Response to Comments from the Environmental Protection Agency (EPA) and
the Federal Land Managers (FLMs) on the Rhode Island (RI) Draft Regional
Haze (RH) State Implementation Plan (SIP), dated January 26, 2009

Comment:	An executive summary would be helpful.  Section 1.0 essentially
serves this purpose, but additional specifics about Rhode Island’s
actions should be added, including specifics of the long-term strategy. 
(United States Department of Agriculture (USDA))

Response:	Additional state-specific information was added to Section 1.0
in response to this comment.

Comment:	Paragraph four on page 1 should be revised as follows:  “The
Regional Haze Rule calls for each state to establish reasonable progress
goals for visibility improvements and to  formulate a long-term strategy
for meeting these goals.” (EPA)

Response:	The SIP was revised in response to this comment.

Comment:	Although RI has adopted the MANE-VU Ask as its long term
strategy, the draft SIP is unclear as to how the State will implement
the Ask.  In Section 1.0 (Introduction), RI adopts the MANE-VU Ask and
concludes that this strategy takes into account a four-factor analysis
for each control measure.  However, the four-factor analysis is not
included in the document. The draft SIP does a poor job in linking RI
actions to the MANE-VU Ask. The SIP should be revised to demonstrate
that the State is adopting the MANE-VU Ask and other measures as
reasonable progress based on, at a minimum, the four factors noted in
the RH Rule.  (Department of the Interior (DOI))  We recognize the
impacts from Rhode Island sources are relatively small, but this does
not negate the requirement that the Regional Haze SIP include all
measures deemed necessary for Rhode Island to obtain its share of
emissions reductions needed to the meet the Reasonable Progress Goals
for the Class I areas in the states listed above.   Specific information
on enforceable controls and compliance schedules for Rhode Island
sources should be provided in the SIP.  (USDA)

Response:  In response to these comments, a table outlining the results
of MANE-VU’s four factor analysis of possible control measures was
added to section 10.2.1, “Rationale for Determining Reasonable
Controls” and discussions of that analysis for the low-sulfur fuel oil
and targeted EGU strategies were added to sections 10.2.3 and 10.2.4,
respectively.  In addition, more extensive discussion of the emissions
control strategies for Rhode Island and a demonstration that those
strategies constitute Rhode Island’s fair share of emissions
reductions has been added to Section 11, “Long-term Strategy.”

Comment:	It is unclear if RI’s emissions will be decreasing over the
planning period.  Section 1.0 (Introduction) concludes that Rhode
Island’s contribution to emission reduction through its long term
strategy, along with reductions taken by other states in MANE-VU, is
sufficient to meet reasonable progress calls.  However, there is no
information provided to document how much RI’s emissions will be
reduced from 2002 to 2018.  Therefore, it is unclear if RI is meeting
its fair share of emissions reductions to meet reasonable progress under
the MANE-VU Ask. (DOI)

Response:	The tables in Section 6.4, “Summary of Emissions
Inventories,” show a 43.1% decrease in SO2 emissions in Rhode Island
between the 2002 baseline and the “Beyond On the Way” 2018 inventory
and a 78.9% decrease in emissions between the 2002 baseline and the
“Best and Final” 2018 inventory, which includes all measures in the
Ask.  In response to this comment, Section 11.9, “Rhode Island’s
Share of Emissions Reductions” was expanded and now includes a
comparison of the expected “Best and Final” reductions in Rhode
Island (78.9%) and in MANE-VU as a whole (73.5%).  This section
concludes that “This comparison indicates that Rhode Island will meet
its share of anticipated SO2 emission reductions within the region by
2018.”

Comment:	Section 1.1 (The Basics of Haze) states, “On the worst 20
percent days, visibility impairment in Northeast and Mid-Atlantic Class
I areas range from about 25 to 30 deciviews.”  EPA suggests including
the range in miles in order to give the reader a better frame of
reference.  (EPA)

Response:	The range of miles was added to Section 1.1 in response to
this comment.

Comment:	Paragraph 5 on page 4 should be revised as follows: “About
half of the worst visibility days in the New England Class I Areas occur
in the summer when meteorological conditions are more conducive to the
formation of sulfate from SO2 an to the oxidation or organic aerosols. 
In addition, winter and summer transport patterns are different,
possibly leading to different contributions from upwind source regions. 
As a result, The remaining worst visibility dates 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 source regions.”  (EPA)

Response:	Section 1.2 (Anatomy of Haze) was changed in response to this
comment.

Comment:	Section 1.4 (Class I Areas Within MANE-VU) should be revised to
read as follows:  “The MANE-VU RPO contains nine seven Class I areas
in six four states (see Figure 1.2).”  (EPA)

Response:	Section 1.4 was changed in response to this comment.

Comment:	Section 2.0 (Areas Contributing to RH), should include a better
summary of the Contribution Assessment.  Since RI Emissions are deemed
to minimally contribute to visibility impairment at all MANE-VU Class I
areas based on the MANE-VU analyses, the SIP should include graphical
information for all Class I areas, not just one. The table of percentage
mass contribution in Section 2.1 (Class I Areas Affected by Rhode
Island’s Emission Sources) does not provide a context as to the level
of RI Emissions within the region.  A summary of Contribution Assessment
would help support the argument that RI emissions are minimal. (DOI) 
The discussion regarding Rhode Island’s contribution to visibility
impairment at other States’ Class I areas is very brief.  Additional
discussion should be provided to support Rhode Island’s assertion that
its impacts are “minimal.”  Section 8.2 (Contributing States and
Regions) provides additional information on RI’s contribution to
sulfate impacts.  It is suggested that at the very least, a reference to
Section 8.2 be added to Section 2.  (USDA)

Response:	The discussion in Section 2 was expanded in response to this
comment to show the impacts of Rhode Island emissions on sulfate levels
at all MANE-VU and other nearby Class I areas, calculated using several
different methods.  Rhode Island’s contributions to sulfate levels at
all Class I areas, calculated by all methods, is minimal.

Comment:	After Table 3.2, there is a section from the New Hampshire SIP
that should be removed.  (DOI)

Response:	That section has been removed.

Comment:	In Section 3.2.1.2 (Meeting the “Ask” –  Rhode Island),
RI adopts the MANE-VU Ask and agrees to pursue low sulfur fuel oil for
industrial, commercial and institutional (ICI) boilers, electric
generating units (EGUs) and home heating units and to decrease emissions
from outdoor wood boilers (OWBs).  In Sections 8 and 10, the draft SIP
acknowledges that BART and the targeted EGU strategy do not apply to RI.
 However, there is no discussion in either of these sections of how RI
plans to decrease emissions from OWBs.  In addition, as part of the Ask,
RI has agreed to pursue “other reasonable control measures” as
needed and the SIP should elaborate on those controls.  (DOI)

Response:	Section 11.9 has been modified to include more specific
information about Rhode Island’s emissions reduction strategies,
including planned OWB regulations. 

Comment:	In Section 3.2.2 (Technical Ramifications of Differing
Approaches), RI implies that addressing inconsistencies with emission
inventories “caused” most states to miss the 2007 statutory
submittal date.  This statement should be reconsidered for accuracy and
possible removal. (DOI)

Response:	That statement was removed from Section 3.2.2 in response to
this comment.

Comment:	There is no mention of links to other RI programs, including
NSR and PSD permitting programs.  State RH SIPs must address the goal of
protecting the 20% best visibility days in Class I areas.  The RI SIP
should recognize the requirements of full consultation with the FLMs for
review of visibility impacts required by the NSR and PSD Programs.
Please provide information on how RI will use future permit reviews to
contribute to progress in the RH process.  (DOI)  	We request that Rhode
Island provide language in their SIP linking the Regional Haze and New
Source Review programs and continued FLM coordination between these
programs.  Currently, there is no mechanism in the SIP to ensure the
emissions from new stationary sources or major modifications of existing
sources will make reasonable progress toward the national visibility
goal (40 CFR 51.307).  This could be especially important for emissions
from new sources that were not anticipated in 2018 emission inventories.
 (USDA)

Response:	A section discussing the links between Rhode Island’s New
Source Review program and Regional Haze has been added as Section 11.12,
“Prevention of Significant Deterioration.”

Comment:	Section 5.0 (Air Monitoring Strategy) should include language
committing RI to continuing support of the IMPROVE network by stating
that RI agrees the IMPROVE is an appropriate monitoring network to track
RH progress and that RI agrees to work with neighboring states and FLMs
in meeting the goals of the IMPROVE program.  (DOI)   Section 5
discusses the monitoring strategy being used to assess visibility
conditions.  Even though Rhode Island does not have any Class I areas,
this section demonstrates the importance of continued operation of the
IMPROVE monitoring network.  We ask that Rhode Island add a statement
expressing their support for continued operation of the IMPROVE network.
 (USDA)

Response:	A statement of Rhode Island’s support of the IMPROVE network
has been added to Section 5.0.

Comment:	In Section 5.2 (Monitoring Information for Rhode Island), the
Contribution Assessment is incorrectly referenced as Appendix A.  The
reference should be to Appendix B.  (DOI)

Response:	This reference has been corrected.

Comment:	The last paragraph of Section 5.2 should be revised to read as
follows:  “Rhode Island does not contain any Class I Areas; therefore
no monitoring plan is required under Section 51.308(d)(4) or Section
51.305 of EPA’s Regional Haze rule.”  (EPA)

Response: 	Section 5.2 was changed in response to this comment.	

Comment:	Section 5.3 (Monitoring Sites for MANE-VU Class I Areas) should
be revised to reflect that Moosehorn Wilderness and Roosevelt Campobello
International Park also share a monitoring site.  (DOI)

Response:	Section 5.3 was changed in response to this comment.

Comment:	In Section 6.4 (Summary of Emissions Inventories), it would be
helpful to have a state-specific discussion, including an explanation
for increases in PM2.5. PM10, NH3 and SO2 from 2002 Baseline to OTB/OTW
inventories for 2018.  (DOI)  	The discussion of emissions inventories
is generic and only explains the work done by MANE-VU and NESCAUM.  This
section should include additional discussion of how the Rhode Island
specific emissions (presented in Tables 6.1-6.4) were generated. (USDA) 
Tables 6.2 and 6.3 indicate that area SO2 emissions are reduced from
5,398 tpy to 1,368 tpy from implementation of OTB/OTW strategies to BOTW
strategies.  It is not clear why there is such a large reduction in area
SO2 emissions between these two strategies.  Please include a discussion
of the measures included in BOTW that are expected to achieve this
reduction.  (EPA)

Response:	State-specific information about the source of the growth
factors used to grow 2002 emissions to 2018 has been added to Sections
6.3.1.2 (non-EGU point sources) and 6.3.2 (area sources).  An
explanation of the reduction in SO2 emissions in the BOTW and Best &
Final inventories has been added to Section 6.4.

Comment:	Section 3.0 (Regional Planning and Consultation) includes a
discussion on the differing emission inventory approaches of MANE-VU,
MWRPO and VISTAS. This discussion should also be included in Section 6.0
(Emissions Inventory).  (DOI)

Response:	A reference to the discussion in Section 3.0 was added to
Section 6.1, “Baseline and Future-Year Emissions Inventories for
Modeling.”

Comment:	Section 6 should discuss which inventory was used for
performance testing of the numerous models used in developing the
MANE-VU inventory.  (DOI)

Response:	Section 6.1.1, “Baseline Inventory (2002),” includes the
following statement:  

Version 3 of the MANE-VU 2002 baseline emissions inventory was used in
the regional air quality modeling simulations.  Further description of
the data sources, methods, and results for this version of the 2002
baseline inventory is presented in E.H. Pechan & Associates, Inc.,
“Technical Support Document for 2002 MANE-VU SIP Modeling
Inventories, Version 3, November 20, 2006, also known as the Baseline
Emissions Report (Attachment M).

No modifications were made in response to this comment.

Comment:	We would like Rhode Island to commit to annually tracking
emissions and reporting how the projected emissions compare to actual
emissions in 2012 and 2018. (USDA)

Response:	Section 1.3.2 of the draft document (now 1.3.3), “State
Implementation Plan” includes the following commitment:

Pursuant to 40 CFR 51.308(d)(4)(v), RI DEM will also make periodic
updates to the Rhode Island’s emissions inventory (see Section 6.0,
Emissions Inventory).  RI DEM proposes to complete these updates to
coincide with the progress reports.

In response to this comment, the following sentence was added to that
commitment:  “Actual emissions will be compared to projected modeled
emissions in the progress reports.”

Comment:	Section 7 (Air Quality Modeling) concludes that models were
tested and found to be adequate.  Please summarize the meteorology,
emissions and results of such evaluations in making these conclusions. 
This is especially important since RI used a suite of models in making
conclusions for the draft SIP.  (DOI)  In Sections 7.1 (Meteorology) and
7.3 (Model Platforms), brief discussions of model performance would be
helpful.  (USDA)

Response:	Since Rhode Island did not perform modeling independent of
MANE-VU, the State has nothing additional to add to this discussion,
which was prepared regionally. The attachments address the modeling
methodology in more detail.

Comment:	In Section 8.1 (Fine-Particle Pollutants) the draft SIP states
that organic carbon accounts for the second largest share of the fine
particulate mass responsible for light extinction.  However, Section
11.7 (Agricultural and Forestry Smoke Management) states that organic
carbon emissions do not need to be controlled or managed.  This may be a
matter of timing for this round of SIP development and what is needed
for reasonable progress at this time.  However, RI should commit to
reviewing its position on organic carbon in the 2013 review.  (DOI)

Response:	Section 8.1, “Fine Particle Pollutants,” states the
following:

Organic carbon was found to be the next largest contributor to haze
after sulfate.  In comparison with sulfate, the emission sources of
organic carbon are diverse, variable, more diffuse, and less well
understood; and the problem of controlling organic carbon emissions is
exceedingly complex.  For these reasons, MANE-VU considered organic
carbon to be the subject of possible future control measures but not a
specific target pollutant in the initial strategy to mitigate regional
haze.

Section 8.3.2 states:

In short, further work is needed to characterize the organic carbon
contribution to regional haze in the MANE-VU states and to develop
emissions inventories that will be of greater value for visibility
planning purposes.  As pointed out in Subsection 8.1, above, organic
carbon could be the subject of future control measures to mitigate
regional haze but is not the focus of initial planning. 

The following sentence was added to that section in response to this
comment: “This issue will be discussed further in the first progress
report.”

Comment:	In Section 8.2 (Contributing States and Regions), RI agrees to
pursue adoption of regional control measures, but is not specific as to
what the control measures are.  If regional control measures are not
available, please commit to addressing this issue in the 2013 review. 
(DOI)

Response:	That section is referring to measures included in the Ask and
any subsequent MANE-VU actions; those measures are detailed elsewhere in
the document (e.g. sections 10.2 and 11.4).  Section 11.9 specifies
which of these measures are applicable to Rhode Island and commits to
pursuing those measures. 

Comment:	The reference cited for Figure 8.11 appears inaccurate.  Please
correct.  The source of the data used to generate Figures 8.12, 8.13,
8.15, 8.19, 8.20 and 8.22 should also be referenced. (EPA)

Response:	 These data were generated by the MARAMA Emissions Inventory
Project and are listed on the MARAMA website at:   HYPERLINK
"http://www.marama.org/visibility/Inventory%20Summary/2002EI-Ver3Sum.htm
l" 
http://www.marama.org/visibility/Inventory%20Summary/2002EI-Ver3Sum.html
 .  That reference has been included in the SIP document.

Comment:	Section 8.3.4 (Primary Particulate Matter (PM10 and PM2.5))
concludes that emission inventories indicate that residential wood
combustion represents 25% of primary fine particle emissions in the
region.  Please provide an evaluation of control measures on sources of
residential wood combustion, especially considering that RI has agreed
to pursue such controls as part of the MANE-VU Ask/RI long term
strategy.  (DOI)  RI should include a discussion of its plans to
decrease emissions from OWB, including how the emission reductions will
be made federally enforceable.  (EPA)

Response:	As stated in Section 11.3.3, “Controls on Area Sources
Expected by 2018,” MANE-VU’s emissions projections counted the
federal woodstove New Source Performance Standards (NSPS) as OTB/OTW
control measures.  The assumptions used to project emissions reductions
in 2012 and 2018 as a result of the NSPS are detailed in Table D-3 of
MARAMA’s “Development of Emission Projections for 2009, 2012, and
2018 for NonEGU Point, Area, and Nonroad Sources in the MANE-VU Region,
Final Report,” which is Attachment N to the Rhode Island SIP.  

RI DEM has included a four factor analysis of controls for residential
wood combustion in Table 10-2.  A statement of Rhode Island’s planned
OWB regulatory action has been added to Section 11.9.

Comment:	Section 8.3.4 states, “Most states showed a steady decline in
annual PM10 emissions in the years leading up to the 2002 inventory.  By
contrast, emission trends for primary PM2.5 were more variable.”  RI
should include examples of the trend data.  (EPA)

Response:	That sentence was removed from the SIP document in response to
this comment.  Rhode Island did not track PM10 and PM2.5 emissions in
the years leading up to the 2002 inventory.

Comment:	Since Rhode Island has no Class I areas, it is acceptable to
state that Rhode Island agrees with the reasonable progress goals
established by the States of Maine, New Hampshire, Vermont, and New
Jersey for their Class I areas.  Even though the impacts are minimal,
Section 10.0 (Reasonable Progress Goals) should also, at least,
recognize that emissions from Rhode Island sources impact Class I areas
in West Virginia and Virginia as well.  (USDA)

Response:	Impacts of Rhode Island emissions at Shenandoah National Park
(Virginia) and Dolly Sods Wilderness (West Virginia) are presented in
Table 2.1, Figure 2.2.1(d), Table 8.1, and Figures 8.1, 8.3 and 8.9. 
The REMSAD estimates of Rhode Island’s sulfate impacts on those areas
are 0.01%.

Comment:	In Section 11.0 (Long-Term Strategy), RI incorporates the
MANE-VU Ask as its long term strategy and indicates that the long term
strategy has enforceable emission limits, compliance schedules and
“other measures necessary” to attain goals, but these items are not
included.  There are no links between regional emission control
strategies and RI-specific actions.  (DOI)  Section 11.0 indicates the
long term strategy includes “enforceable emissions limitations,
compliance schedules and other necessary measures” to achieve the
reasonable progress goals established by other States for their Class I
areas.   The information presented in Sections 11.1-11.4 is mostly
generic MANE-VU information that applies to other states.  Specific
information on enforceable controls and compliance schedules for Rhode
Island sources should be provided as well. (USDA)  The long-term
strategy should include specific commitments and enforceable emissions
limitations needed to demonstrate that Rhode Island is obtaining its
share of the emissions reductions needed to meet the reasonable progress
goals.  Additional information should be added to Sections 11.9 and
11.10 of the Draft SIP to demonstrate that Rhode Island is doing its
“fair share.”   (USDA)

Response:	More detail has been added to Section 11.9, “Rhode
Island’s Share of Emissions Reductions,” and 11.10,
“Enforceability of Emission Limitations and Control Measures,” in
response to these comments.

Comment:	Section 11.2 (Technical Basis for Strategy Development)
references technical reports that were used to determine the level of
emission reduction required by RI to achieve reasonable progress goals
in affected Class I areas.  Please provide a statement or summary of the
necessary reduction levels.  (DOI)

Response:	Rhode Island did not conduct these analyses and has no further
information on this subject beyond that which is in the document.  As
discussed in the document, Rhode Island sources contribute considerably
less than 2% of the sulfate at any Class I area, and thus the State has
been determined to not be a significant contributor to visibility issues
in those areas. In addition, as discussed in Section 11.2, expected SO2
emissions reductions in Rhode Island are consistent with those in
MANE-VU as a whole.

Comment:	Section 11.3.1 (Controls on EGUs Expected by 2018) should
include the permit levels for the RI EGUs, since they are enforceable
emissions limits and RI is not subject to CAIR.  (DOI)  In Section
11.3.1, more details about RI EGUs should be included, e.g. what are the
sources, what are the limits to which they are subject, and are those
limits federally enforceable.  

Response:	Those levels are now listed in 11.3.1.  The section includes a
statement that the limits are federally enforceable.

Comment:	Section 11.3.2 (Controls on Non-EGU Point Sources Expected by
2018) should identify any non-EGU sources affected by the RH program. 
(DOI)

Response:	Rhode Island does not have Non-EGU point sources that are
affected by the RH program, other than point sources that burn fuel oil.

Comment:	In Sections 11.3.3 (Controls on Area Sources Expected by 2018)
and 11.3.5 (Controls on Non-Road Sources Expected by 2018), please
identify what specific measures RI is taking based on MANE-VU regional
strategies.  (DOI)

Response:	References to applicable RI area source regulations have been
added to Section 11.3.3.  The non-road measures identified in 11.3.5 are
federal rules and, therefore, do not require state regulatory action.

Comment:	Section 11.4 (Additional Reasonable Measures) concludes that
adoption of the MANE-VU Ask is reasonable as RI’s long-term strategy. 
However, it does not include the required four-factor analysis of each
measure in the Ask specific to RI sources. In addition, the SIP should
indicate how RI plans to satisfy each of those measures.  The long-term
strategy does not include the measures to address new source performance
standards for wood combustion that were mentioned in Section 3. The
draft SIP concludes that most wood smoke is from residential wood
combustion but lacks any analysis of control measures on this source
category, even through RI has effectively adopted such a measures under
the MANE-VU Ask in Section 3.

 (DOI)

Response:	These issues are now addressed in more detail in Section 11.9.

Comment:	In Section 6.0, the draft SIP concludes that organic carbon is
the second largest contributor to RH.  RI Does not have a smoke
management program and is not required to do so based on a technical
report developed for MANE-VU.  The MANE-VU emissions inventories
indicate that emissions from agricultural managed and prescribed burning
are very minor source categories.  However, in Section 11.7
(Agricultural and Forestry Smoke Management), RI should include a
commitment to track such in the future to help determine the level of
contribution for future planning periods.  (DOI) We agree that based on
existing inventories of smoke emissions from wildfires and prescribed
fires, they are not a significant emission source for Rhode Island or a
significant contributor to regional haze in downwind Class I areas at
this time.  It would be helpful to add a reference to the specific
sections in Attachment V which support this claim.  Also, we request
that Rhode Island commit to track smoke emissions in the future to help
determine the level of contribution for future planning periods.  (USDA)
 RI should develop a smoke management plan which addresses emissions
from prescribed burning. (EPA)

Response:	As commented by DOI and USDA, a SMP is not required for Rhode
Island because prescribed, managed and agricultural burning is an
extremely small emissions source in the State.  In response to these
comments, Rhode Island-specific emissions information, as reported in
the technical report, and a commitment to including this category in
future inventory efforts was added to Section 11.4.

Comment:	Section 11.9 (Rhode Island’s Share of Emission Reductions)
should detail the emissions reductions needed and anticipated by RI to
demonstrate that RI will achieve its fair share of emissions reductions.
 (DOI)

Response:	Section 11.9 has been augmented in response to comments. 	

Comment:	In Section 11.4, RI fully adopts the MANE-VU Ask, yet Section
11.9 states that RI is continuing to evaluate the control measures in
the strategy to determine whether they are reasonable to adopt.  The SIP
should identify emissions control strategies being adopted now and those
slated for future adoption.  In addition, RI should commit to address
any measures still being considered in the 2013 review.  (DOI)  In
Section 11.4, Rhode Island indicates it will be relying on the MANE-VU
“Ask” in its long term strategy.  However, there is little
information provided about specific actions that will be taken by Rhode
Island to meet the “Ask.”  Specifically, in regards to the
“low-sulfur fuel oil strategy,” Rhode Island only commits to review
the details of this strategy in five years to determine whether
requiring low-sulfur fuel “remains a viable option for implementation
by 2018.”  (USDA)  Section 11.4.2 (Low-Sulfur Oil Strategy), states
that RI will review in low-sulfur fuel oil strategy in five years, “to
ascertain that requiring the use of low-sulfur fuel remains viable for
implementation by 2018.”  This appears inconsistent with the MANE0VU
Ask for the other zone which calls for #2 distillate oil to be reduced
to 500 ppm sulfur by  no later than 2014.   (EPA) 

Response:	Sections 11.4 and 11.9 have been altered in response to these
comments.  RI DEM is committing to adopt the low-sulfur fuel strategy
with the caveat that Phase II limits will be further evaluated for
viability by 2018 in the first progress report.  RI DEM is also
committing to address any additional measures still under consideration
in the first progress report.

Comment:	Section 11.4.2 includes a discussion of possible logistical
issues that may impact implementation of the low-sulfur oil strategy in
the northern New England states.  The SIP should either explain how this
might be relevant to RI’s ability to enact the MANE-VU low sulfur fuel
oil strategy or delete the discussion.  (EPA)

Response:	That discussion, which was not relevant to Rhode Island, has
been deleted.

		

Comment:	Table 11.2 in Section 11.5 (Source Retirement and Replacement
Schedules) lists sources that were shut down after 2002.  Are there any
other sources that are planning to shut down before 2018?  If
information is available for any other sources that are expected to shut
down before 2018, it should be discussed in this section.  (USDA)

Response:	RI DEM does not have definitive information about planned shut
down of additional facilities.

Comment:	A short discussion of the Clean Air Interstate Rule (CAIR) and
the recent court rulings would be helpful to provide the full breadth of
consultation issues and uncertainties experienced by MANE-VU.  (DOI) 
Section 11.3.1 should include a brief description of the CAIR remand
(EPA)

Response:	A discussion of CAIR was added in as Section 11.3.2.

Comment:	The numbering of footnotes throughout the document needs to be
checked (e.g., the text on page 65 refers to notes 11 and 12, but they
are numbered as 13 and 14).  On page 88, there is a reference to Figure
11.6.  The document does not contain a Figure 11.6.  (USDA)  RI should
fix the footnote numbering in Section 11.3.1 (EPA)

Response:	The references and numbering have been corrected.

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