIR ......................................................................4

1.4 S TATE I MPLEMENTATION P LAN R EQUIREMENTS .........................................................................................7

1.5 T HE B ASICS OF H AZE

............................................................................................................................... ...8

1.6 A NATOMY OF R EGIONAL H AZE .................................................................................................................10

1.7 T HE L YE B ROOK W ILDERNESS A REA ........................................................................................................12

1.8 M ONITORING AND R ECENT V ISIBILITY T RENDS ........................................................................................13

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

2.1 S TATES C ONTRIBUTING TO V ISIBILITY I MPAIRMENT AT L YE B ROOK ........................................................22

2.2 O THER C LASS I A REAS A FFECTED BY V ERMONT E MISSIONS ....................................................................23

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

3.1 M ID -A TLANTIC / N ORTHEAST V ISIBILITY U NION (MANE-VU) ...............................................................25

3.2 R EGIONAL C ONSULTATION AND THE MANE-VU “A SK ”..........................................................................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 “A sk” – Vermont .................................................................................................... ............ 32

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

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

3.2.4 Consultatio n Issues ........................................................................................................... ...............34

3.2.5 State/Tribe and Federal La nd Manager Coordination ....................................................................37

4. ASSESSMENT OF BASELINE AND NAT URAL VISIBILITY CONDITIONS ............................39

4.1 C ALCULATION M ETHODOLOGY .................................................................................................................40

4.2 MANE-VU B ASELINE V ISIBILITY ............................................................................................................41

4.3 L YE B ROOK W ILDERNESS B ASELINE V ISIBILITY ......................................................................................42

4.4 L YE B ROOK W ILDERNESS A REA

– N ATURAL B ACKGROUND ....................................................................43

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

5.1 IMPROVE P ROGRAM O BJECTIVES AND V ERMONT M ONITORING C OMMITMENTS ...................................44

5.2 L YE B ROOK W ILDERNESS

, V ERMONT

- M ONITOR L OCATION ...................................................................45

5.3 L YE B ROOK W ILDERNESS M ONITORING S TRATEGY .................................................................................46

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

6.1 B ASELINE AND F UTURE -Y EAR E MISSIONS I NVENTORIES FOR M ODELING .................................................48

6.1.1 Baseline Inve ntory (2002)..................................................................................................... ...........49

6.1.2 Future-Year Emissi ons Inventories............................................................................................. .....50

6.2 E MISSION P ROCESSOR S ELECTION AND C ONFIGURATION .........................................................................51

6.3 I NVENTORIES FOR S PECIFIC S OURCE C ATEGORIES ....................................................................................51

6.3.1 Stationary Point Sou rces...................................................................................................... ............51

6.3.1.1 Electric Generati ng Units (EGUs) ............................................................................................... ........... 52

6.3.1.2 Non-EGU Poin t Sources.......................................................................................................... ............... 52
6.3.2 Stationary Area Sources ....................................................................................................... ...........53iii 6.3.3 Non-Road Mo bile So urces ....................................................................................................... ........53

6.3.4 On-Road Mob ile So urces........................................................................................................ .........54

6.3.5 Biogenic Emis sion Sou rces ..................................................................................................... .........54

6.4 S UMMARY OF V ERMONT E MISSIONS I NVENTORIES ...................................................................................55

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

7.1 M ETEOROLOGY

............................................................................................................................... ..........58

7.2 D ATA P REPARATION

............................................................................................................................... ..59

7.3 M ODEL P LATFORMS

............................................................................................................................... ...59

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

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

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

7.4 R EFERENCES FOR S ECTION 7.....................................................................................................................62

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

8.1 F INE -P ARTICLE P OLLUTANTS ....................................................................................................................63

8.2 C ONTRIBUTING S TATES AND R EGIONS ......................................................................................................64

8.3 E MISSION S OURCES AND C HARACTERISTICS .............................................................................................68

8.3.1 Sulfur Dioxide (SO 2 ) ........................................................................................................................69

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

8.3.3 Oxides of Nitrogen (NO X ) ................................................................................................................72

8.3.4 Primary Particulate Matter (PM 10 and PM 2.5 ).................................................................................74

8.3.5 Ammonia Emissions (NH 3 )...............................................................................................................79

8.4 R EFERENCES FOR S ECTION 8.....................................................................................................................81

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

9.1 B ART -E LIGIBLE EGU S AND THE R OLE OF CAIR.......................................................................................84

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

10.1 C ALCULATION OF U NIFORM R ATE OF P ROGRESS ......................................................................................85

10.2 I DENTIFICATION OF (A DDITIONAL ) R EASONABLE C ONTROL M EASURES ..................................................86

10.2.1 Rationale for Determinin g Reasonable Contro ls ........................................................................87

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

10.2.3 Low-Sulfur Fu el Strategy ...................................................................................................... ......90

10.2.4 Targeted EGU Strategy for SO 2 Reduction.................................................................................95

10.2.5 Non-EGU SO 2 Emissions Reduction Strategy for Non-MANE-VU States .................................101

10.3 R EASONABLE P ROGRESS G OALS FOR C LASS I A REAS IN THE S TATE .......................................................108

10.4 V ISIBILITY E FFECTS OF (A DDITIONAL ) R EASONABLE C ONTROL M EASURES ..........................................109

10.5 R EFERENCES FOR S ECTION 10.................................................................................................................111

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

11.1 O VERVIEW OF S TRATEGY D EVELOPMENT P ROCESS ................................................................................112

11.2 T ECHNICAL B ASIS FOR S TRATEGY D EVELOPMENT .................................................................................114

11.3 E XISTING C OMMITMENTS TO R EDUCE E MISSIONS ..................................................................................115

11.3.1 Controls on EGUs Ex pected by 2018........................................................................................116

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

11.3.3 Controls on Area Source s Expected by 2018 ............................................................................121

11.3.4 Controls on Mobile Sour ces Expected by 2018.........................................................................122

11.3.5 Controls on Non-Road Sour ces Expected by 2018....................................................................123

11.4 A DDITIONAL R EASONABLE M EASURES ...................................................................................................123

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

11.4.2 Low-Sulfur Oi l Strategy ....................................................................................................... .....125

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

11.5 S OURCE R ETIREMENT AND R EPLACEMENT S CHEDULES ..........................................................................128

11.6 M EASURES TO M ITIGATE THE I MPACTS OF C ONSTRUCTION A CTIVITIES .................................................128

11.7 A GRICULTURAL AND F ORESTRY S MOKE M ANAGEMENT .........................................................................128iv 11.8 E STIMATED E FFECTS OF L ONG -T ERM S TRATEGY ON V ISIBILITY ............................................................129

11.9 V ERMONT ’ S S HARE OF E MISSION R EDUCTIONS ......................................................................................134

11.10 V ERMONT C OMMITMENTS TO S PECIFIC R EGULATORY C HANGES T HAT W ILL F URTHER P ROTECT
V ISIBILITY

............................................................................................................................... ................135

11.11 E MISSION L IMITATIONS AND C OMPLIANCE S CHEDULES .........................................................................136

11.12 E NFORCEABILITY OF E MISSION L IMITATIONS AND C ONTROL M EASURES ...............................................136

11.13 P REVENTION OF S IGNIFICANT D ETERIORATION ......................................................................................138v L IST OF F IGURES

Figure 1.1 Ma p of CAIR States.............................................................................................. .................................5 Figure 1.2 Illustrated Spect rum of Visibility Impairment Cond itions at Lye Brook Wilderness ............................9 Figure 1.3 Contribution of Aerosol Species to Ae rosol Mass and Light Extinction at Lye Brook, 2004..............11 Figure 1.4 Lye Broo k Falls................................................................................................. ..................................12 Figure 1.5 Bourne Pond in the Lye Brook W ilderness Area.................................................................... .............13 Figure 1.6 Lye Brook Tra il Signs ........................................................................................... ..............................13 Figure 1.7 Lye Brook and Nearby Class I areas .............................................................................. ....................13 Figure 1.8 Lye Broo k 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. Came ra Site.............................14 Figure 1.11 Lye Brook Aerosol and Nephelome ter Monitoring Site on Little Mt. Equinox ...................................15 Figure 1.12 Location of Lye Brook Monito ring site relative to the Wilder ness 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 Regi onal Planning Organ izations (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 Mo nitoring Site on Little Mt. Equinox......................................................... ....47 Figure 7.1 National and Northeas t Regional RPO Mode ling Grid Domains..................................................... 58 Figure 7.2 Examples of Processed Model-Ready Emissions: (a) SO 2 from Point, (b) NO 2 from Area, (c) NO 2 from On-Road, (d) NO 2 from Non-Road, (e) ISOP from Biogenic, and (f) SO 2 from all Source Catego ries ..................................................................................................................... ......................60 Figure 8.1 Contributions to PM 2.5 Extinction at 7 Class 1 Ar eas..........................................................................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 Cl ass I sites .............................................................66 Figure 8.5 Modeled 2002 Sulfate Contribu tions at Lye Brook on the 20% Worst Days ......................................67 Figure 8.6 Trends in Annual Sulfur Dioxide (SO 2 ) Emissions, by State ..............................................................69 Figure 8.7 2002 Sulfur Dioxide (SO 2 ) 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 (NO X

) Emissions, by State.............................................................73 Figure 8.10 2002 Nitrogen Oxide (NO X ) 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 (PM 10 ) Emissions, by State .........................................................75 Figure 8.12 Trends in Primary Fine Particle (PM 2.5 ) Emissions, by State.............................................................75 Figure 8.13 Upwind Incremental Pro bability for LYBR PMF Wo od Smoke Source..............................................77 Figure 8.14 Incremental probability for 1989-1995 Un derhill VT wood smoke compared with Canadian forest fire loca tions................................................................................................................. .......................77 Figure 8.15 2002 Primary Coarse Particle (PM 10 ) 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 (PM 2.5 ) Emissions, by State Bar Graph = Percentage Fractions of Four Source Categories Line Graph = Tota l Annual Emissions (106 tpy)..................................................79 Figure 8.17 Trends in Ammonia (NH 3 ) Emissions, by State...................................................................................80vi Figure 8.18 2002 Ammonia (NH 3 ) 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 PM 2.5

Due to Low-Sulfur Fuel Strategy (Phases I and 2 Combined)
Relative to OTB/OTW (values in μ g/m 3 ) .............................................................................................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 PM 2.5 Resulting from a 90-Percent Reduction in

SO 2 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 Con centrations at Lye Brook W ilderness on Best and Worst Days ........................................................................................................................... .......................132 Figure 11.3 Expected Visibility Improvement at Acad ia National Park Based on Most Recent Projections .......132 Figure 11.4 Expected Visibility Improvement at Br igantine National Wildlife Ref uge Based on Most Recent Projec tions .................................................................................................................... ....................133 Figure 11.5 Expected Visibility Improvement at Great Gulf Wilderness Based on Most Recent Projections......133 Figure 11.6 Expected Visibility Improvement at Mo osehorn National Wildlife Refuge Based on Most Recent Projec tions .................................................................................................................... ....................134vii L IST OF T ABLES

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 Broo k, and Brigantine .......................................................................................... .....22 Table 2.3 Contributions of Individual States and Regions to Total Annual Average Sulfate Impact (Percent, Mass Basis) at the Lye Broo k Wilderness in 2002 ..............................................................................23 Table 2.4 Vermont’s Contributions to Total Annual Average Sulfate Impact (Percent, Mass Basis) at Eastern

Class I Area s in 2002 .......................................................................................................... ................24

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

Table 3.2 MANE-VU Consultation Principles for Region al Haze Planning ..................................................... .27 Table 3.3 Summary of MANE-VU Co nsultations on Region al Haze Planning...................................................28 Table 3.4 States (Listed by Regional Planning Organization) and Provinces Contributing to Visibility Impairment at Vermont’s Ly e Brook Wilder ness Area........................................................................30

Table 4.1 IMPROVE Mon itors 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 Cla ss 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 fo r Vermont (tpy) .....................................................5 5

Table 6.3 2018 BOTW Emissions Inventory Summary for Vermont (tpy) ......................................................... ..55 Table 6.4 2018 Most Recent (“Updated Scenar io”) 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 Progre ss Calculation (all valu es in d eciview s)................................................... ......86 Table 10.2 Summary of Results from Four-Fac tor Analysis of Different Source Ca tegories................................88

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

Controlled as a Resu lt of BART Alone).......................................................................................... .....90 Table 10.4 Estimated Cost Ranges for SO 2 Control Options for Coal-Fired EGU Boilers (2006 dollars per ton of SO 2 removed) ...................................................................................................................... ...........99

Table 10.5 Available SO 2 Control Options fo r ICI Boilers..................................................................................103

Table 10.6 Estimated Costs of Dry Sorbent Injection (DSI) fo r ICI Boilers (2006 dollars)................................105 Table 10.7 Estimated Costs of Flue Gas Desulfurization for ICI Bo ilers (2006 do llars)....................................106 Table 10.8 Reasonable Progress Goals for Lye Brook Wilderness (in deciviews)...............................................1 08viii L IST OF A TTACHMENTS

ATTACHMENT A – MANE- VU Contribution Assessment

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

ATTACHMENT C – Consultation Su mmaries 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 Modeli ng for Reasonable Progress Goals

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

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

Stakeholders

ATTACHMENT I – MANE-VU Natura l Background Visibility Conditions

ATTACHMENT J – MANE-VU Baseline and Natural Background Visibility Conditions ATTACHMENT K – Technical Support Do cument for 20002 MANE-VU SIP Modeling Inventories, Version 3 ATTACHMENT L – Development of Em ission Projections for 2009, 2012, and 2018 for

NonEGU Point and Nonroad Sour ces in the MANE-VU Region ATTACHMENT M – Development of MANE-VU Mobile Source Projection Inventories for SMOKE/MOBILE6 Application

ATTACHMENT N – NYSDEC Techni cal Support Document TSD-1c

ATTACHMENT O – MANE-VU 2018 Visibility Projections

ATTACHMENT P – NYSDEC Techni cal Support Document TSD-1a ATTACHMENT Q – NYSDEC Techni cal Support Document TSD-1e

ATTACHMENT R – NYSDEC Tec hnical Support Document TSD-1d ATTACHMENT S – Technical Support Docume nt 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 R easonable Progress for Regional Haze

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

ATTACHMENT W – Low-Sulfur Heati ng Oil in the Northeast States ATTACHMENT X – Comparison of CAIR and CAIR Plus Pr oposal Using the Integrated Planning Model (IPM®)

ATTACHMENT Y – The Nature of Fine Partic le 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 Regionix A CKNOWLEDGMENTS

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

invaluable assistance and contri butions provided in developing this Plan by the dedicated staff of the NESCAUM, MARAMA and MANE-VU regi onal organizations, a nd the other MANEVU State Air Programs. We are particularly gr ateful for the substant ial 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 a dded Section 169 (42 U.S.C. 7491) setting forth the followi ng 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 in clude many of our best known na tural places, including the Grand Canyon, Yosemite, Yellowstone, Mount Rainier, Shenandoah, the Great Smokies, Acadia, and the Everglades. In Vermont, th e affected area is the Lye Brook Wilderness.

Section 169 also directed EPA to promulgate regulations to assu re reasonable progress toward this national visibility goal and to require State Implementation Plan (SIP) revisions in states containing the affected Clas s I Federal Areas as well as in states, “the emissions from which may reasonably be anticipat ed to cause or contribute to impairment of visibility in any such [C lass I] area”. In 1980, EPA prom ulgated visibility regulations which focused primarily on impairment attribut able to individual sources or small groups of sources (“plume blight”), but which also required long-term st rategies to assure reasonable progress toward the national visibility goal.

In April, 1986, the State of Vermont submitte d 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 sulfat e aerosol transported

from SO 2 sources in upwind states. The 19 86 VT SIP revision included a summer seasonal sulfate standard of 2 μg/m 3 (roughly half the estimated prevailing concentration at that time) as an interim measure to assure re asonable progress toward the national visibility goal for Lye Brook. Vermont also requested th at EPA implement an Eastern US regional

SO 2 emission reduction program to improve visi bility in Lye Brook (and other eastern US Class I areas), and also specifi cally 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 vi sibility SIP. Alt hough it concurred that “Vermont’s visibility impairment is predomin antly 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 SO 2 emission reductions, and requested SIP calls in major upwind contri buting states. EPA argued that it had no curr ent regulatory2 basis to address regional haze effects, and that substantial additional research was needed to develop the technical ba sis for such regulations.

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

SO 2 emission reductions in the Eastern US, si milar to but somewhat less stringent than and with a longer time delay than what Verm ont had requested in its 1986 SIP. The 1990

CAA Amendments also added Section 169B (42 U.S.C. 7492), authorizing further visibility research and peri odic 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 visi bility transport commissions and setting forth their duties, Section 169B(f ) of the 1990 CAA mandated cr eation of the Grand Canyon Visibility Transport Commission (GCVTC) to make recommendations to EPA for the region affecting the visibility of the Gr and 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 effect s of various po llution sources over a wide geographic region. Th is wide reaching pollution net means that many states – including those without Class I Areas – are requi red to participate in haze reduction efforts.

In consultation with the states and trib es, EPA designated five Regional Planning Organizations (RPO) to assist with the coor dination and cooperation needed to address the

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

formed the Mid-Atlantic / Northe ast 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 Associ ation 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 vi sibility 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 Appeal s for the District of Columbia Circuit issued another ruling vacating th e 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 Re gional Haze Rule governing the optional emissions trading program for certain Western States an d 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 SIP3 EPA’s subsequent final rulema king provided the following ch anges to the Regional Haze Regulations:

1. Revised the regulatory text in Sect ion 51.308(e)(2)(i) in response to the CEED court’s remand, to remove the requireme nt 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 Secti on 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 op tional 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 impairme nt in the form of regional haze. Haze is an atmospheric phenomenon that obscures the clar ity, color, texture, and form of what we see. Haze in the Eastern US is caused pr imarily by anthropogenic (manmade) pollutants but can also be influenced by a number of na tural 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 th an 2.5 microns diameter) being the predominant contributor at most times and places. Some haze-causing part icles are emitted directly to the atmosphere by primary particle emission sources such as el ectric power plants, factories, automobiles, construction activities, and agri cultural burning. Others occur when gases emitted to the air (particle precursors) interact to form secondary particles. Some secondary particles including sulfate and nitrate co mpounds 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. Be cause of the regional nature of haze, EPA’s regulations require the states to consul t with one another toward the national goal of improving visibi lity – specifically, at the 15 6 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 includ e enforceable emission reduction measures designed to meet reasonable progress goals. Th e first long-term strate gy covers the 10 to 15-year period ending in 2018, and subsequent re visions are to be issued every 10 years thereafter. In identifying the emission reducti on measures to be in cluded in the long-term4 strategy, states should address all types of manmade emissions contributing to visibility degradation in Class I areas, in cluding those from mobile sour ces; 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 in to account emission reduct ions attributable to ongoing air pollution control programs at the state, regional, or nationa l levels. For most states and regions of the country, however, additional emission control measures beyond those already on the books will be necessary if na tional visibility goals are to be achieved. In addition, the Regional Haze Rule mandates th at control measures be implemented for certain existing sources placed into operati on 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. Ve rmont’s SIP, was developed af ter extensive consultations with other states and regional planning organizations. In pa rticular, Vermont contributed to many analyses and reports produced by the me mber states of the Northeast States for Coordinated Air Use Manageme nt (NESCAUM), the Mid-Atla ntic Regional Air Managers Association (MARAMA), and the Mid-Atlantic /Northeast Visibil ity Union (MANE-VU) Regional Planning Organization for the purpos e of coordinated regional haze planning.

Vermont also consulted with states outside th e 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 so me other states in asserting that additional measures beyond CA IR 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, reas onable 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 (SO 2 ) and nitrogen oxides (NO X ) emissions in the eastern Unite d States through a cap-and-trade system using emission allowances. As prom ulgated, CAIR permanently caps emissions originating in 28 eastern states and the Di strict of Columbia (Figure 1.1). Although Vermont was not designated as a participatin g 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, SO 2 emissions in the affected states would be reduced by more than 70 percent from 2003 levels, and NO X 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 yi eld $85 to $100 billion in health benefits and nearly $2 billion in visi bility benefits per year by 2015, and premature mortality would be substantially reduced across the eastern U.S.

This program came to an abrupt end, howev er, on July 11, 2008, when the U.S. Court of Appeals for the District of Co lumbia 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 th e 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 whethe r the court should stay its vacatur until EPA promulgates a revised rule. Vermont, along wi th 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 stat es argued that because they “reasonably relied on CAIR in formulating lo ng-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 in6 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 re gional haze SIPs, some Southeast states have relied almost entirely on CAIR to demons trate 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 inve ntories 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 “notwith standing the relative fl aws 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 enviro nmental 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, Verm ont believes that future emissions and air quality levels will not be vastly different from values pred icted 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 repr esent 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 stat es have maintained all along that the regional haze SIPs should look beyond the provi sions 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 so me other states in asserting that additional measures beyond CA IR 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 fact or for the long term, but does not present impediment to making visibility progress in th e near term. The salient points to consider

are as follows:

• Because Vermont is a non-CAIR state, CA IR does not directly affect any of Vermont’s proposed in-state control stra tegies for visibility improvement.

• Vermont will meet its “fair share” of emissions in comparison with other MANEVU states and the original CAIR stat es, as Vermont’s long-term strategy demonstrates (see Section 11.0).

• Sources in upwind states rel ease 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 s hould be available. It7 should then be possible to fine-tune regional haze plans to take into account any rule that EPA has promulgated to re place CAIR. Vermont is committed to reviewing and updating its regional ha ze SIP as new information becomes

available.

Given the D.C. Circuit’s remand without vacatu r of CAIR, Vermont ha s chosen to retain appropriate references to CAIR in the comp letion of Vermont’s Regional Haze SIP, which will help to maintain continuity with the la rge body of completed work – much of it based

on CAIR – that serves as the foundation fo r 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 regiona l planning, and state/tr ibe and Federal Land Manager (FLM) coordina tion 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 ev ery 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 reasona ble 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), Vermon t will also make periodic updates to

Vermont’s emissions inventor y (see Section 6, Emissions I nventory). Vermont proposes to complete these updates to co incide with the progress report s. 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 appr opriate 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 furt her revision of the plan is not needed.

• If Vermont determines that its implemen tation plan is or ma y 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 EP A Administrator and to thos e other state(s). Vermont8 will also collaborate with the other stat e(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 implemen tation plan is or ma y be inadequate to ensure reasonable progress as a result of emissions from sources in another country, Vermont will provide notification, along w ith 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 reducin g the amount of visual information about distant objects that reaches an observer. Some light scattering by air molecules (Rayleigh scattering) and naturally occurring aeroso ls occurs even under natural conditions. * The distribution of particles in the atmosphere depends on mete orological 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 pl ume of pollution from a particular emissions source – occurs under stable atmospheric condi tions, 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 extincti on per unit distance (e.g., Mm-1) † ; and deciviews (dv), a useful metric for m easuring increments of visibility change that are just perceptible to the human eye. Visibility impairment can be measured directly by nephelometer (light scattering) or transmi ssometer (light transmission – includes both scattering and absorption) and can also be calculated from color slide photographs using slide densitometry measurements, known target di stances, and estimated inherent contrast measurements. Light extinction and other visibility metrics can also be “reconstructed”

from measured concentrations of ambient particle species co mponents, taking into account their unique light-scattering (o r absorbing) properties and ma king appropriate adjustments for relative humidity effects on hygroscopi c 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 ki lometers or 8 dv. U nder current polluted conditions in the region, average visibility ra nges from 103 Mm-1 in the south to 55 Mm-1

* The fact that air molecules scatter mo re short-wavelength (blue) light accounts fo r the blue color of the sky. The term “aerosol” is defined as a suspension of part icles in a gas. In this report, the term refers to particles suspended in the atmosphere.

†. In units of inverse length. An inverse megamete r (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 da ys, visibility impairment in Northeast and

Mid-Atlantic Class I areas ra nges 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 clea nest days and 24.5 dv (visual range of 38 kilometers) on the 20 percent haziest days.

The photographs in Figure 1.2 illu strate 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 k ilometers south of Lye Brook Meadows.

The view looks across the Wilderness area towa rd Mother Myrick Mountain, 18 kilometers to the NNW (336 degrees). The visibility metr ics were calculated us ing slide densitometry measurements, known target distances, and esti mated inherent contrast measurements.

Figure 1.2 Illustrated Spectrum of Visibility Impairment Conditions at Lye Brook Wilderness10 The small particles that commonly cause ha zy conditions in the East are primarily composed of ammoniated sulfate and nitr ate compounds, organic ma tter (organic carbon and associated oxygen and hydrogen), elemental carbon (soot), crustal ma terial (e.g., soil dust) and sea salt. Of thes e constituents, only elementa l carbon impairs visibility by absorbing visible light; the others scatter light. Sulfates, nitrat es, and some of the organics are secondary pollutants that form in the atmosphere from precursor pollutants, primarily sulfur dioxide (SO 2 ), oxides of nitrogen (NO X ), and volatile organic compounds (VOCs), respectively. By contrast, soot, sea salt, crus tal material and some organic carbon particles are released directly to the at mosphere. Particle constituents also differ in their relative effectiveness at reducing visibility. Sulfat es 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 s how that fine particle concentrations, and hence visibility impairment, are generally hi ghest near industrial and highly populated

areas of the Northeast and Mid-Atlantic. Partic le concentrations are lower, and visibility conditions are better, at the more norther ly 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 s ubstantial 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 to tal light extinction at Class I

sites in the Northeast and Mid-Atlantic. Even on the clearest 20 per cent of days, sulfate typically constitutes 40 percent or more of tota l fine particle mass in the region. Moreover, sulfate accounts for 60 to 80 percent of the diffe rence in fine particle mass concentrations on hazy versus clear days.

Organic carbon consistently accounts for the ne xt largest fraction of total fine particle mass; its contribution typically ranges from 20 to 30 percent on the ha ziest days. Notably, organic carbon accounts for as mu ch as 40 to 50 pe rcent of total mass on the clearest days, indicating that biogenic hydrocar bon sources (i.e. vegetation) ar e important at Class I areas in the region.

The relative contributions of nitrate, elementa l 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 su ch as a monitoring site in Washington, DC,

* “20 percent best visibility conditi ons” are defined throughout this report as the simple average of the lower 20th percentile of a cumulative frequency distribution of available da ta (expressed in deciviews). Similarly, “20 percent worst visibility conditions” represent the upper 20th percent ile of the same distribution of available data.11 nitrate plays a considerably larger role , pointing to the im portance of local NO X and/or

NH 3 sources to fine-particle pollu tion in urban environments.

About half of the worst visibility days in Lye Brook occur in the summer when meteorological conditions are more conduciv e to the formation of sulfate from SO 2 and to the oxidation of organic aerosols. The remainin g 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 varia tion. Figure 1.3 shows the rela tive contributions of aerosol species at Lye Brook in 2004 to PM 10 mass (top) and aerosol light extinction (bottom) on the 20% best days (left) a nd 20% worst days (right).

Figure 1.3 Contribution of Aerosol Species to Aero sol 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. Emissi ons 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 tr ansport of airborne particles and precursor pollutants in the atmosphere. The key sulfate precursor, SO 2 , for example, has an atmospheric lifetime of several days and is known to be subject to transpor t distances of hundreds of miles. Once converted to SO4 aerosol, the atmospheric li fetime and transport distances for sulfur compounds are even greater. Gaseous NO X , nitric acid, ammonia and some gaseous organic carbon species are also subject to tran sport, and their trans port 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 Northeaste rn US have been traced to intercontinental transport of Asian and African dust.

* This is largely due to the fa ct that the ammonium nitrate bond is more st able at lower temperatures. The role of

ammonia in combination with both sulfate and nitrate is discussed further in later sections12 The importance of transport dynamics is well illustrated by a partic ularly 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 heavil y urbanized, southern portion of the northeastern Re gional Planning Organization re gion (i.e., Philadelphia - DC - southern New Jersey). At the same time, wind patterns above th e area of stagnation brought a steady flow of air from the Midwest into the New England st ates. This set of

conditions resulted in severa l days of unusually high con centrations of fine-particle pollution throughout the region. On July 17, 1999, ambient sulfate concentrations at Acadia National Park were 40 percent higher th an any previous measurement at that site since the late 1980s. On the same day, visibi lity at the Burlington, Vermont, airport was limited to just 3 miles. Fine Particle ma ss concentrations in the Lye Brook Wilderness exceeded 40 μg/m 3 , including nearly 30 μg/m 3 of ammonium sulfate. As is often the case, high concentrations of ground-level ozone accompanied these severe haze conditions. These coinciding conditions occurred becau se haze and ground-level ozone – although they are fundamentally different phenomena – tend to form and accumulate under similar meteorological conditions. In addition, hi gh concentrations of ozone and other photochemical oxidants can acce lerate the formation of se condary sulfate and organic aerosols, with possible contributions of different precursor gasses – SO 2 , NO

x , VOCs – from different sources in different regions mixing together and impa iring visibility over large downwind regions.



### 1.7 The Lye Brook Wilderness Area

Figure 1.4 Lye Brook Fall s The Lye Brook Wilderness Area, within the Green Mountain National Forest, is located east of

Manchester Center and S underland 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 Manchest er. 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, roughl y 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 Alba ny 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 nor th, 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 includ ed scene monitoring by automatic cameras, optical monitoring by integrating nephelome ter and aerosol monitoring by the IMPROVE (Interagency Monitoring of PROtected Visual Environments) program. Between 1987 and 1995, the USDA Forest Service operated 2 auto mated 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 to ward Mother Myrick Mtn. In June 1992, the14 camera was moved to a site on Little Mt. Equino x to the west of the Wilderness, looking ESE

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

Figure 1.9 Lye Brook Camera Si te & View 1987-91 and Lye Broo k 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 Visibilit y Conditions for the Stratton Mtn. Camera Site

Between 1993 and 2003, the USDA Forest Serv ice operated an unheated (Optec NGN2) integrating nephelometer at the Little Mt. Equin ox 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 Ly e Brook IMPROVE aerosol samplers (see Figure 1.11). Note that this site is west of, and at 101 5 meters elevation is slightly higher than the highest elevation (880 mete rs) in the wilderness (Figur e 1.12), but haze and aerosol measurements are considered representati ve of regional haze conditions in Lye Brook.15 Figure 1.11 Lye Brook Aerosol and Nephelo meter Monitoring Site on Little Mt. Equinox

Figure 1.12 Location of Lye Brook Monito ring site relative to the Wilderness Area16 IMPROVE aerosol sampling was in itiated at the Lye Brook Little Equinox site in September 1991. Daily (24-hour midnight to midnight lo cal time) samples were initially taken Wednesdays and Saturdays with th e schedule revised to every 3 rd day in 2001. Aerosol sampling and filter analysis is conducted according to procedures described in “ IMPROVE Standard Operating Protocols: Pa rticle Monitoring Network ( http://vista.cira.colostate.edu/im prove/Publications/IMPROVE_SOPs.htm ). The data are

stored in and available from the Visibility Information Exch ange Web System (VIEWS at: http://vista.cira.colostate.edu/views/ ).

The haze-relevant aerosol measurements include PM 10 mass and PM 2.5 mass (from which coarse mass is calculated), fine sulfate and nitrate ions (from whic h ammonium sulfate and

ammonium nitrate are calculated ), fine organic carbon (from which particulate organic matter is calculated), fine elemental carbon, fine elemental chlorine a nd 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, enha nced hygroscopic growth functions (for sulfate nitrate & sea salt) using climatologically derive d 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 extincti on calculations – referred to as the IMPROVE Equation, Version II, a nd 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/Pub lications/GrayLit/016_IMPROVEeqReview/IMPR OVEeqReview.htm

.

Bext ≈ 2.2 x fS (RH) x [Small (NH 4 ) 2 SO 4 ] + 4.8 x fL (RH) x [Large (NH 4 ) 2 SO 4 ] + 2.4 x fS (RH) x [Small NH 4 NO 3 ] + 5.1 x fL (RH) x [Large NH 4 NO 3 ] + 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 [NO 2 (ppb)]

Where: Bext = The light extinction coeffi cient in inverse megameters [Mm -1 ], fs (RH) and fL (RH) = Humidity factor a ssociated with small and large mode mass size distributions of (NH 4 ) 2 SO 4 and NH 4 NO 3, fss (RH) = Humidity factor associated with Sea Salt,

NO 2 data are not available and concentra tions are assumed to be negligible

Apportionment of the total concentrations of ammonium sulfate ((NH 4 ) 2 SO 4 ) into the concentrations of small and large size fractions is accomplished using the following equations:

[Large (NH 4 ) 2 SO 4 ] = [Total (NH 4 ) 2 SO 4 ]/20 x [Total (NH 4 ) 2 SO 4 ]

[Small (NH 4 ) 2 SO 4 ] = [Total (NH 4 ) 2 SO 4 ] - [Large(NH 4 ) 2 SO 4 ] Similar equations are used to apportion total ammonium nitrate (NH 4 NO 3 ) 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 B ext /10

The calculated deciviews are unitl ess values where the higher the value, th e greater amount of visibility impairment exists. A ch ange 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 averag ed over the clearest 20 % of days in each year and the haziest 20% of da ys 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 hazies t days over this 13-year period.

Figure 1.13 Trends in Visibility on Clean an d Hazy Days at the Ly e Brook IMPROVE Site

The EPA Regional Haze Rule requires that there be no deterioration of visibility on the cleanest 20% days, and that visibility impair ment 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 na tural background conditions (cu rrently 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 lig ht extinction at Lye Brook for the period 1993 through 1995 for the best 20 % days (top left) and worst 20% da ys (bottom left) along with the contributions of individual aerosol species. While sulfate is the largest contributor to haze18 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 tota l 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 D ays (top right) and Hazy Days (bottom right),

1993-2005

The right side of Figure 1.14 shows ATAD traj ectory-based incremental probability fields (areas most likely to have been upwind for a se lected condition at the receptor) calculated by the Combined Aerosol Trajectory Tool ( http://datafedwiki.w ustl.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 No rth Atlantic and/or Eastern Canada. On the haziest days (on wh ich Lye Brook sulfate has not improved), the air has previously resided well to the southwest of Vermont. Any reas onable 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 Ru le requires states to determine their contributions to visibility impairment at mandato ry 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 a pproaches are summarized in Table 2.1 below, and presented in detail in the Appendix I Re port “Contributions to Regional Haze in the Northeast and MidAtlantic United States,” August 2006, otherw ise 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 La grangian 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 meteorol ogy 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 observati on - based meteorology (m odeling conducted by20 VT DEC staff) are displayed in Figure 2.1. Sl ightly different proportio nate contributions to sulfate in Lye Brook and in other MANE-VU Cla ss 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 pe rcent and rank of the different

state contributions.

Figure 2.2 Normalized Percent Co ntributions to LYBR Su lfate using Alternative Assessment Techniques

The regional REMSAD modeling performed by MANE-VU used a pollutant tagging scheme to produce a comprehensive assessment of the i ndividual contributions from 28 nearby states to visibility impairment at Lye Brook and seve n other nearby Class I areas. The modeling also provided a partial accounting of the contributions from severa l states along the western and southern edges of the modeling domain (i.e., boundary conditions) wher e only a portion of the

states’ emissions were tracke d. Modeling was conducted for th e 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 contri butions of states with in the modeling domain were expected to decrease significantly by 2018 as a result of anticipated SO 2 emission reductions from implementation of existing stat e programs, the federal Clean Air Interstate Rule (CAIR), and additional state and federa l 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 cont ributions from outside the modeling domain will represent a larger share of th e total after the various emission control programs have reduced

contributions from within the domain.21 According to the completed MANE-VU CMAQ m odeling, sulfate concentrations at the Lye Brook Wilderness Area on the 20 percent worst visibility days will decline from 8.5 μg/m 3 in 2002 (representing the baseline pe riod of 2000-2004) to 5.5 μg/m 3 in 2018. Mirroring the results for sulfate, fine particulate matter (PM 2.5 ) concentrations from all sources are projected to fall by a similar percentage, from 14.6 μg/m 3 in 2002 to 11.2 μg/m 3 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 (Appe ndix 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 Days22 

### 2.1 States Contributing to Visibi lity Impairment at Lye Brook

Based on the combined results from the multiple assessment techniques employed in the MANE-VU Contribution Assessment, Vermont a nd other MANE-VU states concluded that it was appropriate to define an ar ea of influence including all of the states participating in MANE-VU plus other states that modeling indi cated contributed at least 2% of the annual average sulfate ion at M ANE-VU Class I areas in 2002.

Through participation in the MANE-VU regi onal haze planning process, Vermont has identified the following States as causing or contributing to visibility impairment in the following Class I areas Acadia National Par k, Brigantine Wildlife Refuge, Great Gulf Wilderness Area, Lye Brook Wilderness Area, Moosehorn Wildlife Refuge, Presidential Range-Dry River Wilderness Area, and Roos evelt-Campobello International Park.*

Table 2.2 States that Contribute to Visibility Im pairment 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 pe rcent contributions to 2002 annual average sulfate concentrations at Lye Brook Wilderness from states within the MANE-VU RPO as well as from other RPO regi ons, Canada and “Other” area s outside the REMSAD modeling

domain. Taken from MANE-VU’ s Contribution Assessment, the data provide clear evidence that the large majority of su lfate pollution at Lye Brook origin ates from sources outside the Vermont (>99%) and that nearly 70% of Lye Br ook 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 Stat e of Vermont have or may have impacts on the Lye Brook Wilderness Area, but do not have signi ficant 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 concentr ations 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* & Rooseve lt Campobello International Park* 0.09

Shenandoah National Park 0.01

* MANE-VU Class 1 Area25 

## 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 visibilit y 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 Improveme nt State and Tribal Association of the Southeast), MRPO (Midwe st Regional Planning Or ganization), CenRAP (Central Regional Air Planning Association), an d WRAP (Western Regi onal 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 Ma nagement Associati on (MARAMA), and the

Northeast States for Coordinated Air Use Mana gement (NESCAUM). The states, tribes, and federal agencies comprising MANE-VU are listed in Table 3.1. Individu als from the member states, tribes, and agencies, along with professional staff from OTC, MARAMA, and NESCAUM, make up the various committees an d workgroups. MANE-VU also established a Policy Advisory Group (PAG) to provide ad vice 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 issu es related to regional haze. The primary committees are the Technical Support Committee (TSC) and the Communications Committee.

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

decisions reside with and ar e 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 pr ocess to ensure that important regional-haze-related projects are co mpleted in a timely fashion, and members are kept informed of all MANE-VU tasks and du ties. In addition to the formal working committees, there are three standing workgr oups of the TSC assigned by topic area: the Emissions Inventory Wor kgroup, the Modeling Workgroup, and the Mon itoring/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 oversee s the production of MANE -VU’s newsletter and outreach tools, both for stakeholders and th e public, regarding regi onal issues affecting

MANE-VU’s members.



### 3.2 Regional Consultation and the MANE-VU “Ask”

On May 10, 2006, MANE-VU adopted the Inter-R PO 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 pr inciples 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 Prin ciples for Regional Haze Planning 1. All State, Tribal, RPO, and Federal partic ipants are committed to continuing dialogue and information sharing in order to create understandi ng of the respective concerns and needs of the parties

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

in the SIP submittal to EPA. 3. States alone have the authority to undertake sp ecific measures under their SIP. This inter-RPO framework is designed solely to facilitate need ed communication, coordi nation and cooperation among jurisdictions but does not establish binding oblig ation 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 the se policy decision areas, there may be a need for the RPOs, in coordination with their State and Trib al members, to have informal consultations on

these technical considerations. 5. During both the formal and informal inter-RPO c onsultations, it is anticipated that the States and Tribes will work collectively to facilitate the c onsultation 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 facilita te 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 Stat es 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 anticipat ed 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 th eir 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 comme nts 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 affect ed FLMs to protect the air resources of the

State/Tribe and Class I areas in accordan ce with the FLM coordination requirements specified in 40 CFR §51.308(i) a nd other consultation procedur es developed by consensus. 10. The consultation process is designed to sh are 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, in cluding States, Tribes and affected FLMs, w ill promptly respond to other RPOs’/States’/Tribes’ requests for comments.28 The following points offer a snapshot of se veral important ways in which MANE-VU member states and tribes have coope ratively addressed regional haze:

• Prioritization : MANE-VU developed a process to coordinate MARAMA, OTC, and NESCAUM staff in developing budget pr iorities, 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 discus sed pertinent issues.

• SIP Policy and Planning : MANE-VU states/tribe s collaborated on the development of a regional haze SIP templa te and the technical aspects of the SIP development process.

• Capacity Building : To educate its staff and members, MANE-VU included technical presentations on c onference calls and organized workshops with nationally recognized experts. Presentations on data an alysis, Best Available Retrofit Technology (BART) applicability, inventory topics, modeling, and c ontrol measures were effective

education and coordination tools.

• Routine Operations : MANE-VU staff at OTC, MARAMA, and NESCAUM

established a coordinated a pproach to budget tracking, proj ect deliverables and due dates, workgroup meetings, inter-RPO consultations, etc.

The consultations among MANE-VU states and other states/tribes an d provinces occurred through much of 2007. Documentation of consu ltation 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-V U, and a statement requesting a course of action by the U.S. EPA . Federal Land Managers also participated in the call. Upon appr oval, 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 ma nagement strategies. This requirement applies both when emissions from a state/tribe are reason ably anticipated to contribute to visibility impairment in Class I ar eas outside the state/tribe and when emissions from other states/tribes are reasonably anticipa ted 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 re gional haze. This coordinated

effort considered the individua l and aggregated impacts of stat es’/tribes’ emissions on Class I

areas within and outside the states/tribes. Th rough the MANE-VU process, more than twenty states and Canadian provinces have been identifi ed as contributing to visibility degradation in the Lye Brook Wilderness Area. On Februa ry 23, 2007, Vermont sent letters formally requesting consultation under the Regional Haze Rule to states and Canadian provinces – specifically, those shown via modeling to contribut e 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 representa tives 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 reque sted 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 he ld on August 6 in Chicago, this call provided an opportunity for M ANE-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 thei r understanding of the Ask and provided direction to modeling sta ff regarding interpretation of the Ask for purposes of estimating visi bility 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 MA NE-VU’s evaluations. Inde pendent of the other MANE-VU states with Class I areas, Vermont separately identified Wisconsin as having the potential to impact the Lye Brook Wilder ness Area based on CALPUFF regional modeling using the VTDEC modeling platform which pred icts 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 Northe ast and Mid-Atlantic United States”, August 2006 (Attachment A}. In addition, the Canadi an 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. requi rements. Table 3.4 provides a co mplete listing of states, provinces, and regional planning or ganizations invited to partic ipate 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, Ontari o, Canada, invited representatives of Vermont Department of Environmental Conservation (VTDEC), New Hampshire Department of Environmental Services (NHDES), Maine De partment of Environmental Protection (MEDEP), New York Department of E nvironmental Conservation (NYDEC), and NESCAUM to join the Shared Air Summit in Toronto on June 12, 2007, followed by an informal consultation meeting with represen tatives from Ontario on June 13, 2007. At these meetings, Ontario announced its plan to s hut down all coal electrical generation and challenged participating states to pursue sim ilar goals. Considerable discussion took place regarding trans-border air pollution trans port and its affect on human health.

Formal inter-regional consultation meetings took place on August 6, 2007, in Rosemont, Illinois, (for Midwestern stat es) and on August 20, 2007, in Atlant a, Georgia, (for Southern states). Consultation continues with the Midw estern states, seeking common approaches for reducing power plant emissions beyond the leve ls 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 Hampshire31 controls on industria l 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 measur es being considered w ould also result in visibility improvements.



### 3.2.2 The MANE-VU “Ask”

In addition to having a set of guiding principl es 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 res earch and analysis, on June 20, 2007, MANE-VU adopted the following pair of documents (ava ilable in Attachment D), which provide the

technical basis for consu ltation among the interested parties a nd define the basic strategies for controlling pollutants that cause vi sibility impairment at Class I areas in the eastern U.S.:

• “ Statement of the Mid-Atlant ic / Northeast Visibility Union (MANE-VU) Concerning a Course of Action within MANE-V U toward Assuring Reasonable Progress ,” and

• “ Statement of the Mid-Atlant ic / Northeast Visibility Union (MANE-VU) Concerning a Request for a Course of Action by Stat es 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 manageme nt 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 ha ve stated their intention to meet the terms of the Ask in their individual State Implementation Plans. Th e Ask for member states promises that each state will pursue the adoption and implemen tation 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 th ereof) 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 late r than 2012, of #6 residual oil to 0.3-0.5% sulfur by weight by no later th an 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 distilla te oil to 0.05% sulfur by weight (500 ppm) by no later than 2014, of #4 residual oil to 0.25-0.5% sulfur by32 weight by no later than 2018, and of #6 residua l oil to no greater th an 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 ge nerating 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 di stinct emission points. Consequently, this strategy is sometimes re ferred to as the 167-stack strategy.) The targeted EGU strategy calls for a ninety percent or greater reduction in sulfur dioxide (SO 2 )

emissions from all identified units. If it is infeasible to achieve that level of reduction from specific units, equivalent alternative meas ures 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

SO 2 and nitrogen oxide (NO X ) 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 fe llow 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 pursui ng 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 adop ted, 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 c onsulting states outside the MANE-VU region. This Ask requests the affected states to pursu e adoption and implementation of the following control strategies, as ap propriate 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 visibil ity impairment at mandatory Class I areas in the MANE-VU region, or an equivalent SO 2 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 SO 2 emissions beyond current on-the-books/on-the-way (OTB/O TW) 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 additi onal reductions in

SO 2 and NO X 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 co nflicts, and relative lack of perceived benefits within their jurisdictions. On the basis of consultations held, M ANE-VU members believe

that some non-MANE-VU states will choose not to pursue re ductions beyond CAIR controls and other measures pertaining to BART requirements.

There are some positive exceptions, however. Ma ny states of the MRPO are working with MANE-VU states to investigate the potential fo r widespread use of lo w-sulfur fuel oil and

installation of emission controls on ICI boilers within thei r 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 VIST AS claim that a substa ntial portion of the top 167 contributing EGU stacks will be controlled. However, instead of taking concrete actions

on uncontrolled or under-controlled f acilities, many of these states appear to be satisfied with meeting CAIR requirements and not look ing beyond CAIR for additional emission

reductions. Further discussion of these i ssues is provided in Part 3.2.4, below.



### 3.2.3 Technical Ramifications of Differing Approaches

MANE-VU states intended to develop a mode ling platform that was common in terms of meteorology and emissions with each of the ot her nearby RPOs. The RPOs worked hard to

form a common set of emissions with similar de velopmental assumptions. Even with the best of intentions, it became difficult to keep up wi th each RPO’s updates and corrections. Each rendition of emissions inventory improved its qu ality, 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 th e official filing date of December 17, 2007.34 The RPOs also took differing perspectives on wh ich version of the EGU dispatching model to use. At the beginning of the process, Interna tional’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 prev ious IPM analyses, MANE-VU opted also to remain with IPM v2.1.9. Therefore, for th e three eastern RPOs, differing emissions assumptions eventually worked their way into the final set of modeling assumptions.

MANE-VU’s most recent visibi lity 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 devel oped 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 H aze 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 consul t 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 descri ption of what actions were taken to resolve the disagreement. Most states willingly cons ulted with Vermont and took Vermont’s regional haze Ask under serious consideration. In fact, a ll 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 be nefits. In particul ar, reductions in SO 2 emissions, because they would yield lower ambient concentrations of fine particle (PM 2.5 ) pollution, would help all MANE-VU states in meeting th e NAAQS and would have direct benefits to public health and welfare.

Some states in the MRPO and VISTAS regions had interpreta tions of the requirements for BART and for establishing Reasonable Progres s Goals which differed from those in the

MANE-VU states. Some states claimed that CAIR alone set th e 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 CA IR, 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 reas onable progress goals without including the effects of a rigorous BART determination for th e non-EGU sector. It is apparent that the35 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 regi on 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-perce nt control on coal-fir ed boilers and 75-pe rcent 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 additi onal 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 M ANE-VU. VISTAS stated that they would further review BART-applicable controls.

→ Outcome : In MANE-VU’s modeling to dete rmine reasonable progress goals, MANE-VU made no adjustments to contro ls in the VISTAS region to reflect application of BART beyond the info rmation that VISTAS provided.

• Situation : The low-sulfur fuel oil strategy adopt ed by MANE-VU elicited concerns from MRPO and VISTAS as not being reasonable becau se of the limited availability of low-sulfur fuel oil and the historically lower usag e of this fuel within their regions.

→ Outcome : MANE-VU agreed to modify the Ask to reflect greater flexibility in providing for alternative measures that w ould produce a comparable rate of emission reductions. Accordingly, the Ask for non-M ANE-VU states was m odified to provide for an overall 28 percent reduction in SO 2 emissions wherever they were found to be reasonable. In MANE-VU’s modeling to determine reasonable progress goals, SO 2 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-E GU sources (see Section 10.0, Reasonable Progress Goals).36 • Situation : The targeted EGU strate gy was thought by some non-M ANE-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 re quest. 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 emi ssion reductions resulting from the Ask were distributed among facilities on the basis of recommendations received during inter- and intra-regional cons ultations. To maintain th e CAIR emissions budget as predicted by the modeling, excess emi ssion 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 visibi lity in the MANE-VU states. For the initial planning, MANEVU has allowed flexibility as to how othe r 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 on ly by means of binding obligations to EGU emission reductions bey ond 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 sensitivit y modeling (see Attachment F, “MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Control Measure Be nefits,” Feb. 7, 2008) and demonstrated to

be available at reasonable co st (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,” Revise d Final Draft, April 28, 2008).

MANE-VU’s position on this issue is formallyexpressed 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 statem ent, 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 plan ning. Vermont is pleased with the significant opportunities identified for ongoing consultation with other states concerning long-term strategies not only for regional haze mitigation bu t 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 participat ion 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 consu lt with the Federal Land Managers during the development of future progress reports an d plan revisions, as well as during the implementation of programs having the potential to contribute to visibili ty impairment in the mandatory Class I areas.

40 CFR 51.308(i) of the Regional Haze Rule requi res coordination between states/tribes and the Federal Land Managers (FLMs). Opport unities have been provided by MANE-VU for

FLMs to review and comment on the techni cal 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 prio r 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 Agenci es (FLMs), including th e Forest Service of the U.S. Department of Agriculture and the Na tional Park Service and U.S. Fish and Wildlife Service of the U.S. Department of the Inte rior (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 wa s identical to the 12/18/08 draft with the exception that it included minor revisions to re flect 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.v t.us/air/Planning/htm/ DraftRegionalHazeSIP.htm and was noticed in the newspapers of record in Vermont on Thursd ay January 15, 2009. The newspaper notices and the APCD website provided an opportunity for p ublic 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 Fe bruary 17, 2009, the public hearing was cancelled.

Vermont did receive written comments from th e 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 subseque ntly made a number of revisions which are incorporated into the current May 11, 2009 vers ion of this VT Regional Haze SIP. A listing of the specific FLM and EPA comments and Verm ont’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 procedur es for continuing consultati on between the states/tribes and FLMs on the implementation of the visibili ty protection program. Vermont will consult periodically with the FLMs as necessary on the status of the following implementation items. In particular, consultations will be conducte d 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 probabl e contributors to visi bility impairment, but not directly addressed in th e 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’ cons ideration or support is requested; and

6. Summary of topics discussed in ongoi ng communications (e.g., meetings, emails, etc.) between Vermont and the FLMs rega rding implementation of the visibility improvement program.39 

## 4. Assessment of Baseline and Na tural Visibility Conditions

Pursuant to 40 CFR 51.308(d)(2) of the Regiona l Haze Rule, states must determine baseline and natural visibility conditions for each Cla ss I area within their jurisdictions. This

information allows states to assess current leve ls of visibility degrad ation and provides a basis for setting reasonable progress goals toward rest oration of natural visi bility conditions in

Class I areas.

The effectiveness of any plan to reduce region al haze in Class I areas is dependent on the availability of reliable data. The Interagenc y Monitoring of Protected Visual Environments (IMPROVE) program was establishe d in 1985 to provide the da ta necessary to support the creation of Federal and State implementation plan s for the protection of visibility in Class I areas. IMPROVE has made it possibl e to assess current visibility conditions, track changes in visibility, and identify the chemical species and emission sources resp onsible for visibility impairment. In particular, IMPROVE data we re used to calculate baseline and natural

conditions for MANE-VU Class I Areas.

The IMPROVE monitors listed in Table 4.1 prov ide 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 pr ovided 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 Ar eas 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 fo r visibility impairment caused by sea salt at coastal sites. However, MANE-VU found that th ese refinements did not significantly improve the accuracy of the estimates, and MANE-VU states desired a consistent a pproach to visibility assessment. Therefore, default estimates we re used with the understanding that this methodology would be reconsidered upon demons trated improvements in the science.

Once the technical analysis of visibility c onditions was complete, MANE-VU provided an opportunity to comment to federal agencies an d 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 Mi dwest 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 appro ach in general; other comments were divided among four main topics: 1) the equation used to ca lculate visibility, 2) th e 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 wh en 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 an d a summary of stakeholders’ comments.

MANE-VU’s position on natural background conditi ons was presented in a report issued in June 2004 (see Attachment I, “Natural Backgrou nd Visibility Conditions: Considerations and Proposed Approach to the Calculation of Natural Background Visibility Conditions at MANE-VU Class I Areas,” June 10, 2004). The re port stated, “Refinemen ts to other aspects of the default method (e.g., refinements to the a ssumed distribution or tr eatment 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 aspe cts of the default method. The scientific basis for these revisions was well understood, and the Committee de termined that the revisions improved the performance of the equation at reproducing observe d visibility at Class I sites. This Revised IMPROVE extinction equation was presente d in Section 1.7 of this document.41 In 2006, MANE-VU conducted an assessment of th e default and alternative approaches for calculation of baseline and natural background c onditions 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 a nd Natural Background Visibility Conditions at MANE-VU Class I Areas,” December 2006.) MA NE-VU will continue to participate in further research efforts on this topic and w ill reconsider the calculation methodology as

scientific understa nding evolves.



### 4.2 MANE-VU Baseline Visibility

The IMPROVE program has calculated the 20 pe rcent best and 20 pe rcent worst baseline (2000-2004) and natural visibili ty 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 (V IEWS) 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 averag e baseline visibility values for the period 2000-2004, natu ral visibility levels, and th e 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 inte rest because they describe the magnitude of visibility impairment attribut able 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 Vi sibility and Natural Visibility Condit ions 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 6/22/200742 

### 4.3 Lye Brook Wilderness Baseline Visibility

As indicated in the table above, the 2001- 2004 baseline visibili ty 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 desc ribed 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 fou r-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 Natu ral 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 A rea – Natural Background

Natural background refers to the visibility co nditions that existed before human activities affected air quality in the region. Consistent wi th the stated visibility goals of the Clean Air Act, natural background is identified as the vi sibility target to be reached by 2064 in each

Class I area.

The Lye Brook Wilderness Area has an estima ted 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 we re calculated using th e above-referenced EPA guidelines and approved alternative method de scribed in NESCAUM’s Baseline and Natural Background document (Attachment J). This met hod of calculating natu ral background using the revised IMPROVE algorithm is also describe d 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/N aturalConditionsII_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 Qua lity and Radiation at Moab, Utah, April 200844 

## 5. Monitoring Strategy

In the mid-1980’s, the IMPROVE program (Inte ragency Monitoring of Protected Visual Environments) was established to measure visibi lity impairment in mandatory Class I areas throughout the United States. The monitoring s ites 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 Serv ice. In 1991, several additional organizations joined the effort: State and Territorial Air Pollution Program

Administrators and the Associat ion of Local Air Pollution Cont rol Officials (which now goes by The National Association of Clean Air Agenci es), Western States Air Resources Council, Mid-Atlantic Regional Air Mana gement Association, and Northe ast 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 sour ces responsible for ex isting anthropogenic visibility impairment,

• Document long-term trends for assessing progr ess towards the nationa l 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 Ly e 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 reasonabl e 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 Inform ation 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 ar e used in determining the contribution of

emissions from within the Stat e to regional haze visibility imp airment at mandatory Class I45 Federal areas both within and outside the Stat e. MANE-VU and the Stat e of Vermont accepts the contribution assessment analysis completed by NESCAUM entitled, Contributions to Regional Haze in the Northe ast and Mid-Atlantic States . See Attachment A and associated appendices. We agree that NESCAUM is provid ing quality technical information by using the IMPROVE program data and the VIEWS site. In formation 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, Na tural and Current Conditions of this SIP.

Section 51.308 of the Federal Regulation H aze Rule requires each state containing a mandatory Class I Federal area to include in its SIP a strategy fo r evaluating reasonably attributable visibility impair ment (RAVI) in any such Class I Area by visual observation or other appropriate monitoring techniques. The pl an must provide for the consideration of available visibility data and must provide a m echanism for its use. This requirement does not apply to the State of Vermont b ecause 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 H aze Rule requires the inclusion of other monitoring elements, including reporting, recor dkeeping, and other measures, necessary to assess and report visibility. While the st ate 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, whic h provides continuous, speciat ed information on rural

aerosol characteristics and vi sibility parameters; the EP A CASTNET program, which has provided complementary rural fine particle speciation data at no n-class I sites; the EPA Speciation Trends Network (STN), which provi des speciated, urban fine particle data to help develop a comprehensive picture of loca l and regional sources; st ate-operated rural and urban speciation sites using IMPROVE or STN methods; and the Supersites program, which has provided information through special studie s that generally expa nds our understanding of the processes that control fine particle form ation and transport in the region. Vermont will

continue to utilize these and other data -- as th ey 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 Wilder ness Area (indicated as LYBR1) is located on Mount Equinox at the windmills in Manchest er Vermont. (see Figures 5.1 through 5.3)

The monitor is not in the Wilderness Area but is located on a mountain ri dge across the valley

to the west of the wilderness. The Wilder ness Area is at high elevation in the Green46 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 Ar ea 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 reasona ble progress goals of the Lye Brook Wilderness Area and no additional monitoring sites or equi pment are necessary at this time. Vermont routinely participates in the IMPROVE m onitoring 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 m onitoring 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 pers onnel resources to support enhancements to existing IMPROVE visibility monitoring at Lye Brook, but would be interested in discussing future options, including possibilities for shar ing 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 m onitoring site, and on use of the aerosol monitoring data to calculate extinction ar e 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. Equinox48 

## 6. Emission Inventory

40 CFR 51.308(d)(4)(v) of EPA’s Regional H aze 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 polluta nts inventoried by Vermont include nitrogen oxides (NO X ), sulfur dioxides (SO 2 ), volatile orga nic compounds (VOCs), fine particles (particulate matter less than 2.5 micrometers in diameter, or PM 2.5 ), coarse particles (particulate matter less than 10 micrometers in diameter, or PM 10 ), and ammonia (NH 3 ). The following source categories were included in Verm ont’s emissions inventory: stationary point sources, stationary area sources, on-road m obile 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 Emi ssions 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 us ed for assessing progress in making emission reductions. In accordance with EPA’s guidanc e memorandum “2002 Base Year Emission Inventory SIP Planni ng: 8-hour Ozone, PM 2.5 , 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 baseli ne modeling inventory using

the inventories that Vermont and other states submitted to EPA to meet their SIP obligations and the requirements of the Consolidated Em issions 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 fi les 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 we re 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 redu ctions expected from the implementation of

control measures. While the 2009 and 2012 emissi ons projections were originally developed in support of other MANE-VU states’ ozone a ttainment demonstrations, the inventory for 2018 (the year targeted by the Regional Haze Ru le) was developed for the specific purposes of regional haze SIP planning. Therefore, a lthough 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 inve ntories are crucial to the analyses required for the regional haze SIP process. These emissi ons inventories were used to drive the air quality modeling simulations undertaken to as sess the visibility improvements that would49 result from possible control measures. Air quality modeling was also used to perform a pollution apportionment, which evaluates the c ontribution 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 th e Sparse Matrix Operator Kernel Emissions (SMOKE) emissions pre-processor for subse quent input into the CMAQ and REMSAD air quality models described in S ubsection 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 em issions inventory wa s the 2002 inventory submittals that were made to EPA by state and local agencies as part of the Consolidated Emissions Reporting Rule (CERR). With contr actor assistance (E.H. Pechan & Associates, Inc.,), MANE-VU then coordinated and quality-a ssured the 2002 inventory data, and prepared it for input into the SMOKE emissions m odel. The 2002 emissions from non-MANE-VU areas within the modeling domain were obtaine d from other Regional Planning Organizations for their corresponding areas. These Regional Pla nning Organizations incl uded the Visibility Improvement State and Tribal Association of the Southeast (VISTAS), the Midwest Regional Planning Organization (MRPO), and the Ce ntral 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 th e final inventory and SMOKE input files were completed during January 2005. Work on Version 2 (covering the period of April through September 2005) involved incorporati ng revisions requested by some MANE-VU state/local agencies on the point, area, and on-ro ad categories. Work on Version 3 (covering the period from December 2005 through April 2006) included additional revisions to the point, area, and on-road categorie s 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 Ve rsion 3, the non-road inventory was completely redone because of changes that EPA ma de to the NONROAD2005 non-road mobile

emissions model.

Version 3 of the MANE-VU 2002 baseline emissi ons inventory was used in the regional air quality modeling simulations. Further descript ion 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 Base line 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 provide d in MACTEC’s technical support document, “Development of Emissions Projections fo r 2009, 2012, and 2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU Regi on,” Final Report, February 28, 2007, also known as the Emission Projections Report (Attachment L). This document describes the data sources, methods, and modeling resu lts for three future years, five emission source sectors, two emission control scenarios, seven pollutants, and eleven st ates plus the District of Columbia. The following summarizes the basic fr amework of the future-year inventories that were developed:

• Projection years: 2009, 2012, and 2018;

• Emission source sectors: point-source electric genera ting units (EGUs), point-source nonelectric generating units (non-EGUs), area so urces, 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 pl ace as of June 15, 2005, as well as some emission control regulations that are not ye t 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 nece ssary to meet attainment a nd other regional air quality goals, mainly for ozone.

- An updated scenario (sometimes referred to as “b est-and-final”) to account for additional potentially reasonable control measures. For the MANE-VU region, these

include: SO 2 reductions at a set of 167 EGUs which were identified as contributing to visibility impairment at northeast Class I ar eas; implementation of a low-sulfur fuel strategy for non-EGU sources; and implemen tation of a Best Available Retrofit Technology (BART) strategy for BART-eligib le 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 (NO X ), sulfur dioxide (SO2), volatile organic compounds ( VOCs), fine particulate matter (PM 2.5 , sum of filterable and condensable components), and coarse particulate matter (PM 10 , sum of filterable and condensable components).

• States: Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, a nd Vermont, plus the Di strict 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 emissi ons estimates are simulated from “first principles.” This means that, with the excep tion of mobile and biogenic sources, SMOKE’s purpose is to provide an efficien t, 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 s upport 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 equi pment, 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 baselin e and future-year emissions estimates. All emissions data were prepared for modeli ng in accordance with EPA guidance.



### 6.3.1 Stationary Point Sources

Point source emissions are emissions from larg e individual sources. Ge nerally, 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 po int sources are inventoried annually. Sources with emissions greater than or equal to 100 tons per year (tpy) of a cr iteria 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 al so calculated individually but le ss 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 comp liance with the Acid Rain Program or 2002 state emissions inventory data. The CEM data provided actual hour ly emission va lues used in the modeling of SO 2 and NO

x emissions from these large sources. Emissions of other pollutants (e.g., VOCs, CO, NH 3 , and PM 2.5 ) 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 elec tric growth and state-specific NO

x and SO 2 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 reliab le basis upon which to predict EGU closures. Specific plant closures in the Vermont / M ANE-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 r ecent 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 shutdo wn predictions were unlikely to occur. In particular , many oil-fired EGUs in urban ar eas 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, th e IPM modeling output was adjusted before the most recent modeling to reflect staff knowledg e of specific plant status in MANE-VU, VISTAS, and MRPO states. Where expected E GU operating status was c ontrary to what was predicted by IPM modeling, the fu ture-year emissions inventory was adjusted to reflect the expected operation of those plants.

• Second, as a result of inter- and intra-RP O consultations, MANE-VU agreed to pursue certain emission control measures (see Sectio n 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 th at contributed the most to visibility impairment at any Class I area in the M ANE-VU region. This approach, known as the targeted EGU strategy, is further desc ribed 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 wa s data reported by state and local agencies for the CERR. As de scribed in Part 6.1.1, MANE-VU’s contractor, E.H. Pechan & Associates (Pechan), coordina ted the quality assurance of the inventory and prepared the necessary files for input into th e SMOKE emissions model. Further information53 on the preparation of the MANE-VU 2002 base line point source modeling emissions inventory can be found in Chapter II of the Baseline Emissions Report (Attachment K). Projected non-EGU point source emissions we re developed for the MANE-VU region by MACTEC Federal Programs, Inc. under contract to Mid-Atlantic Regional Air Management Association (MARAMA). The specific methodologi es that were employe d are described in Section 2 of the Emission Projections Report (Attachment L). MACTEC used state-supplied growth factor data, where available, to proj ect future-year emissions. Where state-supplied data were not available, MACTEC used EP A’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, thei r collective emissions ar e significant. Some examples include dry cleaners, service stations, and residential heating. For each area source, emissions are estimated by multiplying an a ppropriate emission factor by some known

indicator of collective activity, such as fuel usage, num ber 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 in ventory. 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 augm ented it with additional data, including MANE-VU-sponsored inventories for categorie s such as residential wood combustion and open burning. Details on the pr eparation of MANE-VU’s 2002 base line area source emissions inventory can be found in Chapter III of th e Baseline Emissions Report (Attachment K).

In similar fashion, MACTEC prepared future -year area source emission projections for the MANE-VU region. The specific methodologies empl oyed are described in Section 3 of the Emission Projections Report (Att achment 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 accoun ted for the appropriate control strategies in the future year projections.



### 6.3.3 Non-Road Mobile Sources

Non-road mobile sources are equipment that ca n move but do not use the roadways, such as construction equipment, aircraft, railroad locomo tives, and lawn & garden equipment. For the majority of non-road mobile sources, emi ssions are estimated us ing the EPA’s NONROAD model. Aircraft, railroad locomotives, and commercial marine vessels are not included in the NONROAD model; and their emissions are estim ated using applicable references and methodologies. Again, Pechan prepared the 200 2 baseline modeling inventory using the state and local CERR submittals as a starting point. Details on the preparation of the 2002 baseline54 non-road inventory are described in Chap ter 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 em ployed 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 EP A’s National Mobile I nventory Model (NMIM). Since the calendar year is an explicit input in to 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 include d in the NONROAD m odel (i.e. aircraft, locomotives, and commercial marine vessels) , MACTEC used the 200 2 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 th e 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 f actors for the required future

years.



### 6.3.4 On-Road Mobile Sources

The on-road emissions source catego ry consists of vehicles thatare meant to travel on public roadways, including cars, trucks, buses, and motorcycles. The basic methodology used for on-road mobile source calculations is to multip ly vehicle-miles-traveled (VMT) by emission factors developed using the EPA’s MOBILE6 mo tor vehicle emission factors model. The onroad mobile category requires that SMOKE m odel inputs be prepared instead of the

SMOKE/IDA emissions data format that is re quired by the other emi ssion source categories. Therefore, for the 2002 base line inventory, Pechan prep ared the necessary VMT and MOBILE6 inputs in SMOKE format.

Projected on-road mobile source inventorie s 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 th is 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 M obile Source Projection Inventories for SMOKE/MOBILE6 Application,” June 2006 (Attachment M).



### 6.3.5 Biogenic Emission Sources

For the purposes of the 2002 ba seline modeling emissions invent ory, biogenic emissions were calculated for the modeling domain by the New York State Department of Environmental Conservation (NYSDEC). NYSDE C used the Biogenic Emissions Inventory System (BEIS)

Version 3.12 as contained within the SMOK E emissions processing model. Biogenic55 emissions estimates were made for CO, nitrous oxide (NO) and VOCs. Further details about the biogenic emissions processing can be f ound in NYSDEC’s techni cal support document TSD-1c, “Emission Processing for the Revise d 2002 OTC Regional and Urban 12 km Base Case Simulations,” September 19, 2006 (Appe ndix 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 re ported in tons per year (tpy).

Table 6.1 2002 Emissions Inventory Summary Vermont (tpy)

Emission Sector VOC NO X PM 2.5 PM 10 NH 3 SO 2

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 NO X PM 2.5 PM 10 NH 3 SO 2

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 In ventory Summary for Vermont (tpy)

Emission Sector VOC NO X PM 2.5 PM 10 NH 3 SO 2

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 6,02056 It may be noted that there is virtually no chan ge 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 PM 2.5 (nor is

VT a CAIR state for ozone or PM 2.5 ). 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 NO X PM 2.5 PM 10 NH 3 SO 2

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 3,49357 

## 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 se veral future periods, including the primary target date, 2018, for th is 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 reasona ble progress goals and establish a long-term emissions management strategy for MANE-VU Class I Areas.

Several modeling tools were ut ilized for these analyses:

• The Fifth-Generation Pennsylvania St ate University/National Center for Atmospheric Research (NCAR) Mesoscale Model (MM5) was used to derive the required meteorological inputs fo r the air quality simulations.

• The Sparse Matrix Operator Kernel Emissions (SMOKE) emissions modeling system was used to process and format the emissions inventories fo r 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 a nd Deposition (REMSAD) was used during contribution apportionment.

• The California Puff Model (CALPUFF) and its associated meteorological wind field pre-processor (CALMET) was used to asse ss the contribution of individual states’

emissions to sulfate levels at se lected Class I receptor sites.

Each of these tools has been evaluated and f ound to perform adequately. The SIP-pertinent modeling underwent full performance testing, and the results were found to meet the specifications of EPA modeling guidance. M odeling using CALPUFF for the contribution assessment of sulfate impacts at selected Cl ass I receptor sites involved two different platforms for regional scale modeling which e ach 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 fiel ds. The two platforms were each evaluated separately as described in the NESCAUM re port, “Contributions to Regional Haze in the

Northeast and Mid-Atlantic United States”, August 2006 (Attachment A).

For more details on the regional haze mode ling, refer to the NESCAUM report, “MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Control Me asure Benefits,” February 7, 2008 (Attachment F). The detailed modeling approach for the most recent 2018 projections can be found in NESCAUM’s “2018 Visibility Projecti ons,” May 13, 2008 (Attachment O).58 

### 7.1 Meteorology

The meteorological inputs for th e air quality simulations were developed by the University of Maryland (UMD) using the MM5 meteorological modeling syst em. Meteorological inputs were generated for 2002 to corr espond with the baseline emi ssions 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 con tinental grid and a nested 12-km, 172 x 172 grid encompassing the eastern United States an d 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 Ea rth 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 meteorologi cal processing and the modeling domain can

be found in NYSDEC’s techni cal support document TSD-1a, “Meteorological Modeling Using Penn State/NCAR 5th Generation Me soscale Model (MM5),” February 1, 2006 (Attachment P), and in the NESCAUM report, “MANE-VU Modeling for Reasonable Progress Goals, Model Perf ormance Evaluation, Pollution Apportionment, and Control Measure Benefits,” November 27, 2007 (Attachment F



### 7.2 Data Preparation

Emissions data were prepared for input in to 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 pro cessed emissions outputs are shown in Fig. 7. 2.

Further details on the SMOKE processing conducte d in support of the air quality simulations is provided in NYSDEC’s tec hnical support document TSD-1c , “Emission Processing for the Revised 2002 OTC Regional and Urban 12 km Ba se Case Simulations,” September 19, 2006 (Attachment N), and in NESCAUM’s report , “MANE-VU Modeling fo r Reasonable Progress Goals, Model Performance Evaluation, Pollu tion 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 ai r quality models, CMAQ and REMSAD, were used for the air quality simulations that directly supported the regi onal haze SIP effort. CMAQ was developed by EPA and was used to perform the primar y SIP-related modeling. The CMAQ modeling simulations were also an important tool fo r the 8-hour ozone SIP process. REMSAD was developed by ICF Consulting/Systems Applicat ions 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 perfor mance analysis to evaluate CMAQ model predictions against obs ervations of ozone, PM 2.5 , and other pollutant species. This model performance evaluation is described in deta il in NYSDEC’s techni cal support document TSD¬1e, “CMAQ Model Performance and A ssessment, 8-Hr OTC Ozone Modeling,” February 23, 2006 (Attachment Q). A model performance evaluation for PM 2.5 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 Be nefits,” February 7, 2008 (Attachment F).60 Figure 7.2 Examples of Processed Model-Ready Emissions: (a) SO 2 from Point, (b) NO 2 from Area, (c)

NO 2 from On-Road, (d) NO 2 from Non-Road, (e) ISOP from Biogenic, and (f) SO 2 from all Source Categories61 

### 7.3.1 CMAQ

The CMAQ air quality simulations were pe rformed cooperatively among five modeling centers: NYSDEC, the New Jersey Department of Environmental Pr otection (NJDEP) in association with Rutgers University, the Virg inia 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 NYS DEC’s technical support document TSD-1d, “8hr Ozone Modeling Using the SMOKE/CMAQ Syst em,” 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 fo r 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 co ntribution 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 Be nefits,” February 7, 2008 (Attachment G), further describes the REMSAD model and its app lication 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 at mospheric pollutants. Two parallel CALPUFF modeling platforms were developed by the Vermont Department of Environmental Conservation (VTDEC) and the Maryland Depa rtment of the Environment (MDE). The VTDEC CALPUFF modeling platform utilized me teorological observation data from the National Weather Service (NWS) to drive th e 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. Th ese two platforms were run in parallel to

evaluate individual states’ contri butions to sulfate levels at No rtheast and Mid-At lantic Class I

areas.

The VTDEC CALPUFF modeling e ffort was tailored to accur ately 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 polluti on dispersion calculations. This modeling was performed in 2003 for calendar year 2002 meteor ology 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 ch anges to the CALPUFF modeling system that

were first made available in the 2003 beta mode l version have been larg ely 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 modele d, which may range from less than a kilometer, to long range transport applica tions 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 va rious observational, and/or pr ognostic 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 inte rpolation 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 NE SCAUM’s report, “Contributions to Regional Haze in the Northeast and Mid-Atla ntic United States,” August 2006 (Attachment A).



### 7.4 References for Section 7

Pennsylvania State University/N ational Center for Atmospheri c Research. Mesoscale Model (MM5). http://www.mmm.ucar.edu/mm5/mm5-home.html

.

Center for Environmental Modeling for Policy De velopment, 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 Ai r Quality (CMAQ) Modeling System.

http://www.cmaq-model.org

.

ICF International/Systems Applications Inte rnational. 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 Source s 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 SO 2 , NO X , VOCs, NH 3 , PM 10 , and PM 2.5 . The MANE-VU Contribution Assessment (Attachment A), fina lized in August 2006, re flects a conceptual model in which sulfate emerges as the most impo rtant single constituent of haze-forming fine particle pollution and the principle cause of visi bility 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. Organi c carbon was shown to be the s econd 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-Atla ntic Regions, MANE-VU concluded that an effective emissions management approach w ould rely heavily on broad-based regional SO 2 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, a nd light absorption can be measured by transmissometer, nephe lometer and aethalometer, respectively.

Figure 8.1 Contributions to PM 2.5 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 extinc tion 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 vari ous modeling techniques, air quality data analysis, and emissions inventor y analysis to identify source categories and states that contribute to visibility impairment in M ANE-VU and nearby Class I areas. Based on estimates obtained by several evaluation me thods, emissions that originated within MANE¬VU states contributed approximately one-f ourth of the total sulfate aerosol recorded at in the Lye Brook Wilderness Area in 2002. Mo re 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 per cent; Eastern Canada, 6-16 percent; and all other regions, 19 percent (see Tables 8.1 thro ugh 8.5 of the Contribu tion Assessment for details). These findings highli ght 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 asse ssment 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 cont ributions to annual su lfate impacts in ni ne Class I areas.

Table 8.1 Percent Contributions (Ma ss 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 12.4865 Figures 8.2 and 8.3, also borrowed from the Contri bution Assessment, illustrate several other simple methods for identifying and ranking individual states’ contributions to sulfate at

northeastern Class I ar eas using the 2002 emissions data and regional meteorology. Figure 8.2 shows results from a simple technique for dedu cing the relative impact of emissions from local and upwind source areas on specific recepto r 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 th e frequency effect of pr evailing winds. The use of this technique is explained in the Contribution Assessment (s ee 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 apportion ment 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 fi eld (UP) is then multiplied by the 2002 SO 2 emissions data to provide an es timate of proportionate state by state contributions to sulfate

contributions to the northern MANE-VU Class I Ar eas. The use of this technique is explained in the Contribution Assessment (see pa ges 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 upwin d contributions which are quite similar to results from the more sophisticated CALLPUFF and REMSAD m odels. See for example the comparative ranking results in Figure 8.4, also borrowe d from the Contribution Assessment.66 Figure 8.3 Ranked state percent sulfate contributio ns to Mid-Atlantic Class I receptors based on emissions times upwind probability (E x UP) results

Figure 8.4 Comparison of normalized (percent co ntribution) results usin g different techniques for ranking state contributions to sulfate levels at the MANE-VU Class I sites67 The ranking of emission contributions to visi bility impairment in the MANE-VU Class I Areas by methods such as these has direct re levance to the consulta tion process described previously in Section 3.0, Regional Planning and Consultation. Using results from the REMSAD model, MANE-VU applied the followi ng three criteria to identify states and regions for the purposes of c onsultation on regional haze:

1. Any state/region th at contributed 0.1 μ g/m3 sulfate or greater on the 20 percent worst visibility days in the base year (2002),

2. Any state/region that contri buted 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 contri butors 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 th ree listed criteria are id entified graphically for Lye Brook. Similar results are available fo r 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 Days68 Figure 8-5 has three components:

• On the left is a single bar graph of the IMPROVE-monitored PM 2.5 mass concentration ( μ g/m3) by constituent species fo r the baseline years 2000-2004. The yellow, bottom portion of the bar represents the measured sulfate concentration. • The middle component of each figure pr ovides 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 Dist rict of Columbia we re 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 participan ts in MANE-VU, those entities have agreed to pursue adoption of regional control measures ai med 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 pollu tants responsible for regional haze are SO 2 , NO X , VOCs, NH 3 , PM 10 , and PM 2.5 . The following is a desc ription of the sources (e.g., point, area, and mobile) and characteristics of pollutant em issions contributing to haze in the eastern United States. Emissions data and graphics presen ted for the purposes of this section are taken

from the MANE-VU 2002 Baseline Emissions I nventory, Version 2.0 (note that the more

recent MANE-VU 2002 Baseline Emissions Inve ntory, Version 3.0, released in April 2006, has superseded Version 2.0 for modeling pur poses). Although the emissions inventory database also includes carbon monoxide (CO), th is primary pollutant is not considered here because it does not contribute to regional haze.

In addition to the MANE-VU inventory, useful emissions inventorie s 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 Pla nning 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 pollu tants (HAPS). The database

includes estimates of a nnual emissions, by source, in each area of the country on an annua l 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 (faciliti es), as well as county-level estimates for area, mobile, a nd other sources, are available currently for 1985 through 1999 for criteria pollutants. NEI da ta help support air dispersion modeling, regional strategy development, setting regulations, air toxics risk assessment, and tracking trends in emissions over time. For inventories prio r to 1999, the National Emission Trends (NET) databa se 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 (SO 2 

### )

SO 2 is the primary precursor pollutant for sulf ate particles. Sulfate particles commonly account for more than 50 percent of particle-r elated 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,

SO 2 emissions are an obvious targ et of opportunity for reducing re gional haze in the eastern United States. Combustion of coal and, to a lesser extent, of certa in petroleum products accounts for most anthropogenic SO 2 emissions. In fact, in 1998, a single source category – coal-burning power plants – was responsible for two-thirds of total SO 2 emissions nationwide (NESCAUM, 2001a).

Figure 8.6 shows SO 2 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 Mary land) show declines in 2002 annual SO 2 emissions compared with 1996 emissions. While some stat es show an increase in emissions in 1999 followed by a decline in 2002, others show consis tent declines throughout the entire period.

Figure 8.6 Trends in Annual Sulfur Dioxide (SO 2 ) Emissions, by State

The upward trend in emissions after 1996 in se veral 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 rath er than implement new controls as electricity output expanded. The observed decline in SO 2 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 em ission limits to a greater number of power plants.70 Figure 8.7 2002 Sulfur Dioxide (SO 2 ) Emissions, by State Bar Graph = Percentage Fractions of Four Source Categories Line Graph = To tal Annual Emissions (106 tpy)

The bar graph in Figure 8.7 displays the percen tage contributions from different emission source categories to annual SO 2 emissions in the MANE-VU stat es in 2002. The chart shows that point sources – consisting mainly of stationary combustion sources for generating electricity, industrial power, and heat – dominate SO 2 emissions in the region. Smaller stationary combustion sources, referred to coll ectively 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 hea ting sources. By contra st, on-road and non-road mobile sources make a relatively minor contribution to overall SO 2 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, th ere is less concern w ith the volatile organic gases emitted directly to the atmosphere than with the secondary organic aerosols (SOAs) that VOCs form after undergoing condensation and oxid ation. Thus the VOC inventory category is of interest primarily because of the organic matter component of PM 2.5

.

Particle phase organic matter is present in the atmosphere as thousands of complex mixtures composed primarily of organic carbon, oxyge n and hydrogen. These organic compounds may71 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 include s a mix of pollutants originating from anthropogenic sources such as gasoline and diesel mo tor 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 reduc tions in organic carbon emissi ons may be driven by programs that address fine part icles and visibility.

Understanding the source regions and transpor t 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 characte ristics, and the fact that a gi ven 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 an d area sources. Onroad mobile sources of VOCs include evaporative emissions from transportation fuels and exhaust emissions from gasoline passenger vehi cles and diesel-powere d, heavy-duty vehicles. VOC emissions may also originate from a vari ety of area sources (including those that use organic solvents, architectural co atings, and dry cleani ng 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 containi ng 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 de velop emissions inventories that will be of greater value for visib ility planning purposes.72 Figure 8.8 2002 Volatile Organi c Carbon (VOC) Emissions, by Stat e Bar Graph = Percentage Fractions
of Four Source Categories Line Gra ph = Total Annual Emissions (106 tpy )



### 8.3.3 Oxides of Nitrogen (NO X 

### )

NO X emissions contribute to visibility impairment in the eastern U.S. by forming lightscattering nitrate particles. N itrate generally accounts for a subs tantially smaller fraction of fine particle mass and related lig ht extinction than su lfate and organic car bon at northeastern Class I areas. Notably, nitrate may play a more important role in urban settings and in the wintertime. In addition, NO X 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 NO X from all sources have show n 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 tran sportation sector, as power plant combustion sources have implemented emission reductions during the same time period. Figure 8.9 shows

NO X emissions in 1996, 1999, and 2002 for each stat e in the MANE-VU region. Most states experienced steadily declining NO X emissions between the two outer years. The exceptions were Massachusetts, Maryland, Ne w York, and Rhode Island, where NO X emissions

increased from 1996 to 1999 before declin ing to below-1996 levels in 2002.73 Figure 8.9 Trends in An nual Nitrogen Oxide (NO X ) Emissions, by State

Power plants and mobile sources gene rally dominate state and national NO X emissions inventories. Nationally, power plants account for more than one-quarter of all NO X emissions, amounting to over six million tons annually. The electric sector plays an even larger role in parts of the industrial Midwes t, where power plan ts contribute si gnificantly to NO X emissions. By contrast, m obile sources dominate the NO X inventories for more urbanized MANE-VU states, as shown in Figure 8.10.

Figure 8.10 2002 Nitrogen Oxide (NO X ) Emissions, by State Bar Graph = Percentage Fractions of Four Source Categories Line Graph = To tal Annual Emissions (106 tpy)74 In these states, on-road mobile sources (i.e ., highway vehicles) represent the largest NO X source category. Emissions from non-road (i.e ., off-highway) mobile sources, primarily diesel-powered engines, al so make up a substantial fraction of the inventory.

While there are fewer uncerta inties associated with NO X emissions than with other key hazerelated pollutants (especially primary fine par ticulate and ammonia emissions), further efforts could improve the quality of current NO X emission inventories in a number of areas (NESCAUM, 2001a). Specifically, better inform ation on the contribution of area and nonroad mobile sources may be of most intere st in the context of regional haze planning. Available emission estimation methodologies are w eaker for these types of sources than for the large stationary combustion sources. Moreover, because NO X emissions must mix with ammonia to participate in secondary ammonium nitrate particle formation, emissions that occur over large areas at the su rface may be more efficient in secondary fine particulate

formation than concentrated emissions fr om isolated tall st acks (Duyzer, 1994).



### 8.3.4 Primary Particulate Matter (PM 10 

### and PM 2.5 

### )

Directly emitted, or “primary,” particles (as distin ct from secondary particles that form in the atmosphere through chemical reactions i nvolving precursor pollutants such as SO 2 and NO X )

can also contribute to regional haze. For regulatory purpos es, a distinction is made between particulate matter (PM) with an aerodynamic diameter less than or equal to 10 micrometers (PM 10 ) and smaller particles with an aerodyna mic diameter less than or equal to 2.5 micrometers (PM 2.5 ).

Figures 8.11 and 8.12 show PM 10 and PM 2.5 emissions, respectively, for the MANE-VU states for the years 1996, 1999, and 2002. Note that the inventory values for PM 10 are drawn from

the 2002 NEI. Most states show a steady decline in annual PM 10 emissions over this time period. By contrast, emission trends for primary PM 2.5 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 PM 10 emissions from these types of sources by measuring the horizontal flux of particulat e mass at a fixed downwind sampling location within perhaps 10 meters of a road or field. Comparisons be tween estimated emission rates for fine particles using these types of measurem ent techniques and observed concentrations of

crustal matter in the ambient ai r at downwind receptor sites sugge st that physical or chemical processes remove a significant fr action 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 typica lly reduce estimates of total PM 2.5 emissions from all crustal sources by applying a factor of 0.15 to 0.25 to the total PM 2.5 emissions before including them in modeling analyses.75 Figure 8.11 Trends in Primary Coarse Particle (PM 10 ) Emissions, by State

Figure 8.12 Trends in Primary Fine Particle (PM 2.5 ) Emissions, by State76 From a regional haze perspective, crustal materi al generally does not play a major role. On the 20 percent best visibility days duri ng the baseline period (2000-2004), crustal PM accounted for six to eleven percent of partic le-related light extinction at MANE-VU Class I sites. On the 20 percent worst visibility days , however, crustal materi al generally plays a much smaller role than other haze-forming pollu tants, contributing only two to three percent of light extinction, Moreover, the crustal fractio n includes materials of na tural origin, such as soil or sea salt, that is not targeted under th e Regional Haze Rule. Of course, the crustal fraction can be influenced by construction, ag ricultural practices, and road maintenance (including wintertime salting). T hus, 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 Un ited States, where the crustal component has played a more significant role in overall particulate and regiona l haze levels, may be applicable to the extent

that it is relevant to the s ituation 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-sal t stemming from regulator y obligations related to their past non-attainment status with respect to the NAAQS for PM 10

. Current emissions inventories for the entire M ANE-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 wi ld fires as well as managed or prescribed burning ac tivities occur largely in other seasons. The latter category includes agricultural field-burning, prescribed bu rning of forested area s, and miscellaneous burning activities such as construction waste burning. Particulate emissions from many of these sources can be managed by limiting allowe d burning activities to times when favorable meteorological conditions can efficiently disperse the emissions.

Many sections of the relatively high elevat ion 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 contri butor to haze at Lye Brook than it is as a contributor to high winter PM 2.5 concentrations in more populated, lower elevation mountain valley locations. In a recepto r 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) sour ce 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 co ntribution 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 fire s rather than resident ial wood combustion.

Figure 8.13, taken from the MANE-VU Contribu tion 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 ar ea in eastern Ontario and western Quebec which has been periodically associated with lightening-induced forest fires.77 Figure 8.13 Upwind Incremental Probab ility 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 Ca nadian fires between 1994 and 1997, and the locations of the massive July, 2002 Quebec fires.

Figure 8.14 Incremental probabilit y for 1989-1995 U nderhill VT wood smoke co mpared with Canadian

forest fire locations78 While there are occasionally large Canadian w ild fire impacts at Lye Brook, these infrequent natural sources are not subject to regulatory co ntrols. 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 Fore stry Smoke Management in the MANE-VU Region,” September 1, 2006 (Attachment S), conc luded that fire from land management activities was not a major contributor to regi onal haze in MANE-VU Cl ass I Areas, and that the majority of emissions from fires were fr om 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 PM 2.5 concentrations and visibility impairment in the future.

Figures 8.15 and 8.16 show that area sources dominate primar y PM emissions. (The NEI inventory categorizes residential wood combus tion and some other combustion sources as area sources.) The relative contribution of point sources is larger in the primary PM 2.5 inventory than in the primary PM 10 inventory because the crustal component of particulate emissions (consisting mainly of larger, or coar se, particles) contribu tes more to overall PM 10 levels than to PM 2.5 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 a nd their gaseous precursors.

Figure 8.15 2002 Primary Coarse Particle (PM 10 ) Emissions, by State Bar Graph = Percentage Fractions of Four Source Categories Line Graph = Total Annual Emissions (10 6 tpy)79 Figure 8.16 2002 Primary Fine Particle (PM 2.5 ) Emissions, by State Bar Graph = Percentage Fractions of Four Source Categories Line Graph = Total Annual Emissions (10 6 tpy)



### 8.3.5 Ammonia Emissions (NH 3 

### )

Because ammonium sulfate ((NH 4 ) 2 SO 4 ) and ammonium nitrate (NH 4 NO 3 ) are significant contributors to atmospheric lig ht scattering and fine partic le mass, knowledge of ammonia emission sources is important to the develo pment of effective regional haze reduction strategies. According to 1998 estimates, livestock agriculture and fertilizer use accounted for approximately 86 percent of all US ammoni a 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 in clude ammonia in their emissions data collection efforts until fairly recently (see the Consolidated Em issions 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 emissi ons to the atmosphere) is an important constituent of airborne particulate matter, t ypically accounting for 10–20 percent of total fine particle mass. Reductions in ammonium ion con centrations can be instrumental to controlling regional haze because such reductions can yiel d proportionately greater reductions in fine particle mass. Ansari and Pa ndis (1998) showed that a one μ g/m 3 reduction in ammonium ion could result in up to a four μ g/m 3 reduction in fine particulat e matter. Decision makers,80 however, must weigh the benefits of ammonia reduc tion 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 Universi ty (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 emissi ons 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† a nd can make updates easily, allowing additional

ammonia sources to be added or emission fact ors to be replaced as better information becomes available (Strader et al., 2000; NESCAUM, 2001b).

Figures 8.17 and 8.18 show that estimated ammoni a emissions held fair ly 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 (NH 3 ) Emissions, by State

* SO 2 reacts in the atmosphere to form sulfuric acid (H 2 SO 4 ). Ammonia can partially or fully neutralize this strong acid to form ammonium bisulfate or ammonium sulfate. If planners focus future control strategies on ammonia and do not achieve corresponding SO 2 reductions, fine particles formed in the atmosphere will be substantially more acidic than those presently observed.

† 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 (NH 3 ) Emissions, by State Bar Graph = Percentage Fractions of Four Source Categories Line Graph = Total Annual Emissions (10 6 tpy)

Area and on-road mobile sources dominate the ammonia inventory data. Specifically, emissions from agricultural s ources and livestock pr oduction account for th e largest share of

estimated ammonia emissions in the MANE-VU re gion, except in the District of Columbia.

The two other sources contribu ting 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 precurs or concentrations,” Environ. Sci. Technol., 32, 2706-2714, 1998.

Davidson, C., Strader, R., Pandis, S., and R obinson, 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 Visibi lity Union and Midwest Region al 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 Vi sibility in the Northeast and Mid-Atlantic States,” January 2001a.

NESCAUM, “Development of an Improved Amm onia 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 a nd A.V. Polissar, Compar ative 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., De velopment 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 Emi ssion 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/tr ends/trends98/trends98.pdf, 2000b. EPA 2005, http://www.epa.gov/ttn/chief/eiinformation.html83 

## 9. Best Available Retrofit Technology (BART)

In the Regional Haze Rule, EPA included provisions designed specifically to reduce emissions of visibility-impairing pollutants from la rge sources that, because of their age, were exempted from new source performance sta ndards (NSPS) established under the Clean Air Act. These provisions, known as Best Avai lable 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 applie s to units installed a nd 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 represen ting 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 impair ment 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 el igible for BART controls. The rule also:

• Outlines methods to determine whether a sour ce is “reasonably anticipated to cause or contribute to haze,”

• Defines the methodology for conducting BART control analysis,

• Provides presumptive limits for electricit y generating units (EGUs) larger than 750 Megawatts, and

• Provides a justification for the use of the Cl ean Air Interstate Rule (CAIR) as meeting BART requirements for CAIR-affected electri cal generating units (EGUs). (Note: Vermont (along with many other states) has always held that CAIR requirements are not source-specific and theref ore should not, in the gene ral 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 co llective importance of BART sources to the management of regiona l haze, the MANE-VU Board decided, in June 2004, that a BART determination would be ma de by the member states for each BARTeligible source, without exception. Howeve r, as indicated in the MANE-VU Reports “Assessment of Control Technology Options fo r BART-Eligible Sources” (Attachment V), and “Five-Factor Analysis on BART-Eligib le Sources” (Attachment T), there are no BARTeligible sources in Vermont.

Many facilities in the MANE-VU region are rela tively small emission sources with potential emissions exceeding the BART applicability thre shold of 250 tons per year of haze-causing pollutants but whose actual emissions are well be low 250 tons in any year. Some of these84 facilities may have accepted an enforceable permit limitation restri cting their emissions to less than 250 tons per year. Any otherwise BART-eli gible 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 th ere 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 SO 2 or NO X if a BART-eligible source has the potential to emit less than 40 tons per year of these pollutants, or for PM 10 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 populat ion of BART-eligible EGUs within the MANE-VU domain was geographically divi ded 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 SO 2 and NO X );

• CAIR states (seasonal) : EGUs in states eligible to participate in the seasonal CAIR program only (Connecticut and Massachusetts, for summertime NO X ); and

• Non-CAIR states : EGUs in states not eligible to participate in the CAIR annual or seasonal programs (Maine, New Hamp shire, Rhode Isla nd, 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 NO X

.

The original purpose of BART wa s 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 be nefit. (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 natu ral 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 st ates in the setting of reasonable progress goal s. The rule states:

“In developing each reasonable progress goal, the St ate 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 progre ss, the State must describe in its submittal the actions taken to resolve the disagreement. In re viewing 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 contribu te 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, Vermon t agrees with the reasonable progress goals established by Maine, New Hampshire, and New Jersey. A description of the consulta tion 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 an d the emission reduction measures needed to achieve it for the period covered by the implemen tation 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 vi sibility improvement c ontinues at the rate proposed.



### 10.1 Calculation of Uniform Rate of Progress

As a benchmark to aid in developing reas onable progress goals , MANE-VU compared baseline visibility conditions to natural visi bility conditions at each MANE-VU Class I area.

The difference between baseline and natural visi bility 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 na tural visibility cond itions by 2064. Table 10.1 presents baseline visibility, natural visibility, and required uniform rate of progress for each86 MANE-VU Class I area. Visibility values ar e expressed in deciviews (dv), where each single-unit deciview decrease would represent a ba rely 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 conforma nce with an alternative method recommended by the IMPROVE Steering Committee.*

The reasonable progress goals established for M ANE-VU’s Class I Areas, described later in Subsection 10.3, are expected to provide visib ility 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 id entified specific emission control measures – beyond those which individual states or RPOs ha d already made commitments to implement – that would be reasonable to undertake as part of a concerted strate gy to mitigate regional haze. The proposed additional control measures we re 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 stra tegy are described in th e Vermont/MANE-VU “Ask” (see Part 3.2.2 in Section 3.0, Regional Planning and Consultation). St ates targeted for coordinated actions toward achieving these goal s include all of the MANE-VU states plus Georgia, Illinois, Indiana, Kentucky, Michigan, North Caro lina, Ohio, South Carolina, Tennessee, Virginia, West Vi rginia and Wisconsin.†

In addition to including proposed emission cont rols in the eastern Un ited States, MANE-VU

determined that it was reasonable to include an ticipated emission reductions in Canada in the modeling used to set reasonable progress goals. This determination wa s based on evaluations

* “Baseline and Natural Visibility Cond itions, Considerations and Proposed Appro ach to the Calculation of Baseline and

Natural Visibility Conditions at MANE- VU Class I Areas,” NESCAUM, December 2006.

† Independently from other MANE-VU m odeling and assessments, Vermont CALPU FF 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 acc ounts 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 na tural gas turbine units equipped with selective catalytic reduction (SCR) by 2018.

The process of identifying reasonable measures and setting reasonab le progress goals is

described in the subsections which follow. Further elaboration on the reasonable measures which make up the Vermont/MANE-VU long-term st rategy 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 SO 2 and NO X emissions. For a description of how proposed emission c ontrol measures were modeled to estimate resulting visibility improvements, see Subs ection 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 H aze Rule requires that, in establishing reasonable progress goals for each Class I ar ea, 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 th ese factors were taken into consideration in setting the RPGs. These factors are sometimes te rmed the “four statutory factors,” since their consideration is required by the Clean Air Act.

Focus on SO 2 : MANE-VU conducted a Contributi on Assessment (Attachment B) and developed a conceptual model that showed the do minant 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 SO 2 . While other pollutants, including organic carbon, will need to

be addressed in order to achieve the nationa l visibility goals, MANE-VU’s contribution assessment suggested that an early emphasis on SO 2 would yield the greatest near-term benefit. Therefore, it is reasonable to conclude that the additional measures considered in setting reasonable progress goa ls require reductions in SO 2 emissions.

Contributing Source s : 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 Mi dwest and Southeast regions were responsible for about 15 to 25 percent each. Point sources dominated the inventory of SO 2 emissions. Therefore, MANE-VU’s long-term strategy includes additional measures to control sources of

SO 2 both within the MANE-VU region and in other st ates 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 Ar eas. 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 num ber of potential control measur es. Several measures that

would reduce SO 2 emissions were identified for further study.88 These efforts led to producti on 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 Repor t (Attachment U). This report provides an analysis of the four statutory factors fo r five major source categories: electrical generating units (E GUs); industrial, commercial, and institutional (ICI) boilers; cement and lime kilns; heating oil combustion; and residentia l wood combustion. Table 10.2

summarizes the results of MANE-VU’s four-f actor analysis for the source categories

considered.

Table 10.2 Summary of Results from Four-F actor 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 SO 2 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 SO 2 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 SO 2 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 SO 2 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 vers us CAIR plus analysis conducted for MA RAMA/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 po ssible control measures, and concluded by adopting the statements known as the MANE-VU As k. These statements identify the control measures that would be purs ued toward improving visibility in the region. The following

discussions focus on the four basic control st rategies chosen by MANE-VU and included in the modeling to establish the reasonable progress goals:

1. Best Available Retrof it Technology (BART),

2. Low-sulfur fuel oil requirements,

3. Emission reductions from specific EGUs, and

4. Additional measures determ ined to be reasonable.



### 10.2.2 Best Available Retrofit Technology Controls

The MANE-VU states have identified appr oximately 100 BART-eligible sources in the region. Most of these facilities are already c ontrolling emissions in response to other federal or state air programs or are likely to inst all emission controls under new programs. (Previously, EPA had determined that CAIR fu lfilled the BART requirement for all EGUs in participating CAIR states.) A complete comp ilation 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,” Ma rch 2005, also known as the BART Report (Attachment V).

To assess the benefits of implementi ng 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 s ources were identified by a survey of states’ staff members, who furnished data on the poten tial control technologies and expected control levels for these sources under BART implementati on. The twelve sources are listed in Table 10.3 along with their 2002 baseline and 2018 es timated 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 M ANE-VU Class I Areas. MANE-VU prepared reports to provide

states with information about available c ontrol technologies (e.g., MANE-VU’s BART Report referenced above), estimated cost ranges, and ot her 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 Verm ont and elsewhere in MANE-VU will make determinations demonstrating the reasonableness of BART controls for so urces 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
SO 2 Emissions

(tons) 2018
SO 2 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-pollu tant 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 sect or. The sulfur conten t 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 excee d 2.0 percent. Combustion of distillate and

residual fuel in the MANE-VU states resulted in SO 2 emissions totaling approximately 380,000 tons in 2002.

As the second component of MANE-VU’s long-te rm strategy, the member states agreed to pursue measures that would require the sale and us e of fuel oils having re duced sulfur content. This strategy would be implemented in two phases:

* U.S. Department of Ener gy, EIA, Table F3a, at http://www.eia.doe.gov/emeu/state s/sep_fuel/html/fuel_use_df.html91 • Phase 1 would require reducing th e sulfur content in distilla te (#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 we ight. It would also restrict the sale of heav ier 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 per cent) by weight, respectively.

• Phase 2 would require further reducing the sulf ur content of the dist illate fraction from 500 ppm (0.05 percent) to 15 ppm (0.015 perc ent) 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 stat es. 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 co mmitment 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 emi ssions will occur as a direct consequence of the low-sulfur fuel strategy. For both phases combined, it is estimated that SO 2 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 combus tion of the heavier fuels. Together, these reductions represent a 35 percent decrease in the projected 2018 SO 2 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 reducti ons 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 SO 2 emissions by 2018 will yield co rresponding reductions in sulfate aerosol, the main culprit in fine-particle pollu tion and regional haze. The full benefit of MANE-VU-s low-sulfur fuel strategy is repr esented in Figure 10.1, which displays the estimated average reductions in 24-hr PM 2.5 concentration as calculated by the CMAQ model for the combined first and second phases of the program.

Low-Sulfur Fuel Oil Requ irements are Reasonable : The MANE-VU Contri bution Assessment documented source apportionment analyses that linked visibility impairment in MANE-VU

Class I Areas with SO 2 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 hom e 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 Averag e Change in 24-hr PM 2.5 Due to Low-Sulfur Fuel Strategy (Phases I and 2 Combined) Relative to OTB/OTW (values in μ g/m 3 )

Four-Factor Analysis – Low-Sulfur Fuel Oil Strategy : The MANE-VU Reasonable Progress Report discussed the four factors as they apply to low-su lfur fuel use for ICI boilers and residential heating systems. MANE -VU’s Reasonable Progress Report identified switching to a lower-sulfur fu el oil as an available SO 2 control option that would achieve 50 to 90 percent reductions in SO 2 emissions from ICI Boilers. The report also noted that home heating oil use generates an estimated 100,000 tons of SO 2 emissions in the Northeast each year and that SO 2 emissions would decline in proportion to reductions in fuel sulfur content. The following discussion summarizes informa tion 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 beca use of requirements for motor ve hicle fuels, refineries have already performed the capital investments requi red for the production of low-sulfur diesel (LSD) and ultra-low sulfur di esel (ULSD). The report estimated a cost per ton of SO 2 removed by switching to lower-sulfur fuel w ould range from $554 to $734 per ton (converted from 2001 to 2006 dollars using a conversion fact or of 1.1383). In some seasons and some locations, low-sulfur diesel is act ually 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 redu ced. 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 Yo rk 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 emi ssions reductions with the low-sulfur fuel strategy are somewhat uncertain, they are believ ed to be reasonable in comparison with the costs of controlling other sectors. Some MANE -VU states are proceedin g with low-sulfur oil requirements much sooner than 2018; however, a ll of the MANE-VU states concur that a lowsulfur oil strategy is both r easonable 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 dete rmined 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, a nd 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 Overvi ew of Benefits, Costs, and Implementation Issues,” December 2005 (Attachment W) obser ves that the federal rules for heavy duty highway diesel fuel are flexible , so that if there is a shorta ge of 15 ppm fuel, the 15 to 500 ppm fuel could be used to reliev e the shortage. With this flex ibility, the report concludes that the likelihood of a fuel shortage in the short term due to use of UL SD 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-sulf ur product. Blending domestically produced biodiesel into heating oil offers opportunity to reduce imports, stabili ze supplies and minimize supply-related price spikes.

Potential supply disruptions and price spikes fo r residual fuels are a particular concern for several northern MANE-VU states. Maine, Ne w Hampshire, and Mass achusetts receive a significant percentage of their residual fuel supplies from o ffshore 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 ha ve expressed concerns that th e 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-tem perature, reduced viscosity) residual fuel oil with a 0.5 percent sulfur content sold for $80.83 per barrel. Residual oil wi th 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 re sidual 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 waiv ers. 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-re lated disruptions, but at a cost of increased recordkeeping and compliance monitoring. Si nce many states alr eady 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 othe r MANE-VU states propos es to phase in the required use of lower-sulfur fuels over the ne xt 10 years, providing adequate time for full implementation.

3) Low-Sulfur Fuel Oil Strategy – Energy an d Non-Air Quality Environmental Impacts of Compliance : According to MANE-VU’s Reasonable Progress Report, re ducing the sulfur content of fuel oil would have a variety of be neficial 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 heat ing units and allowing longer time intervals between cleanings. The MANE-VU report c ites 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 1,4 00 ppm to 500 ppm.

The use of low-sulfur oil could extend the usef ul life of a source by reducing the maintenance required because low-sulfur oil is less damagi ng to the combustion equipment. The report also notes that decreasing sulfur levels in fu el would enable manufact urers 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, SO 2 controls would have beneficial en vironmental impacts by reducing acid deposition and helping to decreas e ambient concentrations of PM 2.5 . Reductions in PM 2.5 resulting from use of low-sulfur fuels coul d help nonattainment area s meet health-based National Ambient Air Quality Standards.

4) Low-Sulfur Fuel Oil Strate gy – Remaining Useful Life of Any Potentially Affected

Sources : Residential furnaces and boile rs 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 year s. As noted above, use of low-sulfur fuel is less damaging to equi pment 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 co uld generate if it ran full time at full capacity.) The typical life expectancy of an ICI boiler ra nges from 10 years to more than 30 years. As in the case of residential units, use of lower-sulfur fuels c ould extend the life span of an ICI boiler.



### 10.2.4 Targeted EGU Strategy for SO 2 

### Reduction

Electrical generating units (EGUs) are the single largest sector contributing to visibility impairment at MANE-VU’s Class I Areas. SO 2 emissions from power plants continue to

dominate the emissions invent ory. Sulfate formed through atmospheric processes from SO 2 emissions are responsible for over half the mass and approximately 70-80 percent of visibility extinction on the days of worst visibili ty (see NESCAUM’s Cont ribution Assessment, Attachment B).

To ensure that EGU control measures are target ed at those units havi ng 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 th e 100 EGU emission points (stacks) having the largest impacts at each MANE- VU Class I Area during 2002. Th e combined list for all seven

MANE-VU Class I Areas identified a total of 167 distinct emi ssion points. These 167 stacks are spread across the Northeast, S outheast, and Midwest (Figure 10.2).

After consultations with its member states and with other RPOs, MANE-VU requested a 90- percent reduction in SO 2 emissions from the top 167 stacks by no later than 2018 (see the MANE-VU “Ask”). NESCAUM’s preliminar y modeling for MANE-VU showed that SO 2 emission reductions of this magnitude from the targeted facilities w ould produce substantial improvements in ambient 24-hour PM 2.5 concentrations. Assuming a control level equal to 10 percent of the 2002 baseline emissions (i.e., 90-percent emission reduc tion), NESCAUM used CMAQ to model sulfate concentr ations in 2018 after implementation of controls. The modeled

sulfate values were then co nverted to estimates of PM 2.5 concentration. Figu re 10.3 disp lays the predicted average change in 24-hr PM 2.5

.

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 SO 2 . Improvements in PM 2.5 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 Contribu ting 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 adva ntageous and potentia lly large, MANE-VU determined, after further consultation with affected states, that it was unreasonable to expect that the full 90-percent reduction in SO 2 emissions would be ach ieved by 2018. Therefore, additional modeling was conducted to assess the mo re realistic scenario in which emissions would be controlled by the individu al facilities and/or states to le vels already projected to take place by that date. At some facilities, the act ual emission reductions are anticipated to be greater or less than the 90 pe rcent benchmark. For details, see Alpine Geophysics’ report for MARAMA entitled, “Documentati on of 2018 Emissions from Electric Generating Units in

the Eastern United States for MANE-VU’s Re gional Haze Modeling, Revised Final Draft,” April 28, 2008 (Attachment G).97 Figure 10.3 Preliminary Estimate of Average Change in 24-hr PM 2.5 Resulting from a 90-Percent

Reduction in SO 2 Emissions from the Top 167 EGU Stacks Affecting MANE-VU Class I Areas

Targeted EGU SO 2 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 modeli ng 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, an d Section 11.0, Long-Term Strategy section of

this SIP.

Based on information gathered from the stat es 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 (o r its replacement) in 2018.

Four-Factor Analysis – Targeted EGU SO 2 Reduction Strategy : The following discussion

addresses each of the four factor s with respect to the strategy of controlling specific EGUs. Information is taken primarily from the M ANE-VU Reasonable Progress Report (Attachment U) and MANE-VU BART Report (Attachment V).98 1) Targeted EGU SO 2 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 SO 2 , NO X , 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 di fferent types of coal. Over the last few years, the cost data clearly indicate that many technologies provid e substantial and costeffective emission reductions.

Both wet and dry scrubbers are in wide co mmercial use in the U.S. for controlling SO 2 emissions from coal-fired power plants. The capital costs for new or retrofit wet or dry scrubbers are higher than the capital costs for NO X and PM controls. Capital costs for scrubbers ranged from $180/kW fo r large units (greater than 600 MW) to as high as $350/kW for small units (200 to 300 MW). (See pa ges 2-22 through 2-25 of the BART Report, Attachment V). However, the last few years ha ve seen a general trend of declining capital costs attributable to vendor competition an d 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 SO 2 removed by the control devices. The typical cost is in the range of 200 to 500 dollars per ton of SO 2 removed, although the cost rises steeply for small units burning lower-sulfur coal and operating at low capacity factors. For any plan t, overall cost-effectiveness depe nds mainly on the baseline precontrolled SO 2 emission rate (or fuel sulfur content), size and capacity factor of the unit, and capital costs of flue gas desulfurizat ion (generally ranging from $150 to $200/kW).

The MANE-VU Reasonable Progress Report reviewed options for controlling coal-fired EGU boilers, including switching to lo wer-sulfur coal, switching to na tural gas, coal cleaning, and flue gas desulfurization (FGD). The most ef fective control option (but not necessarily appropriate for all installations) is FGD, wh ich can achieve up to 95 percent reduction in SO 2 emissions. The costs of different technologi es 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 SO 2 emissions, expressed in dollars per ton of SO 2 removed.

To predict future emissions and further evalua te 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 usi ng 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 sa me time developing least-cost solutions to electrical generating needs within specified emi ssions targets. IPM also provides estimates of the costs of complying with various policy requirements.99 Table 10.4 Estimate d Cost Ranges for SO 2 Control Options for Coal-Fired EGU Boilers (2006 dollars per

ton of SO 2 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 th at CAMR was vacated by the federal courts and is no longer in effect.) Recently, EPA upda ted their input data and developed IPM v.3.0. However, because of time constraints, a ll 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 fu el prices. The resul ting IPM run is called VISTAS PC_1f. This IPM run se rves 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 Mode l (IPM®),” Final Draft Report, May 30, 2007 (Attachment X). The first run, known as the MA RAMA CAIR Base Case run (also known as MARAMA_5c), was based on the VISTAS PC_1 f run and underlying EPA IPM v.2.1.9 with some updated information on fuel prices, control constraints, etc. Th e second run, called the MARAMA CAIR Plus run (also known as MA RAMA_4c), was similarly based on VISTAS100 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 NO X emission caps and higher SO 2 retirement ratios.

Based on the modeling results, MANE-VU estimates that the marginal cost of SO 2 emission reductions (the cost of reducing one additional ton of emissions) ranges from $640/ton in 2008 to $1,392/ton in 2018 (see Ta ble 6, “Allowance Prices (Mar ginal Costs) of Emissions Reductions...,” in Attachment X).

Costs will vary for individual plants to redu ce emissions by 90 percent, as recommended in the Vermont/MANE-VU Ask. However, this st rategy provides states with flexibility to pursue controls on specific sources as appropri ate and to control emissions from alternative sources, if necessary, to meet the 90 pe rcent target established in the Ask.

Given the importance of SO 2 emissions from specific EGUs to visibility impairment in MANE-VU Class I Areas, the MANE-VU Commissi oners, after weighing all factors – the availability of technology to reduce emissions, the estimated co sts of controls, the costs of alternative measures, the flexib ility 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 SO 2 Reduction Strategy – Time Necessary for Compliance : MANE-VU’s Reasonable Progress Report indicates that, generall y, sources are given a 2- to 4-year phase-in period to comply with new rules. Under Phase I of the NO X 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 NO X 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 SO 2 Reduction Strategy – Energy an d Non-Air Quality Environmental Impacts of Compliance : The MANE-VU Reasonable Progress Report identified several energy and non-air quality impacts from additiona l EGU controls. Large-scale fuel switching could potentially impact fuel supplies. Flue gas desulfurization systems may generate wastewater and sludge (which is sometimes r ecycled as a useful byproduct). On the other hand, SO 2 , NO X , and ammonia controls would have beneficial environmental impacts by reducing acid deposition and n itrogen deposition to water bodies and natural land areas. Emission reductions for these pollutants would al so produce decreases in ambient levels of

PM 2.5 and result in corresponding health benefits . Similarly, mercury emissions may be reduced by the addition of contro ls for other pollutants. Verm ont concludes that the energy and non-air quality impacts of additi onal EGU controls are reasonable.

4) Targeted EGU SO 2 Reduction Strategy – Remaining Useful Life of Any Potentially Affected Sources : As noted in the MANE-VU Reasonabl e 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 regulatio ns over the years has101 necessitated emission control retrofits that ha ve increased the expected life spans of many EGUs. The lifetime of an EGU may be exte nded through repair, re -powering, or other strategies if the un it is more economical to r un 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 SO 2 

### 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 neighborin g regional planning organi zations 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 SO 2 emissions by 2018. After consu ltation with other states and consideration of comments received, MANE-VU decided to include, in the latest modeling for the VISTAS and MRPO regions, implementati on of control measures capable of achieving

SO 2 emission reductions equivalent to M ANE-VU’s 28-percent reduction in non-EGU SO 2 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 wh ere the requested emission reductions would

occur in the VISTAS and MRPO states wi thout knowing precisely how those reductions would be realized. As a way to represent approximately a 28-percen t reduction in non-EGU

SO 2 emissions, the following reductions were modeled:

• For control measures in VISTAS and MRPO states:

− Coal-fired ICI boilers: SO 2 emissions were reduced by 60 percent.

− Oil-fired ICI boilers: SO 2 emissions were reduced by 75 percent.

− ICI boilers lacking fuel specification: SO 2 emissions were reduced by 50 percent.

• For additional controls only in the VISTAS states: SO 2 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 SO 2 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-pe rcent reduction in non-EGU SO 2 emissions in their State Implementation Plans at the present time. Verm ont 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 adju st its reasonable progress goals and long-102term strategy at a later date to be consistent with programs implemented by the non-MANEVU states. Any such adjustments would be inco rporated into Vermont’s first regional haze

SIP revision in 2012.

Non-EGU SO 2 Emission Reduction Measures Outside MANE-VU are Reasonable : After EGUs, ICI boilers are the next largest class of SO 2 emitters. ICI boilers are thus a logical choice among non-EGU sources for c onsideration of additional SO 2 control measures.

ICI Boiler Control Options : Air pollution reduction and cont rol technologies for ICI boilers have advanced substantially over the past 25 years. However, according to a 1998 survey of industrial boilers by EPA (2004), on ly 2 percent of gas-fired boile rs and 3 percent of oil-fired

boilers had installed an y kind of air pollution c ontrol device. A largerpercentage 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 SO 2 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 ac id scrubbers). A small percentage of industrial boilers had combusti on controls in place in 1998, although additional

low-NO X firing systems may have been installed since that date.

Almost all SO 2 emission control technologies fall into the category of reducing SO 2 after its formation as opposed to minimizing its form ation during combustion. The method of SO 2 control appropriate for any indi vidual 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 emissi on reduction technologies for SO 2 are available and are effective in reducing emissions from the exhaust gas stream of ICI boilers. Post-combustion

SO 2 control is accomplished by reacting the SO 2 in the gas with a reagent (usually calcium- or sodium-based) and removing th e resulting product (a sulfat e/sulfite) for disposal or commercial use, depending on the particular technology. SO 2 reduction technologies are commonly referred to as flue gas desulfurizati on (FGD) and are usually described in terms of the process conditions (wet versus dry), bypro duct utilization (throwaway versus saleable) and reagent utilization (once- through versus regenerable).

The exceptions to the nearly universal use of post-combusti on 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 SO 2 emission control alternatives

for ICI boilers are outlined in Table 10.5. Furt her description of thes e technology options is available in Chapter 4 of the MANE-VU Reasonable Progress Report (Attachment U).

The SO 2 removal efficiency of these controls vari es from 20 to 99+ percent depending on the fuel type and control technol ogy. For coal-fired boilers, op tions include switching to lowsulfur coal, coal cleaning, wet FGD, dry FGD, and spray dryers. The overall SO 2 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 choosi ng 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- pe rcent reduction in SO 2 emissions. This assumption is validated by data showing that wet FGD systems represent 85 percent of103 the FGD systems in use in the United States and that these systems have an average SO 2 removal efficiency of 78 percent. MANE- VU’s modeling of a 60-pe rcent reduction in SO 2 emission from coal-fired ICI boi lers is therefore reasonable.

Table 10.5 Available SO 2 Control Options for ICI Boilers

For oil-fired boilers, options incl ude switching to a lowe r-sulfur fuel (e.g., oil or natural gas), dry FGD, and spray dryers. The overall SO 2 reductions vary from a low of 40 to 60 percent for dry FGD to a high of 60 to 95 percent fo r spray dry FGD. For comparison, the MANEVU low-sulfur fuel strategy assumes a 50- to 90- percen t reduction in SO 2 emissions from oilfired ICI boilers. Assuming a no rmal distribution of control stra tegies chosen by the sources, MANE-VU’s modeling of an aver age 75-percent reduction in SO 2 emission from oil-fired ICI

boilers is reasonable.

For ICI boilers in which a fuel was not specified, a 50-percent reduction in SO 2 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 en compasses 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 SO 2 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 SO 2 emissions Flue Gas Desulfurization (FGD) - Wet SO 2 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 SO 2 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 SO 2 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 SO 2 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 SO 2 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 SO 2 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 SO 2 emissions by switching to a

lower-sulfur coal104 the implementation of MANE-VU’s non-EGU As k. Given the paucity of data, a lower

reduction in SO 2 emissions (50 percent) was assumed fo r this category than for coal- or oilfired ICI boilers. Implementation of one or more of the suggested SO 2 control options to achieve, on average, a 50-percent reduction in SO 2 emissions at these sources is a reasonable assumption.

For emissions from other area oil-combustio n sources in the VISTAS region, an SO 2 reduction of 75 percent was assumed. This redu ction is equal to the reduction that would result from implementing the MANE-VU low-sulfurfuel strategy for this sector. The fourfactor analysis for the low-sulfur fuel strate gy was described in Part 10.2.3 of this section.

Four-Factor Analysis – Non-EGU SO 2 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 SO 2 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 re trofit technologies that are available for ICI boilers today.

1) Non-EGU SO 2 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 esti mates 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-effectiven ess increases as boiler size and capacity factor (a measure of boiler utilization) increases.

MANE-VU’s Reasonable Progress Report (Attach ment U) provides emission control cost

estimates for ICI boilers in the range of $130 to $11,000 per ton of SO 2 removed, a very wide spread due to the variability of sources and contro l options in this category. All costs presented below for emission controls on ICI bo ilers are borrowed from this report. Dollar amounts originated from EPA publications cited in the report and are re stated in 2006 dollars using appropriate adjustment fact ors found at www.inflationdata.com

.

◊ Cost of Fuel Switching : Although fuel switching can be a very effective means of controlling SO 2 emissions (reductions of 50 to 99.9 pe rcent are possible), burning low-sulfur fuel may not be technically feasible or economically practical as an SO 2 control option for every coal-fired boiler. Factor s 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-fi red boilers switching to a lower-s ulfur 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 substi tution 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 va lue), and the cost of necessary boiler or coal-105 handling equipment modifications. Many plants w ill be able to switch from high-sulfur to

low-sulfur bituminous coal without serious di fficulty, but switching fr om bituminous to subbituminous coal may require potentially signifi cant 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 transpor ted long distances from the supplier. It also may be more cost-effective to burn a higher-sulfur fuel supp lied by nearby suppliers and to use a post-combustion control device.

Switching from coal combustion to natura l gas combustion virtually eliminates SO 2 emissions. It is technically feasible to switch from coal to natural gas, but it is currently uneconomical to consider this option for larg e 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 developi ng countries, reports that the co st of physically cleaning coal varies from $1 to $10 per ton of coal cleane d, 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 t on of coal cleaned. Coal cleaning typically results in a 20- to 25- percent reduction in SO 2 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 syst ems 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 SO 2 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 SO 2 removed)

Fuel SO 2 Reduction (%) Capacity

Factor

(%) 100 MMBtu/hr 250

MMBTU/hr 1,000

MMBTU/hr

14 4,686 3,793 2,979

50 1,312 1,062 834 2%-Sulfur Coal 40

83 772 624 490

14 2,732 2,212 1,737

50 765 619 486 3.43%-Sulfur Coal 40

83 450 364 286

14 2,205 1,786 1,402

50 617 500 392 2%-Sulfur Coal 85

83 363 294 231

14 1,286 1,040 818

50 360 291 229 3.43%-Sulfur Coal 40

83 212 171 134106 Cost of FGD : Installation of post-combustion SO 2 controls in the form of FGD has several impacts on facility operations, maintenance, and waste handling procedures. FGD systems generally require substa ntial land area for construction of th e 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 a ddition, 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 produc es commercial-grade gypsum, which may be

sold as a raw material for other commercial processes.

Table 10.7 presents the total estimate d cost-per-ton of adding FGD-based SO 2 emission controls to ICI boilers for different boiler sizes, fuel types, and capacity factors. There is no indication that these cost data include possi ble 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. CO 2 emissions will become more of an issue in the future if they are limited under climate change mi tigation 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 SO 2 emissions allows states flexibility in determining which sources to control, so that the most cost-effective control measures can be adopted and implemented over th e next 10 years. Gi ven the wide range of control options and costs ava ilable for this purpose, MANE-VU has concluded that the request for a 28-percen t reduction in non-EGU SO 2 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 SO 2 removed) Fuel Technology SO 2 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

50 1,290 899 567 Coal 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

50 2,269 1,765 1,184 Oil FGD (wet) 40

83 1,371 1,079 740107 2) Non-EGU SO 2 Emission Reduction Measures outs ide MANE-VU – Time Necessary for Compliance : For pre- and post-combustion SO 2 emission controls, engineering and construction lead times will vary between 2 and 5 years, depending on the size of the facility and specific contro l 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 sw itching or cleaning), an d a 3-year period is adequate for the installation of post-com bustion controls. MANE-VU has therefore

concluded that there is sufficient time betw een 2008 and 2018 for affected states to adopt emission control requirements and for affected s ources to install the necessary controls to meet MANE-VU’s requested SO 2 emission reductions from non-EGU sources. Vermont

concurs with this conclusion.

3) Non-EGU SO 2 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 its elf, but require additional energy to clean or bl end coal. FGD systems typically operate with high-pressure drops across the control equipment and theref ore consume significant amounts of electricity to operate blowers and circulation pumps. In addition, some combinations of FGD technology and plant configuration may require fl ue 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 SO 2 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 co st, energy requirements, and effluent water quality. Processing of the wastewater sludge can require energy for stabilization and/or dewatering, and transporting the dewatered sludg e to a landfill has additional environmental implications.

Fuel switching to a low-sulfur distillate fuel oi l has a variety of beneficial consequences for

ICI boilers. Low-sulfur distilla te fuel is cleaner burning and emits less particulate matter,

which reduces the rate of f ouling 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 reducti ons in buildup of depos its result in longer service intervals between cleanings.

Reducing SO 2 emissions from ICI boilers would have positive environmental and health impacts. SO 2 controls would reduce acid deposition, helping to preser ve aquatic life, forests, and crops as well as buildings and sculptures made of acid-sensitive materials. These108 emission reductions would also help to decrease ambient levels of PM 2.5 , a significant contributor to premature morbidity and illness in individuals with h eart or lung conditions.

MANE-VU has concluded that the energy and non- air environmental impacts of controlling

SO 2 emissions from ICI boilers are ju stified in light of the benefi cial impacts on regional haze, fine particulate air polluti on, acid rain, and equipment ope ration, as described above.

Vermont concurs with this conclusion.

4) Non-EGU SO 2 Emission Reduction Measures Ou tside MANE-VU – Remaining Useful Life of Any Potentially Affected Sources : Available information for remaining useful life

estimates of ICI boilers indica tes a wide range of life exp ectancies, depending on unit size, capacity factor, and level of maintenance perf ormed. Typical life spans range from about 10 years to over 30 years. However, the remain ing 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, th e technical options available, and the flexibility that non-MANE-VU states wo uld have to meet the Ask, MANE-VU has concluded that a 28-percent reduction in non-EGU SO 2 emissions is reasonable. Vermont

concurs with this conclusion.



### 10.3 Reasonable Progress Goals fo r 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 Wilderne ss in Vermont for the 10-year period of the implementation plan ending in 2018. These RP Gs are determined from modeling based on implementation of the proposed reasonable m easures 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 ba seline visibility for the 5- year period from 2000 through 2004

were calculated in conformance with an a lternative method recommended by the IMPROVE Steering Committee. (See Attachment J, “B aseline and Natural Visibility Conditions: Considerations and Proposed Approach to the Ca lculation of Baseline and Natural Visibility Conditions at MANE-VU Class I Areas,” Decemb er 2006.) Future progress toward the 2018 visibility target will be calc ulated in a nationally consistent manner base d on 5-year averages

in accordance with EPA’s “Guidance for Track ing Progress Under the Regional Haze Rule”109 (EPA-454/B-03-004, September 2003) with adju stments for the alternative method as recommended by the IMPROVE Steering Committee.

40 CFR 51.308(d)(1)(vi) requires that reasonable progress goa ls represent at least the visibility improvement expected from implem entation 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 estim ation 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 Subs ection 10.2. Additional information may be found in Section 6.0, Emissions Inventory, and S ection 11.0, Long-Term Strategy, as well as in the documentation for the MANE-VU modeling.

In setting the reasonable progress goals to im prove visibility at MANE-VU Class I Areas, Vermont recognizes that contribu ting states will have flexibili ty 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 th at contribute to regiona l haze allows each state up to 10 years to implement reasonable SO 2 and NO X control measures as appropriate and necessary.



### 10.4 Visibility Effects of (Addition al) Reasonable Control Measures

MANE-VU’s evaluations included modeling to estimate the e ffects 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 Benef its,” 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 additiona l reasonable control measures described in Subsection 10.2, above. Figures 10.4 and 10.5 descri be the results of th is modeling. In th e 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 “g lide slope” values (the plum-colored bars) shows that all areas are expected to experience visibility impr ovements that meet or exceed the uniform rate of progress ca lculated for each area. The second figure shows that, for the 20 percent of days having best visibility, expected vi sibility in 2018 will be better than it is today

at all locations.

While the MANE-VU states agree that thes e modeled 2018 visibility changes result from required and reasonable control me asures, 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 byVermont and the other MANEVU states are found to be consistent with th e stated national goals of preventing further visibility degradation while making measurable progress toward achievi ng natural visibility conditions in national parks and wilderness areas by 2064.

Figure 10.4 Demonstration of Required and Re asonable Visib ility Progress for 20 Percent Worst Visibility Days

V isibility Progress for 20% Worst Days

0 5 10 15 20 25 30 35

Acadia Brigantine Great Gulf Lye Brook MoosehornVisibility (deciviews)

2002 Baseline 2018 Glideslope 2018 Projected Progress Natural ( Visibilit y Im p rovements Must be Made at Reasonable Rate )

Figure 10.5 Demonstration of Required Maintenanc e 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 MoosehornVisibility (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/Ins titutional 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 a ddresses 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 se ven designated Class 1 areas within the MANEVU region: Lye Brook Wilderness, Great Gulf W ilderness, Presidential Range - Dry River Wilderness, Acadia National Park, Moos ehorn Wilderness, Roosevelt Campobello International Park, and Brigantine Wilderne ss. As presented in Section 3.0, Regional Planning and Consultation, Vermon t consulted with other states to develop the coordinated emission management strategies contained in th is SIP. The following describes how Vermont meets the long-term strategy requirements of the Regional Haze Rule.

Vermont’s long-term strategy includes enfo rceable emission limitations, compliance schedules, and other measures necessary to achi eve the reasonable prog ress goals described in Section 10.0. Additional measures may be reasona ble 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), pertai ning to interstate and international transport of pollu tants. More specifically, S ection 110 (a)(2)(D)(i)(II) requires states to include provisions in their implem entation plans to prohibi t any source or activity from emitting air pollutants in am ounts 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 Ve rmont as well as areas downwind from Vermont. As noted in Chapter 2 of this SIP, Vermont em issions contributed less th an half of 1 percent of annual average sulfate in a ny class I area outside of VT.



### 11.1 Overview of Strateg y Development Process

The regional strategy development process iden tified reasonable measures that would reduce emissions contributing to visibi lity impairment at Class I ar eas by 2018 or earlier. The process of identifying potential emission reducti on measures and the technical basis for the long-term strategy are discussed in this secti on. As a MANE-VU member and participant, Vermont supported several technical analyses unde rtaken to assist th e 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 kno wn as the Contribution Assessment (Attachment B).

• ICF Resources, L.L.C., “Comparison of CA IR and CAIR Plus Proposal Using the Integrated Planning Model®,” Final Dr aft Report, May 30, 2007, otherwise known as the CAIR Plus Report (Attachment X);

• MACTEC Federal Programs, Inc., “Assessm ent 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-E ligible Sources: Survey of Options for Conducting BART Determinations,” June 1, 2007 (Attachment T); and

• NESCAUM, “Assessment of Control T echnology Options for BART-Eligible Sources: Steam Electric Boilers, Industrial Bo ilers, Cement Plants and Paper and Pulp Facilities,” March 2005, ot herwise 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 contract or 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, co mmercial, 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 bur ning (including outd oor wood boilers).

The next step was to further refi ne this list, with th e aid of several of th e reports named above. The CAIR Plus Report documents MANE-VU’s assessment of the costs of CAIR and provides a cost analysis for additional SO 2 and NO X 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 docu ments referenced above pertaining to Best Available Retrofit Technology (BART) controls.

The beyond-CAIR strategy for EGUs rose to th e top of the list because the Contribution

Assessment showed that EGU sulfur emissions ha ve, 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 a nd fuel-oil suppliers co ncluded that such a strategy could realistically be implemented with in the next 10 years. Thus, the low-sulfur heating oil option for the residential and comme rcial sectors and the control measures option

for the oil-fired ICI boiler sect or merged into an overall st rategy 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 mee ting 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 th ey could be covered in programs adopted by114 individual states. The member states also de cided 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 bur ning and outdoor wood-fired boile rs remained on the list for those states where localized visibility impact s are a consideration even though emissions from these sources are primarily organic carbon and direct particulate matte r. Finally, it was

decided that the issue of outdoorwood-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 fo r 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 Verm ont’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 sufficien t 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 reason able progress goals in Class I areas affected by Vermont and other MANE-VU states ar e described in the following documents:

• NESCAUM, “Baseline and Natural Background Visibility Conditions: Considerations and Proposed Approach to the Calcula tion of Baseline and Natural Background Visibility Conditions at MANE-VU Cla ss I Areas,” December 2006 (Attachment J);

• NESCAUM, “The Nature of the Fine Pa rticle and Regional Haze Air Quality Problems in the MANE-VU Region: A Concep tual Description,” Fi nal, November 2, 2006 (Attachment Y);

• NESCAUM, “Contributions to Regional Haze in the Northeast and Mid-Atlantic United States,” August 2006, otherwise kno wn as the Contribution Assessment (Attachment B).

• ICF Resources, L.L.C., “Comparison of CA IR and CAIR Plus Proposal Using the Integrated Planning Model®,” Final Dr aft Report, May 30, 2007, otherwise known as the CAIR Plus Report (Attachment X);

• MACTEC Federal Programs, Inc., “Assessm ent 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-E ligible Sources: Survey of Options for Conducting BART Determinations,” June 1, 2007 (Attachment T);

• NESCAUM, “Assessment of Control T echnology Options for BART-Eligible Sources: Steam Electric Boilers, Industrial Bo ilers, Cement Plants and Paper and Pulp Facilities,” March 2005, ot herwise known as the BART Report (Attachment V);115 • NESCAUM, “MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Cont rol Measure Benefits,” February 7, 2008 (Attachment G); and

• NESCAUM, “2018 Visibility Projecti ons,” May 13, 2008 (Attachment O).

As described in Subsection 11.1, above, Vermont worked with other me mbers of the Ozone Transport Commission and MANE-VU to evalua te a large number of potential emission reduction strategies covering a wide range of sources of SO 2 and other pollutants contributing to regional haze. 40 CFR 51.308(d)(3)(v) require s states to consider several factors in developing their long-term stra tegies. 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 lo w-sulfur heating oil; and

• Residential wood combus tion and open burning.

These efforts led to the selection of the emissi on 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 deve loping its long-term strategy, Vermont considered air pollution programs being impl emented between the 2002 baseline year and 2018. The emission reduction programs desc ribed 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 ve ry same measures that were included in the 2018 emissions inventory and used in the modeli ng. While these control measures were not designed expressly for the purpose of improving vi sibility, the pollutants they control include those that contribute to visibility im pairment in MANE-VU Class I Areas.

MANE-VU’s 2018 beyond-on-the-way (BOTW) em issions inventory acc ounts 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 M ANE-VU 2018 on-the-books/on-theway (OTB/OTW) inventory. Inve ntories used for other RPOs reflect anticipated emissions controls that will be in place by 2018. The i nventory 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 und er consideration for regional haze SIPs that have not yet been a dopted. 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, an d Nonroad Sources in the MANE-VU Region,” Final Report, February 28, 2007, otherwise known as the Emission Projections Report (Attachment L);

• Alpine Geophysics, LLC, “Documentatio n 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 Re asonable Progress Goals: Model Performance Evaluation, Pollution Apportionm ent, and Control Measure Benefits,” February 7, 2008 (Attachment G); and

• NESCAUM, “2018 Visibility Projecti ons,” May 13, 2008 (Attachment O).



### 11.3.1 Controls on EG Us Expected by 2018

The following EGU emission reduction programs were included in the modeling used to develop the reasonable progress goals. These programs repres ent the greatest opportunities for reducing SO 2 emissions and their resulting particul ate 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 su lfate impacts at that area caused by sulfur oxide emissions originating outside Vermont, it is important that EGU SO 2 emission reduction programs of at least the scope identifi ed 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 ow n to require control of individual EGU SO 2 emissions that contribute to haze impacts in Vermont.

Clean Air Interstate Rule (CAIR) : As promulgated, this ma jor federal rule would have imposed permanent emissions caps on sulfur dioxide (SO 2 ) and nitrogen oxides (NO X ) in the eastern United States by 2015. When fully effective, CAIR would have reduced SO 2 emissions in the CAIR region by up to 70 percen t. To predict future emissions from EGUs after implementation of CAIR, MANE-VU used the Integrated Plan ning 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, em ission controls origina ting from the following state and regional programs were considered:

Connecticut EGU Regulations : Connecticut adopted the fo llowing 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 SO 2 emissions from electric generating units (EGUs) will have a larger effect on th e 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 SO 2 controls expected to be installed in re sponse 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 Connectic ut State Agencies (RCSA), section 22a-174-19a , limiting the

SO 2 emission rate to 0.33 lb/MMBtu for fossi l-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 NO X 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 alte rnatively 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

SO 2 , PM, VOC, and NO X state-wide, effective January 2006.

• Reg. 1146, Electric Generating Unit (EGU) Multi-Pollutant Regulation, requiring SO 2 and NO X emission controls state-wide, effective December 2007. SO 2 reductions will be more than regulation specifies

• Reg. 1148, Control of Stationary Combusti on Turbine Electric Generating Unit

Emissions , requiring SO 2 , NO X , and PM 2.5 emission controls st ate-wide, effective January 2007.

Delaware estimates that these regulations will result in the following emission reductions for

affected units: SO 2 emissions of 32,630 tons in 2002 will de cline to 8,137 tons in 2018 (a 75- percent reduction); NO X emissions of 8,735tons in 2002 will decline to 3,740 tons in 2018 (a 57-percent reduction). Also, Delaware anticipa tes the following reductions resulting from the consent decree with Valero Refinery Dela ware City, DE (formerly Motiva, Valero Enterprises): SO 2 emissions of 29,747 tons in 2002 will decline to 608 tons in 2018 (a 98- percent reduction); NO X emissions in 1,022 in 2002 will decline to 102 tons in 2018 (a 90- percent reduction).

Maine EGU Regulations : Chapter 145, NO X Control Program , limits the NO X emission rate to 0.22 lb/MMBtu for fossil-fuel-fired units gr eater than 25 MW built before 1995 with a heat input capacity between 250 and 750 MMB tu/hr, and also limits the NO X 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 NO X , SO 2 , Hg, and CO 2 . These regulations will achieve an approximately 50- percent reduction in NO X emissions and a 50- to 75-percent reduction in SO 2 emissions. Depending on the compliance paths selected, the a ffected facilities will meet the output-based

NO X and SO 2 standards between 2004 and 2008. This regulation also limits the six grandfathered EGUs to a CO 2 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 Polluta nt Annual Budget Trading and Banking Program , capping NO X emissions at 3,644 tons per year, SO 2 emissions at 7,289 tons per year, and CO 2 emissions at 5,425,866 tons CO 2 per year for all existing fossil-fuelfired steam units by December 31, 2006.

• Chapter Env-A 3200

, NO X Budget Trading Program , limiting ozone season NO X emissions on all fossil-fuel-fired EGUs greater than 15 MW to 0.15 lb/MMBtu, effective November 2, 2007.

New Jersey New Source Revi ew 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 a lternative technology by Dec. 31, 2006, to control SO 2 emissions and operate the control technology at all times the unit operates to limit SO 2 emissions to 0.15 lb/MMBtu; inst all SCR or approved alternative technology by May 1, 2007, to control NO X emissions and operate the control technology year-round to limit NO X emissions to 0.1 lb/MMBtu; and install a baghouse or approved alternative technol ogy by May 1, 2007, to control and limit PM

emissions to 0.015 lb PM/MMBtu.

• Mercer Unit #1 : Install dry FGD or approved al ternative technology by Dec. 31, 2010, to control SO 2 emissions and operate the control technology at all times the unit operates to limit SO 2 emissions to 0.15 lb/MMBtu; and install SCR or approved alternative technology by 2005 to control NO X emissions and operate the control technology during ozone season only in 2005 and year-round by May 1, 2006, to limit

NO X emissions to 0.13 lb/MMBtu.

• Mercer Unit #2 : Install dry FGD or approved al ternative technology by Dec. 31, 2012, to control SO 2 emissions and operate the control technology at all times the unit operates to limit SO 2 emissions to 0.15 lb/MMBtu; and install SCR or approved alternative technology by 2004 to control NO X emissions and operate the control technology during ozone season only in 2004 and year-round by May 1, 2006, to limit

NO X emissions to 0.13 lb/MMBtu.

The New Jersey settlement also requires th at units operating an FGD use coal having a monthly average sulfur conten t 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 NO X Budget Trading Program

, limits NO X 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 SO 2 Budget Trading Program

, limits SO 2 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 legi slation require s that coalfired EGUs achieve a 77-percent cut in NO X emissions by 2009 and a 73-percent cut in sulfur

dioxide SO 2 emissions by 2013. This act also established annual caps on both SO 2 and NO X emissions for the two primary utility companies in North Carolina, Duke Energy and Progress Energy. These reductions must be made in No rth 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 con tinuous emission control equipment for

PM/SO 2 /NO X emissions; comply with system-wide annual PM/SO 2 /NO X emissions limits; agree not to buy, sell, or trade SO 2 /NO X allowances allocat ed 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 equi pment to meet stringent pollution limits; implement a series of interim pollution reduc tion measures to reduce emissions while the permanent controls are designed and installed; and retire pollution emission allowances that Tampa Electric or others coul d use, or sell to others, to emit additional

NO X , SO 2 , and PM.

• VEPCO : Virginia Electric and Power Co. agreed to spend $1.2 billion by 2013 to eliminate 237,000 tons of SO 2 and NO X emissions each year fr om 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

NO X emission rates by 61 percent at its Crist 7 generating plant by 2007 with major reductions beginning in early 2005. The Cr ist plant is a significant source of NO X emissions in the Pensacola, Florida, area.120 

### 11.3.2 Controls on Non-EGU Po int Sources Expected by 2018

For non-EGU sources within MANE-VU, Ve rmont relied on MANE-VU’s Version 3.0 Emission Inventory for 2002. MAC TEC conducted an analysis of various control measures as documented in the Emission Projections Re port (Attachment L). Control factors were applied to the 2018 MANE-VU inve ntory for non-EGUs to repres ent the following national, regional, or state control measures:

• NO X SIP Call Phase I (NO X Budget Trading Program) (except ME, NH, VT);

• NO X SIP Call Phase II (except ME, NH, VT);

• NO X RACT in 1-hour Ozone SIPs (alrea dy included in the 2002 inventory);

• NO X OTC 2001 Model Rule for ICI Boilers;

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

• Combustion Turbine and RICE MACT (NO X co-benefits were not included and assumed to be small);

• Industrial Boiler/Proces s Heater MACT*; and

• Refinery Enforcement Initiative (Fluid catal ytic cracking units and fluid coking units, process heaters and boilers, flare gas recove ry, leak detection and repair, and benzene (wastewater)).

In addition, states provided c ontrol measure information about specific non-EGU sources or regulatory programs in their stat es. MANE-VU used the state-sp ecific 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 M ANE-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 NO X emissions from the followi ng non-EGU point sources:

• Asphalt production plants in Connecticut, Ne w Jersey, New York, and the District of Columbia;

• Cement kilns in Maine, Maryland, New York, and Pennsylvania; and

• Glass and fiberglass furnaces in Maryla nd, Massachusetts, New Jersey, New York, and Pennsylvania.

For other regions, MANE-VU used emission inventory data deve loped by the RPOs for those regions, including VISTAS’s Base G2, MRPO’s Ba se 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 Bo ilers and Process Heaters was v acated. Control efficiency

was assumed to be 4 percent for SO 2 and 40 percent for PM. The overall eff ects of including these reductions in the inventory are estimated to be minimal

.121 • Dupont : A 2007 agreement calls for E. I. D upont Nemours & Co.’s James River plant to install dual absorption pollution control equipment by September 1, 2009, resulting

in SO 2 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 SO 2 emissions from its #8 Power Boiler by using a wet scrubber. This control devi ce should result in reductions of over 3,500

tons of SO 2 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 i nventory for area sources by applying growth and control f actors to the 2002 Version 3.0 i nventory. Area source control factors were developed for the following national or regional control measures:

• The Ozone Transport Commission’s VOC M odel Rules, in OTC states where appropriate (for consumer pr oducts, architectural and indus trial maintenance coatings, portable fuel containers, m obile equipment repair and refinishing, and solvent cleaning);

• Stage I vapor recovery systems at vehicle re fueling 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 NO X and VOC emissions for the following area source categories for some (identified) states:

• NO X 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 c ontainers (all MANE-VU states except VT).

As noted above, inventory data for other regi ons 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 in cluded to avoid inventory double-counting.122 Some of the area-source control measures listed above may ha ve 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 invent ory, Vermont relied on MANE-VU’s Version 3.0 emission inventory, which included the follo wing emission control measures for Vermont:

• Vermont’s Low Emission Vehicle Regulat ions, 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 Va por Recovery (ORVR) Rule;

• Federal Heavy-Duty Diesel Engine Emissi on Standards for Trucks and Buses; and

• Federal Emission Standards for Large In dustrial Spark-Ignition Engines and

Recreational Vehicles.

Similar programs in other MANE-VU states were included in the on-road mobile source emission inventory, where applicab le. 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 st andards for refueling emissions controls for passenger cars and light trucks. The onboard controls were requ ired to be phased in for all new car production by 2000 and for all light truc ks by 2006. The rule established a refueling emission standard of 0.20 grams per gallon of di spensed fuel, which was expected to yield a 95 percent reduction of VOC emissions over unc ontrolled levels. The CAA authorizes EPA to allow state and local agencies that are not in the ozone tran sport region (OTR ) to phase out Stage II programs, even in the worst nonatt ainment 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 ye ar. This rule also

includes standards for NO X and non-methane hydrocarbons (NMHC) of 0.20 g/bhp-hr and 0.14 g/bhp-hr, respectively. These NO X 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 a123 97-percent reduction in the sulfur content of highw ay 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 sta ndards for emissions of NO X , hydrocarbons (HC), and carbon monoxide (CO) from several groups of pr eviously unregulated non-road engines. Included are large industrial spark-ignition engi nes and recreational vehicles. The affected spark-ignition engines are those powered by ga soline, liquid propane, or compressed natural gas rated over 19 kilowatts (kW) (25 horsepower). These engines are used in commercial and industrial applications, includi ng 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, co mmercial 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 emi ssions 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 Comp ression Ignition Engines at or above 37 Kilowatts,” 59 FR 31306, June 17, 1994.

• “Control of Emissions of Air Pollution fr om Nonroad Diesel Engines,” 63 FR 56967, October 23, 1998.

• “Control of Emissions from Nonroad Larg e Spark-Ignition Engines and Recreational Engines (Marine and Land-Based),” Fi nal Rule, 67 FR 68241, November 8, 2002.

• “Control of Emissions of Air Pollution from Nonroad Diesel Engine s and Fuel,” Final Rule, April, 2004.

As noted above, inventory data for other regi ons were obtained from those regions’ RPOs.



### 11.4 Additional Reasonable Measures

As required under 40 CFR 51.308(d)(1)(i)(A), Ve rmont and the other MANE-VU states applied four-factor analysis to potential cont rol measures for the pur pose of establishing reasonable progress goals (see Subsection 10.2 for detailed description). Reasonable

measures include those that the affected st ates 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 we re found to be reasonable and were included in124 the modeling that was used to set reasonable progress goals. (These additional measures surpass the “beyond-on-the-way” emission contro ls and inventories.) All of the control

measures – those embodied in the states’ co mmitments to existing or planned programs and

the additional reasonable control measures descri bed 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 requirement s in all states with BART eligible

sources.

• A low-sulfur fuel oil strategy in the inne r-zone MANE-VU states (New Jersey, New York, Delaware, and Pennsylvania, or portions thereof) to re duce the sulfur content of:

− #2 distillate oil to 0. 05 percent (500 pp m) 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 conten t of distillate oil to 15 ppm by 2016.

• A low-sulfur fuel oil strategy in the outer-z one MANE-VU states (the remainder of the MANE-VU region) to reduce the sulfur content of:

− #2 distillate oil to 0. 05 percent (500 pp m) 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 we ight, by no la ter than 2018;

− Further reduction of the sulfur conten t of distillate oil to 15 ppm by 2018, contingent on supply and availability.

• A 90-percent or greater reduction in sulfur dioxide (SO 2 ) emissions from each of the EGUs identified by MANE-VU as reasonably anticipated to cause or contribute to impairment of visibility in any mandator y 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 SO 2 reductions from specific EGUs, equivalent alternative measures w ill be pursued in the affected states.

• Continued evaluation of ot her control measures, including energy efficiency, alternative clean fuels, ot her measures to reduce SO 2 and nitrogen oxide (NO X ) emissions from all coal-burning facil ities by 2018, and new source performance

standards for wood combustion.

This suite of additional control measures are th ose 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 directed125 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. Wh ile some measures that states pursue may not represent enforceable commitments immediat ely, 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 cont rols on all BART-eligible EGU sources if an alternative interstate rule is not promulgated.

To assess the benefits of im plementing BART controls for MANE-VU’s non-EGU sectors,

NESCAUM included in the fi nal 2018 CMAQ modeling analys is anticipated emission reductions for the region’s BART-eligible facili ties, as described previously in Part 10.2.2 of this SIP. It is anticipated that twelve un its at eight BART-eligi ble sources in MANE-VU

would be controlled as a result of BA RT 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 achie ved by other programs that serve as BART but are not specifically id entified 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 resu lt from installation of ne w emission controls at BART-eligible facilities loca ted in neighboring RPOs. Ho wever, the MANE-VU modeling

did not account for BART controls in other RPOs and, consequently, di d 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 ma ximum 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 achieve d by this strategy will come from using low-sulfur #2 distillate for space heating in the residential and commercia l sectors. The costs of these emissions

reductions are estimated at $550 to $750 per ton, as documented in the MANE-VU126 Reasonable Progress Report. While the costs of the low-sulfur fuel oil strategy remain somewhat uncertain, they appear to be reas onable when measured against the costs of controlling other sectors. Currently there are logistical issues in supply ing 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-su lfur #6 fuel oil by 2018.

The MANE-VU states agree that a low-sulfur oil strategy is r easonable to pursue in the next ten years. Vermont will review the details of th is 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 to p 167 EGU emission points that contribute the most to visibility impair ment 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 E GU source sector is to pursue a 90-percent

control level on SO 2 emissions from the 167 identified stacks by 2018. MANE-VU has concluded that pursuing this level of sulfur re duction is both reasonable and cost-effective. Even though current wet scrubbe r technology can achie ve sulfur reducti ons greater than 95 percent, an overall 90-percent sulfur reduction level would include the effects of lower average reduction rates from dr y scrubbing technology, consistent wi th historical experience.

The costs of SO 2 emission reductions will vary by uni t. MANE-VU’s R easonable Progress Report (Attachment U) summarizes the availabl e 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 he lp MANE-VU meet visibility improvement goals. Many of the state programs that will co ntribute to meeting the targeted EGU strategy

are identified in Part 11.3.1 of this section. Listed belo w are other state programs not previously identified that will also contribute to meeting this strategy. These other programs may yield additional benefits by controlling em issions at certain EGUs not listed among the top 167 EGU stacks. The listed programs repres ent existing commitments by the states and, as such, were included in MANE-VU’s most recent modeling.

Maryland Healthy Air Act : Maryland adopted the followi ng requirements governing EGU

emissions:

• For NO X :

− Phase I (2009) sets unit-specific an nual 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 SO 2 :

− Phase I (2010) sets unit-speci fic annual caps totaling 48,818 tons.

− Phase II (2013) sets unit-speci fic annual caps totaling 37,235 tons.

• For mercury:

− Phase I (2010) requires a 12-month-rolling-av erage 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 (U nits 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-fir ed EGUs in New Jersey will have a mercury removal efficiency of 90 percent. (Some SO 2 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%) SO 2 reduction by 2013.

• Merrimack Station Unit MK-21: 18,812 tons (90%) SO 2 reduction by 2013.

• Newington Station Unit NT-1: 2,613 tons (50%) SO 2 reduction by 2018

Consent Agreements in the VISTAS region : The following consent agreements in the

VISTAS states were reflected in the emi ssions inventories used for those states:

• East Kentucky Power Cooperative : A July 2, 2007, consent agreement between EPA and East Kentucky Power Cooperative (EKP C) requires the utility to reduce its SO 2 emissions by 54,000 tons per year and its NO X emissions by 8,000 tons per year, by installing and operating selective catal ytic reduction (SCR) technology; low-NO X burners, and PM and mercury continuous emissi ons monitors at the utility’s Spurlock, Dale, and Cooper Plants. According to the EP A, 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 re ductions 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 NO X emissions each year by 2016 and 174,000 tons of SO 2 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 de veloping reasonable progress goals. Source retirement and replacement were considered in developing the 2018 emissions inventory described previously in Subs ection 10.3, Reasonable Progress Go als for Class I Areas in the

State. See also Table B-5 in the Em ission Projections Report (Attachment L).



### 11.6 Measures to Mitigate the Impa cts of Construction Activities

40 CFR 51.308(d)(3)(v)(B) of the Regional Haze Ru le requires Vermont to consider measures to mitigate the impacts of construction activities on regional haze. MANE-VU’s

consideration of control measures for constr uction activities is doc umented in “Technical Support Document on Measures to Mitigate the Vi sibility Impacts of Construction Activities in the MANE-VU Region,” Draft, October 20, 2006,” (Attachment Z).

MANE-VU’s Contribution Assessm ent (Attachment B) found th at, from a regional haze perspective, crustal material ge nerally does not play a major ro le. On the 20 percent bestvisibility days during the 2000-2004 baseline pe riod, crustal material a ccounted 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 re duced 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. Neve rtheless, 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 evalua tion of further controls. Future deliberations on potential control measures for constructi on 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 manageme nt 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 polluta nt emissions than other sources of wood smoke in the region.129 The largest MANE-VU wood smoke sour ce categories, with respect to PM 2.5 emissions, are residential wood combustion ( 73 percent); open burning ( 15 percent); and industrial, commercial, and institutional wood combusti on (9 percent). Unwanted fires involving buildings and wild lands make up only a mi nor fraction of wood burning emissions and cannot be reasonably addressed in a SIP. Fi res 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 em issions. 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 t hose 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 eff ect on visibility due to projec ted changes in point, area, and mobile source emissions over the period addressed by the long-term strategy. NESCAUM conducted modeling to evaluate th e expected improvements to visi bility at affected Class I areas by 2018 as a consequence of implemen ting 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 originat ing in Vermont have (o r will have) established reasonable progress goals for 2018 for each of th eir Class I areas. The control measures included in this SIP represent the reasonable effo rts of Vermont, in conjunction with efforts of other MANE-VU states, toward achieving the reasonable progress goal s established by the

affected states.

Based on the most recent M ANE-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 elementa l 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 possibi lity 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. (Spe cifically, the fire emissi ons inventory used in VISTAS for the base year relied on an earlier ve rsion of fire emissions data than the one used for the 2018 inventory.) No changes are predicted for sea salt because the model does not130 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 ot her MANE-VU states. To determine baseline visibility for affected Class I areas, Ve rmont used the 2000-2004 IMPROVE monitoring data to calculate the average deciview values for th e 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 av erage visibility conditions for the top and bottom quintiles.

To create the series of visibility graphs which follow, 2018 vi sibility estimates were made in accordance with EPA modeling guidance. First, 2002 daily average baseline concentrations were multiplied by their corresponding relativ e 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 va lues for the 20 percent of days having best visibility were av eraged, and the process repeated for the 20 percent of days having worst visibility. The resulting aver ages represent the projected upper and lower quintiles of visibility in 2018.

The following is provided to assist with interp retation of the line graphs in Figures 11.1 and Figures 11.3 through 11.6. Note that lower de ciview values indicat e 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 wors t 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 th e 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 th e 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 woul d be with no further degradation or improvement.

• The straight green line (

▬ ) represents the 20 percent worst visibility values that establish the uniform rate of progre ss 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 visibili ty baseline value in 2004 and the 20 percent worst visibil ity value under natural conditi ons 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 conditio ns (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 stra tegy, as predicted by the CMAQ model.131 (This value is a reasonable progress goal .)

• The blue star ( 1⁄4 ) represents the 20 percent wors t visibility value in 2018 after implementation of MANE-VU’s long-term stra tegy, 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 th e dashed line indicates that visibility requirements will be met, i.e., th ere will be no further degradation from baseline conditions on days of best visi bility. Figure 11.2 presents ba r 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 y ear, 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 progre ss 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 pe rcent (natural c onditions) in 2064.

Figures 11.3 through 11.6 are line graphs showin g 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 Ly e Brook Wilderness Based on Most Recent Projections

0 5 10 15 20 25 3019851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed

20% Best Observed

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

20% Best 'Natural'132 Figure 11.2 Expected Improvements in Pollutant Concentrations at Lye Brook Wilderness on Best and Worst Days

Figure 11.3 Expected Visibility Im provement at Acadia National Park Based on Most Recent Projections

0 5 10 15 20 25 3019851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed

20% Best Observed

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

20% Best 'Natural'133 Figure 11.4 Expected Visibility Improvement at Brigantine National Wildlife Refuge Based on Most Recent Projections

0 5 10 15 20 25 30 3519851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed

20% Best Observed

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

20% Best 'Natural'

Figure 11.5 Expected Visib ility Improvement at Great Gulf Wilderness Based on Most Recent Projections*

0 5 10 15 20 25 3019851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed

20% Best Observed

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

20% Best 'Natural'

* 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 2519851990199520002005201020152020202520302035204020452050205520602065

YearDecivews 20% Worst Observed

20% Best Observed

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

20% Best 'Natural'



### 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 n ecessary to obtain its share of emission reductions needed to meet the reasonable prog ress goals. The modeling analyses referenced in Subsection 11.8, above, demonstrate that the Vermont/MANE-VU long-term strategy is

sufficient to meet thes e visibility goals.

As demonstrated in Section 2 of th is plan, Vermont su lfur 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 w ill be even smaller as Vermont complies

with the MANE-VU low-sulfur fuel oil strategy, as nearly 85% of Vermont’s SO 2 emissions originate from ICI boilers and residential heating units which would be reduced significantly by 2018 by the MANE-VU (outer z one states) low sulf ur fuel strategy.

The basis for the long-term strategy is a st atement adopted by MANE-VU on June 20, 2007 (see Part 3.3.3, The MANE-VU “Ask”). This docu ment provides that each state will have up to 10 years to pursue adoption and implementa tion of reasonable control measures for NO X and SO 2 emission reductions. Vermont’s regional h aze SIP is wholly consistent with this long-term strategy. To meet its obligation, Ve rmont agrees to pursue the following general and specific emission reduction measures:

* The visibility improvement estimate for Moosehorn Wilder ness also serves as an estimate for Roosevelt/Campobello

International Park.135 • Participation in a regional low-sulfur fuel oil strategy that will result in SO 2 emission

reductions from ICI boilers and residen tial heating units across the state;

• Continued evaluation of other possible cont rol measures for haze-causing emissions.



### 11.10 Vermont Commitments to Speci fic Regulatory Changes That Will Further Protect Visibility

The MANE-VU regional long-te rm strategy for reaching reasonable progress goals for visibility established at Class I areas in th e MANE-VU region implies no large scale sulfur emissions reductions from existing sources in Ve rmont except for the sulfur-in-fuel limitations to be implemented on a regional market ba sis (see Section 11.9 above). Nevertheless, Vermont intends to establish a secondary welfar e standard for particulate matter measures as sulfate ion and a significance level for single s ource 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 sulf ate standard and the incorpora tion of a significance level for ambient sulfate impact will also establish in th e 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 signi ficant large stationary sources impacting on visibility at Class I areas in MANE-VU. Verm ont 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 am bient 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/m 3 ), however the sulfate i on concentration will be identified as the relevant measure of ambient imp act 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 sulfat e particulate matter transported

into Vermont from outside the state. The new re gulation is expected to be adopted within the next year (by 2010) and will be submitted as pa rt 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 sulfat e ion which is currently contained in Vermont Air Pollution Control Regulation TABLE 3 “Lev els 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/m 3 as well as a 24-hr maximum significance level for “sulfates” at 2.0 ug/m 3 . Both of these significance le vels 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 dr afted, a summer seasonal sulfate level of 0.004 ug/m 3 and a 24-hour maximum of 0.10 ug/m 3 will be specified as representing significant sulfate impacts from individual sources. The revision of these significance levels136 will establish in Vermont regulation, new significan ce 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 wh ether newly proposed (or existi ng) sources, lo cated within Vermont (or in upwind states), are significantl y contributing to exceedances of Vermont’s sulfate standard, and therefore significantly cont ributing to Lye Broook visibility impairment. When this SIP has been approved by EPA, Vermont assumes that sources exceeding this significance level will be cons idered by EPA to be interfering with Vermont’s ability to assure reasonable progress toward the Cl ean Air Act §169 national visibility goal.

The significance levels being considered curre ntly to replace the existing ones are on a par

with the EPA 9/21/07 Federa l Register Proposal for PM 2.5 Increments, Significant Impact Levels (SILs) and Significant Monitoring Conc entrations (SMCs). Under the EPA proposal,

the SILs for annual and 24-hr maximum PM 2.5 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 re vised 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) require s 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 addi tional 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 Ch apter 23 (Air Polluti on 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 pr ogress 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 Li mitations and Control Measures

40 CFR 51.308(d)(3)(v)(F) requires Vermont to consider the en forceability 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 applicab le provisions of those

laws and rules.137 The key statutory provisions that allow for th e 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 preven t, abate, or control air pollution; 10 VSA § 567, which authorizes rules to control em issions from motor vehicles; and 10 VSA § 568, which provides for penalties for the viol ation of 10 VSA chapter 23 or any rules adopted thereunder);

• 10 VSA chapter 201, Administrative Envi ronmental Law Enforcement, which authorizes enforcement of 10 VSA chapter 23;

• 3 VSA § 2822(j)(1), which establishes f ees 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 Pote ntially Polluting Mate rials 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 ru les 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 th at national ambient air quality standards are

achieved.

In order to comply with and implement th e MANE-VU low-sulfur oil strategy, Vermont commits to revising the § 5-221( 1) of the Vermont Air Polluti on 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% sulf ur by weight (500 ppm) by no late r than 2014, of #4 residual oil to 0.25-0.5% sulfur by weight by no later than 2018, and of #6 re sidual oil to no greater than 0.5 % sulfur by weight by no late r than 2018, and to reduce the sulf ur content of distillate oil further to 15 ppm by 2018, depe nding on supply availability.138 Ultimately, Vermont’s Regional Haze SIP is depe ndent on the implementation of enforceable emission limitations and control measures, both w ithin 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 pr edicated on the good-faith efforts of contributing upwind states to meet

their fair share of emission reductions thr ough implementation of their own enforceable control measures. While Vermont can provide a ssurances regarding the implementation of instate emission controls, the bulk of regiona l-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 Pollutio n 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 SO 2 , NO 2 or PM 10 in any Class 1 area (i.e. Ly e Brook). The applicant must

also demonstrate “that the increase in allowabl e 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 Ar ea is defined as “any portion of the area comprising Lye Brook Wilderness Area and all ot her 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 w ill 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 fo r meeting its regional haze goals.