  

Massachusetts Regional Haze

State Implementation Plan

August 9, 2012

Executive Summary

The federal Clean Air Act, in sections 169A and 169B, contains
requirements for the protection of visibility in 156 national parks,
forests and wilderness areas that have been federally designated as
Class I areas and include some of our nation’s most treasured public
lands.  Unfortunately, enjoyment of the scenic vistas in these pristine
areas is significantly impaired by regional haze.  In the eastern U.S.,
the average visual range has decreased from 106 miles (under natural
conditions) to 24 - 44 miles today.  

In 1999, the U.S. Environmental Protection Agency (EPA) issued
regulations known as the Regional Haze Rule, which requires states to
develop State Implementation Plans to reduce haze-causing pollution to
improve visibility in Class I areas.  The overall goal of the regional
haze program is to restore natural visibility conditions at Class I
areas by 2064.  

Regional haze is caused by fine particle pollution that impairs
visibility over a large region by scattering or absorbing light.  Fine
particle pollution also adversely impacts human health, especially for
children, the elderly, and people with heart or respiratory conditions. 
The Massachusetts Department of Environmental Protection (MassDEP) has
prepared this State Implementation Plan (SIP) to address Massachusetts
sources that contribute to regional haze.

Class I Areas

Although Massachusetts has no Class I areas, emissions from
Massachusetts sources contribute to visibility degradation in Class I
areas in several other states.  These include Lye Brook Wilderness Area
(Vermont), Great Gulf Wilderness Area (New Hampshire), Presidential
Range-Dry River Wilderness Area (New Hampshire), Acadia National Park
(Maine), Moosehorn Wildlife Refuge (Maine), and Roosevelt Campobello
International Park (Maine/Canada).

In the first round of SIPs, states with Class I areas must set
reasonable progress goals for 2018 for improving visibility in their
Class I areas.  States affecting Class I areas (including Massachusetts)
must submit SIPs with long-term strategies for meeting the 2018
reasonable progress goals.  SIPs also must include control measures for
certain existing sources placed into operation between 1962 and 1977
(known as Best Available Retrofit Technology or BART).  States must
update their SIPs in 2018 and every 10 years thereafter and must
evaluate progress every 5 years.  

Regional Planning Efforts

EPA established five regional planning organizations across the nation
to coordinate regional haze efforts.  Massachusetts is a member of one
of these regional organizations, the Mid-Atlantic Northeast Visibility
Union (MANE-VU), comprised of Mid-Atlantic and Northeast states, tribes,
and federal agencies.  Massachusetts developed this SIP by participating
in a regional planning process coordinated by MANE-VU.  Together, the
MANE-VU members established baseline and natural visibility conditions,
determined the primary contributors to regional haze, identified
reasonable progress goals and long-term strategies, and facilitated a
consultation process with states, other regional planning organizations,
and federal land managers.  

As a MANE-VU member state, Massachusetts adopted the “Statement of
MANE-VU Concerning a Request for a Course of Action by States Within
MANE-VU Toward Assuring Reasonable Progress” at the MANE-VU Board
meeting on June 7, 2007.  This Statement outlines a strategy for
reducing regional haze at MANE-VU Class I areas for the first ten-year
planning period and forms the basis for the actions Massachusetts has
included in this SIP.  

Elements of Massachusetts’ SIP for Regional Haze 

In accordance with 40 CFR 51.308(b), Massachusetts 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).  These actions include:  

Best Available Retrofit Technology - EPA’s Regional Haze Rule requires
the control of emissions from certain stationary sources placed into
operation between 1962 and 1977 through the implementation of Best
Available Retrofit Technology (BART) or an alternative to BART that
achieves greater emission reductions.  Massachusetts identified 5
electric generating unit (EGU) facilities, 1 municipal waste combustor,
and 1 industrial boiler as BART-eligible facilities whose 2002 emissions
(the baseline year for this SIP) contributed significantly to visibility
impairment.  For the EGUs, Massachusetts has adopted an Alternative to
BART program that achieves greater emissions reductions than
source-by-source BART.  For the municipal waste combustor, Massachusetts
has made a source-specific BART determination.  For the industrial
boiler, no BART determination is needed since the facility has accepted
an emissions cap that makes it no longer BART-eligible.  

Targeted EGU strategy - MANE-VU identified 167 EGU stacks at power
plants whose sulfur dioxide (SO2) emissions significantly impaired
visibility at one or more MANE-VU Class I areas, including stacks at 5
Massachusetts power plants.  Massachusetts agreed to reduce SO2
emissions from these specific power plants stacks by 90 percent from
2002 levels by 2018, or to pursue equivalent, alternative measures. 
Each of these EGUs already has reduced SO2 emissions due to
Massachusetts air quality regulations.  Based on MassDEP’s existing
regulations, and additional reductions that will result from MassDEP’s
Alternative to BART, EPA’s Mercury and Air Toxics Standard, and EGU
closures, MassDEP estimates that SO2 emissions in 2018 will be up to 87%
lower than 2002 emissions.

Sulfur in Fuel Oil - MANE-VU determined that states could
cost-effectively achieve significant reductions in SO2 emissions by
requiring lower sulfur content fuel oils, including #2 distillate oil
(home heating oil) and #4 and #6 residual oils (used in power plants and
industrial and commercial boilers).  Refineries already have made
significant capital investments to produce low and ultra-low sulfur
diesel, which is the same product as #2 distillate oil, and lower sulfur
residual oils also are readily available.  To implement the regional
MANE-VU low sulfur fuel oil strategy, MassDEP has adopted regulations
that lower allowable sulfur content in fuel oils, ultimately achieving
15 parts per million sulfur for #2 oil and 0.5 percent sulfur by weight
for #4 and #6 residual oils by 2018.  

The regulatory and technical basis for this proposed SIP is found in
Sections 1 – 7.  The prescriptive elements of this proposed SIP –
BART, reasonable progress goals, and long-term strategy – are found in
Sections 8 – 10.  

Table of Contents

  TOC \o "1-5" \h \z    HYPERLINK \l "_Toc329869099"  Executive Summary	
 PAGEREF _Toc329869099 \h  ii  

  HYPERLINK \l "_Toc329869100"  Table of Contents	  PAGEREF
_Toc329869100 \h  ii  

  HYPERLINK \l "_Toc329869101"  List of Figures	  PAGEREF _Toc329869101
\h  ii  

  HYPERLINK \l "_Toc329869102"  List of Tables	  PAGEREF _Toc329869102
\h  ii  

  HYPERLINK \l "_Toc329869103"  List of Appendices	  PAGEREF
_Toc329869103 \h  ii  

  HYPERLINK \l "_Toc329869104"  Acronyms and Abbreviations	  PAGEREF
_Toc329869104 \h  ii  

  HYPERLINK \l "_Toc329869105"  1.	Background and Overview of the
Federal Regional Haze Regulation	  PAGEREF _Toc329869105 \h  2  

  HYPERLINK \l "_Toc329869106"  1.2.	The Basics of Haze	  PAGEREF
_Toc329869106 \h  2  

  HYPERLINK \l "_Toc329869107"  1.3.	Regulatory Framework	  PAGEREF
_Toc329869107 \h  2  

  HYPERLINK \l "_Toc329869108"  History of Federal Regional Haze Rule	 
PAGEREF _Toc329869108 \h  2  

  HYPERLINK \l "_Toc329869109"  State Implementation Plan	  PAGEREF
_Toc329869109 \h  2  

  HYPERLINK \l "_Toc329869110"  2.	Regional Planning and State/Tribe and
Federal Land Manager Coordination	  PAGEREF _Toc329869110 \h  2  

  HYPERLINK \l "_Toc329869111"  2.2.	Regional Planning	  PAGEREF
_Toc329869111 \h  2  

  HYPERLINK \l "_Toc329869112"  2.3.	Mid-Atlantic/Northeast Visibility
Union (MANE-VU)	  PAGEREF _Toc329869112 \h  2  

  HYPERLINK \l "_Toc329869113"  2.4.	Class I Areas Within MANE-VU	 
PAGEREF _Toc329869113 \h  2  

  HYPERLINK \l "_Toc329869114"  2.5.	Area of Influence for MANE-VU Class
I Areas	  PAGEREF _Toc329869114 \h  2  

  HYPERLINK \l "_Toc329869115"  2.6.	Massachusetts Impact on MANE-VU
Class I Areas	  PAGEREF _Toc329869115 \h  2  

  HYPERLINK \l "_Toc329869116"  2.7.	Regional Haze Planning after the
Remand of CAIR	  PAGEREF _Toc329869116 \h  2  

  HYPERLINK \l "_Toc329869117"  2.8.	Regional Consultation and the
“Ask”	  PAGEREF _Toc329869117 \h  2  

  HYPERLINK \l "_Toc329869118"  2.9.	Meeting the “Ask” – MANE-VU
States	  PAGEREF _Toc329869118 \h  2  

  HYPERLINK \l "_Toc329869119"  2.10.	Meeting the “Ask” –
Massachusetts	  PAGEREF _Toc329869119 \h  2  

  HYPERLINK \l "_Toc329869120"  2.11.	Meeting the “Ask” – States
Outside of MANE-VU	  PAGEREF _Toc329869120 \h  2  

  HYPERLINK \l "_Toc329869121"  2.12.	Technical Ramifications of
Differing Approaches	  PAGEREF _Toc329869121 \h  2  

  HYPERLINK \l "_Toc329869122"  2.13.	Federal Land Manager Coordination	
 PAGEREF _Toc329869122 \h  2  

  HYPERLINK \l "_Toc329869123"  3.	Assessment of Baseline AND Natural
Conditions	  PAGEREF _Toc329869123 \h  2  

  HYPERLINK \l "_Toc329869124"  3.2.	Calculation Methodology	  PAGEREF
_Toc329869124 \h  2  

  HYPERLINK \l "_Toc329869125"  3.3.	MANE-VU Baseline and Natural
Visibility	  PAGEREF _Toc329869125 \h  2  

  HYPERLINK \l "_Toc329869126"  4.	Monitoring Strategy	  PAGEREF
_Toc329869126 \h  2  

  HYPERLINK \l "_Toc329869127"  4.2.	IMPROVE Program Objectives	 
PAGEREF _Toc329869127 \h  2  

  HYPERLINK \l "_Toc329869128"  4.3.	Monitoring Information for
Massachusetts	  PAGEREF _Toc329869128 \h  2  

  HYPERLINK \l "_Toc329869129"  4.4.	Monitoring Information for MANE-VU
Class I Areas Impacted by Emissions from Massachusetts	  PAGEREF
_Toc329869129 \h  2  

  HYPERLINK \l "_Toc329869130"  Acadia National Park, Maine	  PAGEREF
_Toc329869130 \h  2  

  HYPERLINK \l "_Toc329869131"  Great Gulf Wilderness Area, New
Hampshire	  PAGEREF _Toc329869131 \h  2  

  HYPERLINK \l "_Toc329869132"  Presidential Range - Dry River
Wilderness, New Hampshire	  PAGEREF _Toc329869132 \h  2  

  HYPERLINK \l "_Toc329869133"  Lye Brook Wilderness, Vermont	  PAGEREF
_Toc329869133 \h  2  

  HYPERLINK \l "_Toc329869134"  Moosehorn Wilderness Area, Maine	 
PAGEREF _Toc329869134 \h  2  

  HYPERLINK \l "_Toc329869135"  Roosevelt/Campobello International Park,
New Brunswick, Canada	  PAGEREF _Toc329869135 \h  2  

  HYPERLINK \l "_Toc329869136"  5.	Modeling	  PAGEREF _Toc329869136 \h 
2  

  HYPERLINK \l "_Toc329869137"  5.2.	Meteorology	  PAGEREF _Toc329869137
\h  2  

  HYPERLINK \l "_Toc329869138"  5.3.	Emissions Data Preparations	 
PAGEREF _Toc329869138 \h  2  

  HYPERLINK \l "_Toc329869139"  5.4.	Model Platforms	  PAGEREF
_Toc329869139 \h  2  

  HYPERLINK \l "_Toc329869140"  CMAQ	  PAGEREF _Toc329869140 \h  2  

  HYPERLINK \l "_Toc329869141"  REMSAD	  PAGEREF _Toc329869141 \h  2  

  HYPERLINK \l "_Toc329869142"  CALGRID	  PAGEREF _Toc329869142 \h  2  

  HYPERLINK \l "_Toc329869143"  CALPUFF	  PAGEREF _Toc329869143 \h  2  

  HYPERLINK \l "_Toc329869144"  6.	Emissions Inventory	  PAGEREF
_Toc329869144 \h  2  

  HYPERLINK \l "_Toc329869145"  6.2.	Baseline and Future Year Emission
Inventories for Modeling	  PAGEREF _Toc329869145 \h  2  

  HYPERLINK \l "_Toc329869146"  MANE-VU Regional Baseline Inventory	 
PAGEREF _Toc329869146 \h  2  

  HYPERLINK \l "_Toc329869147"  Massachusetts Baseline Inventory	 
PAGEREF _Toc329869147 \h  2  

  HYPERLINK \l "_Toc329869148"  Future Year Emission Control Inventories
  PAGEREF _Toc329869148 \h  2  

  HYPERLINK \l "_Toc329869149"  6.3.	Emission Processor Selection and
Configuration	  PAGEREF _Toc329869149 \h  2  

  HYPERLINK \l "_Toc329869150"  6.4.	Inventories for Specific Source
Types	  PAGEREF _Toc329869150 \h  2  

  HYPERLINK \l "_Toc329869151"  Stationary Point Sources	  PAGEREF
_Toc329869151 \h  2  

  HYPERLINK \l "_Toc329869152"  6.5.	Electric Generating Units	  PAGEREF
_Toc329869152 \h  2  

  HYPERLINK \l "_Toc329869153"  6.6.	Non-EGU Point Sources	  PAGEREF
_Toc329869153 \h  2  

  HYPERLINK \l "_Toc329869154"  Stationary Area Sources	  PAGEREF
_Toc329869154 \h  2  

  HYPERLINK \l "_Toc329869155"  Non-Road Mobile Sources	  PAGEREF
_Toc329869155 \h  2  

  HYPERLINK \l "_Toc329869156"  On-Road Mobile Sources	  PAGEREF
_Toc329869156 \h  2  

  HYPERLINK \l "_Toc329869157"  Biogenic Emission Sources	  PAGEREF
_Toc329869157 \h  2  

  HYPERLINK \l "_Toc329869158"  6.7.	Summary of MANE-VU 2002 and 2018
Emissions Inventory	  PAGEREF _Toc329869158 \h  2  

  HYPERLINK \l "_Toc329869159"  6.8.	Summary of Massachusetts 2002 Base
and 2018 Projected Emissions and Reductions	  PAGEREF _Toc329869159 \h 
2  

  HYPERLINK \l "_Toc329869160"  7.	Understanding the Sources of
Visibility-Impairing Pollutants	  PAGEREF _Toc329869160 \h  2  

  HYPERLINK \l "_Toc329869161"  7.2.	Visibility-Impairing Pollutants	 
PAGEREF _Toc329869161 \h  2  

  HYPERLINK \l "_Toc329869162"  Contributing States and Regions	 
PAGEREF _Toc329869162 \h  2  

  HYPERLINK \l "_Toc329869163"  7.3.	Emissions Sources and
Characteristics	  PAGEREF _Toc329869163 \h  2  

  HYPERLINK \l "_Toc329869164"  Sulfur Dioxide (SO2)	  PAGEREF
_Toc329869164 \h  2  

  HYPERLINK \l "_Toc329869165"  Volatile Organic Compounds (VOCs)	 
PAGEREF _Toc329869165 \h  2  

  HYPERLINK \l "_Toc329869166"  Oxides of Nitrogen (NOX)	  PAGEREF
_Toc329869166 \h  2  

  HYPERLINK \l "_Toc329869167"  Primary Particle Matter (PM10 and PM2.5)
  PAGEREF _Toc329869167 \h  2  

  HYPERLINK \l "_Toc329869168"  Ammonia Emissions (NH3)	  PAGEREF
_Toc329869168 \h  2  

  HYPERLINK \l "_Toc329869169"  8.	Best Available Retrofit Technology	 
PAGEREF _Toc329869169 \h  2  

  HYPERLINK \l "_Toc329869170"  8.2.	BART Overview	  PAGEREF
_Toc329869170 \h  2  

  HYPERLINK \l "_Toc329869171"  8.3.	BART-Eligible Sources in
Massachusetts	  PAGEREF _Toc329869171 \h  2  

  HYPERLINK \l "_Toc329869172"  8.4.	Determination of which
BART-eligible sources are subject to BART	  PAGEREF _Toc329869172 \h  2 


  HYPERLINK \l "_Toc329869173"  8.5.	Pollutants Covered by BART	 
PAGEREF _Toc329869173 \h  2  

  HYPERLINK \l "_Toc329869174"  8.6.	Modeling of BART Visibility Impacts
  PAGEREF _Toc329869174 \h  2  

  HYPERLINK \l "_Toc329869175"  8.7.	Visibility Impacts of Massachusetts
BART-Eligible Sources	  PAGEREF _Toc329869175 \h  2  

  HYPERLINK \l "_Toc329869176"  8.8.	Overview of Massachusetts
BART-Eligible Sources	  PAGEREF _Toc329869176 \h  2  

  HYPERLINK \l "_Toc329869177"  “Cap Out” Source	  PAGEREF
_Toc329869177 \h  2  

  HYPERLINK \l "_Toc329869178"  Sources that Contribute to Visibility
Impairment	  PAGEREF _Toc329869178 \h  2  

  HYPERLINK \l "_Toc329869179"  8.9.	BART Determination for Wheelabrator
- Saugus	  PAGEREF _Toc329869179 \h  2  

  HYPERLINK \l "_Toc329869180"  8.10.	Alternative to BART for EGUs	 
PAGEREF _Toc329869180 \h  2  

  HYPERLINK \l "_Toc329869181"  8.11.	BART for PM10 Emissions	  PAGEREF
_Toc329869181 \h  2  

  HYPERLINK \l "_Toc329869182"  8.12.	Reasonably Attributable Visibility
Impairment	  PAGEREF _Toc329869182 \h  2  

  HYPERLINK \l "_Toc329869183"  9.	Reasonable Progress Goals	  PAGEREF
_Toc329869183 \h  2  

  HYPERLINK \l "_Toc329869184"  10.	Long-Term Strategy	  PAGEREF
_Toc329869184 \h  2  

  HYPERLINK \l "_Toc329869185"  10.2.	Overview of the Long-Term Strategy
Development Process	  PAGEREF _Toc329869185 \h  2  

  HYPERLINK \l "_Toc329869186"  10.3.	Technical Basis for Strategy
Development	  PAGEREF _Toc329869186 \h  2  

  HYPERLINK \l "_Toc329869187"  10.4.	2018 Emission Reductions Due to
Ongoing Air Pollution Controls	  PAGEREF _Toc329869187 \h  2  

  HYPERLINK \l "_Toc329869188"  EGU Emissions Controls Expected by 2018	
 PAGEREF _Toc329869188 \h  2  

  HYPERLINK \l "_Toc329869189"  Non-EGU Point Source Controls Expected
by 2018	  PAGEREF _Toc329869189 \h  2  

  HYPERLINK \l "_Toc329869190"  Area Source Controls Expected by 2018	 
PAGEREF _Toc329869190 \h  2  

  HYPERLINK \l "_Toc329869191"  Onroad Mobile Source Controls Expected
by 2018	  PAGEREF _Toc329869191 \h  2  

  HYPERLINK \l "_Toc329869192"  Nonroad Sources Controls Expected by
2018	  PAGEREF _Toc329869192 \h  2  

  HYPERLINK \l "_Toc329869193"  Additional Controls Analyzed as Part of
Ozone SIPs	  PAGEREF _Toc329869193 \h  2  

  HYPERLINK \l "_Toc329869194"  10.5.	Additional Reasonable Strategies	 
PAGEREF _Toc329869194 \h  2  

  HYPERLINK \l "_Toc329869195"  Rationale for Determining Reasonable
Controls	  PAGEREF _Toc329869195 \h  2  

  HYPERLINK \l "_Toc329869196"  MANE-VU Statement of June 20, 2007	 
PAGEREF _Toc329869196 \h  2  

  HYPERLINK \l "_Toc329869197"  Best Available Retrofit Technology	 
PAGEREF _Toc329869197 \h  2  

  HYPERLINK \l "_Toc329869198"  Low-Sulfur Fuel Oil Strategy	  PAGEREF
_Toc329869198 \h  2  

  HYPERLINK \l "_Toc329869199"  Targeted EGU Strategy	  PAGEREF
_Toc329869199 \h  2  

  HYPERLINK \l "_Toc329869200"  10.6.	Source Retirement and Replacement
Schedules	  PAGEREF _Toc329869200 \h  2  

  HYPERLINK \l "_Toc329869201"  10.7.	Measures to Mitigate the Impacts
of Construction Activities	  PAGEREF _Toc329869201 \h  2  

  HYPERLINK \l "_Toc329869202"  10.8.	Agricultural and Forestry Smoke
Management	  PAGEREF _Toc329869202 \h  2  

  HYPERLINK \l "_Toc329869203"  Regulation of Outdoor Hydronic Heaters	 
PAGEREF _Toc329869203 \h  2  

  HYPERLINK \l "_Toc329869204"  10.9.	Estimated Impacts of Long-Term
Strategy on Visibility	  PAGEREF _Toc329869204 \h  2  

  HYPERLINK \l "_Toc329869205"  Additional Measures Included in Best and
Final Modeling	  PAGEREF _Toc329869205 \h  2  

  HYPERLINK \l "_Toc329869206"  Visibility Impacts of Additional
Reasonable Controls from Best and Final Modeling	  PAGEREF _Toc329869206
\h  2  

  HYPERLINK \l "_Toc329869207"  10.10.	Massachusetts’ Share of
Emissions Reduction	  PAGEREF _Toc329869207 \h  2  

  HYPERLINK \l "_Toc329869208"  10.11.	Emission Limitations and
Compliance Schedules	  PAGEREF _Toc329869208 \h  2  

  HYPERLINK \l "_Toc329869209"  10.12.	Enforceability of Emission
Limitations and Control Measures	  PAGEREF _Toc329869209 \h  2  

  HYPERLINK \l "_Toc329869210"  10.13.	Prevention of Significant
Deterioration	  PAGEREF _Toc329869210 \h  2  

 

List of Figures 

  TOC \h \z \c "Figure"    HYPERLINK \l "_Toc329869211"  Figure 1:
Locations of Federally Protected Mandatory Class I Areas	  PAGEREF
_Toc329869211 \h  2  

  HYPERLINK \l "_Toc329869212"  Figure 2: US EPA Designated Regional
Planning Organizations	  PAGEREF _Toc329869212 \h  2  

  HYPERLINK \l "_Toc329869213"  Figure 3: Class I Areas within MANE-VU	 
PAGEREF _Toc329869213 \h  2  

  HYPERLINK \l "_Toc329869214"  Figure 4: Map of CAIR States	  PAGEREF
_Toc329869214 \h  2  

  HYPERLINK \l "_Toc329869215"  Figure 5: MANE-VU Principles for
Regional Haze Planning	  PAGEREF _Toc329869215 \h  2  

  HYPERLINK \l "_Toc329869216"  Figure 7: Acadia National Park on Clear
and Hazy Days	  PAGEREF _Toc329869216 \h  2  

 HYPERLINK "July 2012 Draft Final Regional Haze SIP.doc" \l
"_Toc329869217" Figure 6: Map of Acadia National Park Showing	  PAGEREF
_Toc329869217 \h  2  

  HYPERLINK \l "_Toc329869218"  Figure 8: Map of Great Gulf and
Presidential Range - Dry River Wilderness Areas Showing IMPROVE Monitor
Location	  PAGEREF _Toc329869218 \h  2  

  HYPERLINK \l "_Toc329869219"  Figure 9: Great Gulf Wilderness Area on
Clear and Hazy Days	  PAGEREF _Toc329869219 \h  2  

  HYPERLINK \l "_Toc329869220"  Figure 10: Location of Lye Brook
Wilderness Monitor	  PAGEREF _Toc329869220 \h  2  

  HYPERLINK \l "_Toc329869221"  Figure 11: Lye Brook Wilderness Area on
Clear and Hazy Days	  PAGEREF _Toc329869221 \h  2  

  HYPERLINK \l "_Toc329869222"  Figure 12: Map of the Baring and Edmunds
Divisions of the Moosehorn National Wildlife Refuge Showing the IMPROVE
Monitor Location	  PAGEREF _Toc329869222 \h  2  

  HYPERLINK \l "_Toc329869223"  Figure 13: Moosehorn Wilderness Area on
a Clear and a Hazy Day	  PAGEREF _Toc329869223 \h  2  

  HYPERLINK \l "_Toc329869224"  Figure 14: Map of Roosevelt/Campobello
International Park	  PAGEREF _Toc329869224 \h  2  

  HYPERLINK \l "_Toc329869225"  Figure 15: Roosevelt/Campobello
International Park on Clear and Hazy Days	  PAGEREF _Toc329869225 \h  2 


  HYPERLINK \l "_Toc329869226"  Figure 16: Modeling domains used in
MANE-VU air quality modeling studies with CMAQ.	  PAGEREF _Toc329869226
\h  2  

  HYPERLINK \l "_Toc329869227"  Figure 17: Examples of processed
model-ready emissions: a) SO2 from Point, b) NO2 from Area, c) NO2 from
On-road, d) NO2 from Non-road, e) ISOP from Biogenic, f) SO2 from all
source categories	  PAGEREF _Toc329869227 \h  2  

  HYPERLINK \l "_Toc329869228"  Figure 18: Contributions to PM2.5
Extinction at Seven Class I Sites	  PAGEREF _Toc329869228 \h  2  

  HYPERLINK \l "_Toc329869229"  Figure 19: Ranked state percent sulfate
contributions to Northeast Class I receptors based on emissions divided
by distance (Q/d) results	  PAGEREF _Toc329869229 \h  2  

  HYPERLINK \l "_Toc329869230"  Figure 20: Ranked state percent sulfate
contributions to Mid-Atlantic Class I receptors based on emissions
divided by distance (Q/d) results	  PAGEREF _Toc329869230 \h  2  

  HYPERLINK \l "_Toc329869231"  Figure 21: Modeled 2002 Contributions to
Sulfate by State at Brigantine	  PAGEREF _Toc329869231 \h  2  

  HYPERLINK \l "_Toc329869232"  Figure 22: Modeled 2002 Contributions to
Sulfate by State at Lye Brook	  PAGEREF _Toc329869232 \h  2  

  HYPERLINK \l "_Toc329869233"  Figure 23: Modeled 2002 Contributions to
Sulfate by State at Great Gulf and Presidential Range/Dry River
Wilderness	  PAGEREF _Toc329869233 \h  2  

  HYPERLINK \l "_Toc329869234"  Figure 24: Modeled 2002 Contributions to
Sulfate by State at Acadia	  PAGEREF _Toc329869234 \h  2  

  HYPERLINK \l "_Toc329869235"  Figure 25: Modeled 2002 Contributions to
Sulfate by State at Moosehorn and Roosevelt Campobello International
Park	  PAGEREF _Toc329869235 \h  2  

  HYPERLINK \l "_Toc329869236"  Figure 26: Modeled 2002 Contributions to
Sulfate by State at Shenandoah	  PAGEREF _Toc329869236 \h  2  

  HYPERLINK \l "_Toc329869237"  Figure 27: Modeled 2002 Contributions to
Sulfate by State at Dolly Sods	  PAGEREF _Toc329869237 \h  2  

  HYPERLINK \l "_Toc329869238"  Figure 28: Trends in Annual Sulfur
Dioxide Emissions by State	  PAGEREF _Toc329869238 \h  2  

  HYPERLINK \l "_Toc329869239"  Figure 29: 2002 Sulfur Dioxide Emissions
(SO2) by State	  PAGEREF _Toc329869239 \h  2  

  HYPERLINK \l "_Toc329869240"  Figure 30: 2002 Volatile Organic Carbon
(VOC) Emissions by State	  PAGEREF _Toc329869240 \h  2  

  HYPERLINK \l "_Toc329869241"  Figure 31: Trends in Annual Nitrogen
Oxide (NOx) Emissions by State	  PAGEREF _Toc329869241 \h  2  

  HYPERLINK \l "_Toc329869242"  Figure 32: 2002 Nitrogen Oxide (NOx)
Emissions by State	  PAGEREF _Toc329869242 \h  2  

  HYPERLINK \l "_Toc329869243"  Figure 33: Trends in Primary Coarse
Particle (PM10) Emissions by State	  PAGEREF _Toc329869243 \h  2  

  HYPERLINK \l "_Toc329869244"  Figure 34: Trends in Primary Fine
Particle (PM2.5) Emissions by State	  PAGEREF _Toc329869244 \h  2  

  HYPERLINK \l "_Toc329869245"  Figure 35: Wood Smoke Source Regional
Aggregations	  PAGEREF _Toc329869245 \h  2  

  HYPERLINK \l "_Toc329869246"  Figure 36: 2002 Primary PM10 Emissions
by State	  PAGEREF _Toc329869246 \h  2  

  HYPERLINK \l "_Toc329869247"  Figure 37: 2002 Primary PM2.5 Emissions
by State	  PAGEREF _Toc329869247 \h  2  

  HYPERLINK \l "_Toc329869248"  Figure 38: Trends in Ammonia Emissions
by State	  PAGEREF _Toc329869248 \h  2  

  HYPERLINK \l "_Toc329869249"  Figure 39: 2002 NH3 Emissions by State	 
PAGEREF _Toc329869249 \h  2  

  HYPERLINK \l "_Toc329869250"  Figure 40: Average Change in 24-hr PM2.5
Due to Low Sulfur Fuel Strategies Relative to OTB/OTW (g/m3)	 
PAGEREF _Toc329869250 \h  2  

  HYPERLINK \l "_Toc329869251"  Figure 41: 167 Targeted EGU Stacks
Affecting MANE-VU Class I Areas	  PAGEREF _Toc329869251 \h  2  

  HYPERLINK \l "_Toc329869252"  Figure 42: Average Change in 24-hr PM2.5
due to 90 Percent Reduction in SO2 Emissions from 167 EGU Stacks
Affecting MANE-VU	  PAGEREF _Toc329869252 \h  2  

  HYPERLINK \l "_Toc329869253"  Figure 43: Projected Visibility
Improvement at Acadia National Park Based on 2018 Visibility Projections
  PAGEREF _Toc329869253 \h  2  

  HYPERLINK \l "_Toc329869254"  Figure 44: Projected Visibility
Improvement at Great Gulf Wilderness Area Based on 2018 Visibility
Modeling	  PAGEREF _Toc329869254 \h  2  

  HYPERLINK \l "_Toc329869255"  Figure 45: Projected Visibility
Improvement at Lye Brook Wilderness Area Based on 2018 Visibility
Modeling	  PAGEREF _Toc329869255 \h  2  

  HYPERLINK \l "_Toc329869256"  Figure 46: Projected Visibility
Improvement at Moosehorn Wilderness Area Based on 2018 Visibility
Modeling 	  PAGEREF _Toc329869256 \h  2  

 List of Tables

  TOC \h \z \c "Table"    HYPERLINK \l "_Toc329869257"  Table 1: MANE-VU
Members	  PAGEREF _Toc329869257 \h  2  

  HYPERLINK \l "_Toc329869258"  Table 2: States that Contribute to
Visibility Impairment at One or More of the MANE-VU Class I Areas of
Acadia, Moosehorn, Roosevelt-Campobello, Great Gulf, Presidential
Range-Dry River, Lye Brook, and Brigantine	  PAGEREF _Toc329869258 \h  2
 

  HYPERLINK \l "_Toc329869259"  Table 3: Class I Federal Areas Affected
by Emissions from Massachusetts	  PAGEREF _Toc329869259 \h  2  

  HYPERLINK \l "_Toc329869260"  Table 4: IMPROVE Monitors for MANE-VU
Class I Areas	  PAGEREF _Toc329869260 \h  2  

  HYPERLINK \l "_Toc329869261"  Table 5: Summary of Baseline Visibility
and Natural Visibility Conditions for the 20 Percent Best and 20 Percent
Worst Visibility Days at MANE-VU Class I Areas	  PAGEREF _Toc329869261
\h  2  

  HYPERLINK \l "_Toc329869262"  Table 6: MANE-VU 2002 Emissions
Inventory Summary (tons)	  PAGEREF _Toc329869262 \h  2  

  HYPERLINK \l "_Toc329869263"  Table 7: MANE-VU 2018 Emissions
Inventory Summary (in tons)	  PAGEREF _Toc329869263 \h  2  

  HYPERLINK \l "_Toc329869264"  Table 8: Massachusetts 2002 Base Year
and 2018 Projected Emissions and Reductions (in tons)	  PAGEREF
_Toc329869264 \h  2  

  HYPERLINK \l "_Toc329869265"  Table 9: Percent of Annual Average
Modeled Sulfate Due to Emissions from Listed States	  PAGEREF
_Toc329869265 \h  2  

  HYPERLINK \l "_Toc329869266"  Table 10: BART-Eligible Facilities in
Massachusetts	  PAGEREF _Toc329869266 \h  2  

  HYPERLINK \l "_Toc329869267"  Table 11: CALPUFF Visibility Modeling
Results using MM5 Platform	  PAGEREF _Toc329869267 \h  2  

  HYPERLINK \l "_Toc329869268"  Table 12: CALPUFF Visibility Modeling
Results using NWS Platform	  PAGEREF _Toc329869268 \h  2  

  HYPERLINK \l "_Toc329869269"  Table 13: Massachusetts Sources with De
Minimis Visibility Impact	  PAGEREF _Toc329869269 \h  2  

  HYPERLINK \l "_Toc329869270"  Table 14: Overview of BART-Eligible EGUs
& MWCs	  PAGEREF _Toc329869270 \h  2  

  HYPERLINK \l "_Toc329869271"  Table 15: MANE-VU BART Workgroup
Recommended BART Emission Limits for SO2 and NOx for non-CAIR EGUs	 
PAGEREF _Toc329869271 \h  2  

  HYPERLINK \l "_Toc329869272"  Table 16: BART Benchmark for SO2	 
PAGEREF _Toc329869272 \h  2  

  HYPERLINK \l "_Toc329869273"  Table 17:  Alternative to BART for SO2	 
PAGEREF _Toc329869273 \h  2  

  HYPERLINK \l "_Toc329869274"  Table 18: BART Benchmark for NOx	 
PAGEREF _Toc329869274 \h  2  

  HYPERLINK \l "_Toc329869275"  Table 19:  Alternative to BART for NOx	 
PAGEREF _Toc329869275 \h  2  

  HYPERLINK \l "_Toc329869276"  Table 20: Massachusetts PM10 BART
Sources, Emissions and Controls	  PAGEREF _Toc329869276 \h  2  

  HYPERLINK \l "_Toc329869277"  Table 21: Uniform Rate of Progress
Calculation (all values in deciviews)	  PAGEREF _Toc329869277 \h  2  

  HYPERLINK \l "_Toc329869278"  Table 22: Reasonable Progress Goals -
20% Worst Days (all values in deciviews)	  PAGEREF _Toc329869278 \h  2  

  HYPERLINK \l "_Toc329869279"  Table 23: Reasonable Progress Goals -
20% Best Days (all values in deciviews)	  PAGEREF _Toc329869279 \h  2  

  HYPERLINK \l "_Toc329869280"  Table 24: Summary of Results from the
Four-Factor Analysis	  PAGEREF _Toc329869280 \h  2  

  HYPERLINK \l "_Toc329869281"  Table 25: Massachusetts Targeted EGUs	 
PAGEREF _Toc329869281 \h  2  

 

List of Appendices

Contributions to Regional Haze in the Northeast and Mid-Atlantic United
States: Mid-Atlantic/Northeast Visibility Union (MANE-VU) Contribution
Assessment. NESCAUM, August 2006.

Final Interim Principles for Regional Planning. MANE-VU, June 2006.

  Statement(s) of the Mid-Atlantic/Northeast Visibility Union (MANE-VU)
Concerning a Request for a Course of Action by States/EPA Within/Outside
MANE-VU Toward Assuring Reasonable Progress. MANE-VU, June 7, 2006.

  Federal Land Manager and EPA Comments and State Responses on
Pre-Public Hearing Draft Massachusetts Regional Haze SIP (Appendices D-1
– D5), Public Comments and State Responses on Public Hearing Draft SIP
(Appendices D6 – D15), and Public Comments and State Responses on
Public Hearing Draft SIP Revision (Appendices D16 – D31).

  Baseline and Natural Background Visibility Conditions: Considerations
and Proposed Approach to the Calculation of Baseline and Natural
Background Visibility Conditions at MANE-VU Class I Areas. NESCAUM,
December 2006.

  MANE-VU Modeling for Reasonable Progress Goals: Model Performance
Evaluation, Pollution Apportionment, and Control Measure Benefits.
NESCAUM, February 2008.

2018 Visibility Projections. NESCAUM, March 2008.

  Meteorological Modeling Using Penn State/NCAR 5th Generation Mesoscale
Model (MM5). NYSDEC TSD-1a, February 2006.

  Emissions Processing for the Revised 2002 OTC Regional and Urban 12 km
Base Case Simulations. NYSDEC TSD-1c, September 2006.

  CMAQ Model Performance and Assessment, 8-Hr OTC Ozone Modeling. NYSDEC
TSD-1e, February 2006.

  Eight Hour Ozone Modeling using the SMOKE/CMAQ system. NYSDEC TSD-1d,
February 2006.

  Modeling Protocol for the OTC CALGRID Screening-Level Modeling
Platform for the Evaluation of Ozone. NHDES, May 2007.

  Technical Support Document for 2002 MANE-VU SIP Modeling Inventories,
Version 3. E.H. Pechan & Associates for MANE-VU, November 2006.

  Development of Emissions Projections for 2009, 2012, 2018 for Non-EGU
Point, Area, and Nonroad Sources in the MANE-VU Region. MACTEC, February
2007.

  Development of MANE-VU Mobile Source Projection Inventories for
SMOKE/MOBILE6 Application. NESCAUM, June 2006.

  Regional Haze and Visibility in the Northeast and Mid-Atlantic States.
NESCAUM, January 2001.

  Technical Support Document on Agricultural and Forestry Smoke
Management in the MANE-VU Region. MANE-VU, September 2006.

  Five Factor Analysis of BART Eligible Sources: Survey of Options for
Conducting BART Determinations. NESCAUM, June 2007.

R-1.	CalPuff BART Modeling Results (MM5)

R-2.	CalPuff BART Modeling Results (NWS)

  Comparison of CAIR and CAIR Plus Proposal using the Integrated
Planning Model®. ICF, May 2007.

  Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I
Areas. MACTEC, July 2007.

T-1. Addendum for Residual Oil.  MANE-VU, April 2011.

  Assessment of Control Technology Options for BART-Eligible Sources:
Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and
Pulp Facilities. NESCAUM, March 2005.

  The Nature of the Fine Particle and Regional Haze Air Quality Problems
in the MANE-VU Region:  A Conceptual Description. NESCAUM, November
2006.  

  Documentation of 2018 Emissions from Electric Generating Units in the
Eastern U.S. for MANE-VU’s Regional Haze Modeling. Alpine Geophysics,
April 2008.

  Technical Support Document on Measures to Mitigate the Visibility
Impacts of Construction Activities in the MANE-VU Region. MANE-VU,
October 2006.

  Low Sulfur Heating Oil in the Northeast States:  An Overview of
Benefits, Costs, and Implementation Issues.  NESCAUM, December 2005.

  SNCR Optimization Report, Wheelabrator Saugus Inc., WTE Units 1 & 2,
Two 750 TPD MSW Combustors. Fuel Tech, January 2010.

AA. Public Health Benefits of Reducing Ground-level Ozone and Fine
Particle matter in the Northeast U.S. – A Benefits Mapping and
Analysis Program (BenMAP) Study. NESCAUM, January 2008.

BB.  Approval of General Electric Aviation NOx Reasonably Available
Control Technology (RACT) Modified Emission Control Plan.  MassDEP,
March 2011.

CC.  310 CMR 7.26(50) through (54): Outdoor Hydronic Heaters.  MassDEP,
December 2008.

DD.  310 CMR 7.29, Emissions Standards for Power Plants. MassDEP

EE.   Mt. Tom Station - Amended Emission Control Plan Final Approval.
MassDEP, May 2009.

FF.   Salem Harbor – Amended Emission Control Plan Final Approval.
MassDEP, March 2012.

GG.  Brayton Point – Amended Emission Control Plan Final Approval.
MassDEP, April 2012.

HH.  Somerset Power – Letter Revoking Permits. MassDEP, June 2011.

II.     310 CMR 7.05: Fuels All Districts. MassDEP, August 2012.

JJ.	Wheelabrator-Saugus – Emission Control Plan Modified Final
Approval. MassDEP, March 2012  

Acronyms and Abbreviations

ACAD1		Acadia National Park IMPROVE monitor

BART		Best Available Retrofit Technology

BEIS-3		Biogenic Emission Inventory System (3 version 0.9)

BOTW 		Beyond on the Way (controls)

BTU 		British Thermal Unit

CAA 		Clean Air Act

CAIR 		Clean Air Interstate Rule

CALGRID	California Grid Model

CEED		Center for Energy and Economic Development

CENRAP	Central Regional Air Planning Association

CERR 		Consolidated Emission Reporting Rule

CFR 		Code of Federal Regulations

CMAQ 		Community Multi-scale Air Quality Modeling System

CO 		Carbon Monoxide

dv 		Deciview

EGU 		Electric Generating Unit

EPA 		Environmental Protection Agency

FLM		Federal Land Manager

GCVTC		Grand Canyon Visibility Transport Commission

GRGU1	Great Gulf Wilderness Area IMPROVE monitor; also monitors
Presidential Range/Dry River Wilderness Area

HAP		Hazardous Air Pollutant

ICI 		Industrial/Commercial/Institutional

IMPROVE	Interagency Monitoring of Protected Visual Environments

IPM		Integrated Planning Model

LADCO		Lake Michigan Air Directors Consortium

LYBR1		Lye Brook Wilderness Area IMPROVE monitor

MassDEP	Massachusetts Department of Environmental Protection

MANE-VU 	Mid-Atlantic/Northeast Visibility Union

MARAMA 	Mid-Atlantic Regional Air Management Association

MM5 		Mesoscale Meteorological Model

MMBtu 		Million British Thermal Units

MOOS1	Moosehorn Wilderness Area IMPROVE monitor; also monitors
Roosevelt/Campobello International Park

MOBILE6.2 	EPA’s On-Road Mobile Source Emissions Estimation Model

MRPO		Midwest Regional Planning Organization

MW 		Megawatt

MWh 		Megawatt Hour

MWC		Municipal Waste Combustor

N/A		Not Applicable

NAAQS		National Ambient Air Quality Standards

NCAR		National Center for Atmospheric Research

NEI		National Emissions Inventory

NET		National Emissions Trend

NESCAUM 	Northeast States for Coordinated Air Use Management

NH3		Ammonia

NOx 		Oxides of Nitrogen

NONROAD	EPA’s Non-Road Emissions Estimation Model 2005 Version

NSPS 		New Source Performance Standards

NTI		National Toxics Inventory

NYSDEC 	New York State Department of Environmental Conservation

NWS		National Weather Service

OC		Organic Carbon

OTC 		Ozone Transport Commission

OTB/W		On the Books/On the Way (controls)

PM2.5 	Fine Particulate Matter; particles with an aerodynamic diameter
less than or equal to a nominal 2.5 micrometers

PM10 		Particles with an aerodynamic diameter less than or equal to a
nominal 10 micrometers

QA		Quality Assurance

RACT		Reasonably Available Control Technology

REMSAD	Regional Modeling System for Aerosols and Deposition

RFP 		Reasonable Further Progress

RH		Regional Haze

RPO		Regional Planning Organization

SIP		State Implementation Plan

SLAMS/ 	State & Local Air Monitoring System and

NAMS		National Air Monitoring System

SCC		Source Category Code

SMOKE		Sparse Matrix Operator Kernel Emissions

SMP		Smoke Management Plan

SOA 		Secondary Organic Aerosol

SO2		Sulfur Dioxide

TPY		Tons per year

TSC		Technical Support Committee (of MANE-VU)

TSD		Technical Support Document

USEPA		United States Environmental Protection Agency

UMD		University of Maryland

VIEWS		Visibility Information Exchange Web System

VISTAS		Visibility Improvement State and Tribal Association of the
Southeast

VOC		Volatile Organic Compound

WRAP		Western Regional Air Partnership

Background and Overview of the Federal Regional Haze Regulation

The Basics of Haze 

Regional haze is visibility impairment caused by the cumulative emission
of air pollutants from numerous sources over a wide geographic area. 
The primary cause of regional haze is the scattering and absorption of
light by fine particles.  Fine particle air pollution also adversely
impacts human health, especially the respiratory and cardiovascular
systems of people at increased risk, including children, the elderly,
and people with heart or respiratory conditions.  

Regional haze obscures views in pristine areas such as national parks,
forests and wilderness areas (156 of which have been designated Federal
Class I areas).  In parks in the eastern U.S., the average visual range
has decreased from 106 miles (under natural conditions) to 24- 44 miles
today.  

Visibility impairment can be quantified using three different, but
mathematically related measures: visual range (i.e., how far one can
see); light extinction per unit distance (e.g., Mm-1); and deciviews
(dv), a useful metric for measuring increments of visibility change that
are just perceptible to the human eye.  Each can be estimated from the
ambient concentrations of individual particle constituents, taking into
account their unique light-scattering (or absorbing) properties, and
making appropriate adjustments for relative humidity.  Assuming natural
conditions, visibility in the Northeast and Mid-Atlantic is estimated to
be about 106 miles, which corresponds to 23 Mm-1 or 8 dv.  Under current
polluted conditions in the region, average visibility ranges from 24
miles in the south to 44 miles in the north; these values correspond to
103 Mm-1 to 55 Mm-1 or 23 to 17 dv, respectively.  On the worst 20
percent of days, visibility impairment in Northeast and Mid-Atlantic
Class I areas ranges from 21.7 to 29 dv (a visual range of about 30 to
14 miles).

The fine particles that commonly cause hazy conditions in the eastern
U.S. are primarily composed of sulfate, nitrate, organic carbon,
elemental carbon (soot), and crustal material (e.g., soil dust, sea
salt, etc.).  Sulfate, nitrate, and organic carbon are secondary
pollutants that form in the atmosphere from precursor pollutants,
primarily sulfur dioxide (SO2), nitrogen oxides (NOx), and volatile
organic compounds (VOCs), respectively.  Sulfate, formed from SO2
emissions, is the dominant contributor to fine particle pollution
throughout the eastern U.S. and therefore most eastern regional control
efforts are directed at reducing SO2 emissions.

Regulatory Framework

In amendments to the Clean Air Act (CAA) in 1977, Congress added Section
169 (42 U.S.C. 7491) setting forth the following national 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 "Class I" designation was given to each of 158 areas in existence as
of August 1977 that met the following criteria: 

all national parks greater than 6000 acres, 

all national wilderness areas and national memorial parks greater than
5000 acres, and 

one international park. 

In 1980, Bradwell Bay, Florida, and Rainbow Lake, Wisconsin, were
excluded for purposes of visibility protection as federal Class I areas.
 Today, 156 national park and wilderness areas remain as Class I
visibility protection areas (  REF _Ref203279927 \h  Figure 1 ).

Over the following years, modest steps were taken to address the
visibility problems in Class I areas.  The control measures taken mainly
addressed “plume blight” from specific pollution sources and did
little to address regional haze issues in the Eastern United States.  

When the CAA was amended in 1990, Congress added Section 169B (42 U.S.C.
7492), authorizing further research and regular assessments of the
progress made.  In 1993, the National Academy of Sciences concluded that
“current scientific knowledge is adequate and control technologies are
available for taking regulatory action to improve and protect
visibility.”

In addition to authorizing creation of visibility transport commissions
and setting forth their duties, Section 169B(f) of the CAA mandated
creation of the Grand Canyon Visibility Transport Commission (GCVTC) to
make recommendations to the U.S. Environmental Protection Agency (EPA)
for the region affecting the visibility of the Grand Canyon National
Park.  The GCVTC submitted its report to EPA in June 1996, following
four years of research and policy development.  This report, as well as
the many research reports prepared by the Commission, contributed
invaluable information to EPA in its development of regulations for
visibility improvement.

Figure   SEQ Figure \* ARABIC  1 : Locations of Federally Protected
Mandatory Class I Areas

 

History of Federal Regional Haze Rule

The federal requirements that states must meet to achieve national
visibility goals are contained in Title 40: Protection of Environment,
Part 51 – Requirements for Preparation, Adoption, and Submittal Of
Implementation Plans, Subpart P – Protection of Visibility (40 CFR
51.300-309).  Known more simply as the Regional Haze Rule, these
regulations were adopted on July 1, 1999, and went into effect on August
30, 1999.  The rule seeks to address the combined visibility effects of
various pollution sources over a large geographic region.  This
wide-reaching pollution net means that many states – even those
without Class I Areas – are required to participate in haze reduction
efforts.  The specific requirements for States’ Regional Haze State
Implementation Plans (SIPs) are set forth in 40 CFR 51.308, Regional
Haze Program Requirements.

In consultation with the states and tribes, EPA designated five Regional
Planning Organizations (RPOs)  to assist with the coordination and
cooperation needed to address the haze issue. The Mid-Atlantic /
Northeast states, including the District of Columbia, formed the
Mid-Atlantic / Northeast Visibility Union (MANE-VU).

EPA’s adoption of the Regional Haze Rule was challenged by the
American Corn Growers Association.  On May 24, 2002, the U.S. Court of
Appeals, D.C. District Court, ruled on the challenge and remanded to EPA
the Best Available Retrofit Technology (BART) provisions of the rule,
but denied industry’s challenge to the haze rule’s goals of natural
visibility and no degradation requirements.  On June 15, 2005, EPA
finalized a rule addressing the court’s remand. 

On February 18, 2005, the Appeals Court issued another ruling vacating
the Regional Haze Rule in part and sustaining it in part.  For more
information see Center for Energy and Economic Development v. EPA, #
03-1222, (D.C. Cir. Feb. 18, 2005; “CEED v. EPA”).  In this case,
the court granted a petition challenging provisions of the Regional Haze
Rule governing the optional emissions trading program for certain
Western States and Tribes (the WRAP Annex Rule). 

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

Revised the regulatory text in 40 CFR 51.308(e)(2)(i) in response to the
CEED court’s remand to remove the requirement that the determination
of BART “benchmark” be based on cumulative visibility analyses, and
to clarify the process for making such determinations, including the
application of BART presumptions for Electric Generating Units (EGUs) as
contained in Appendix Y to 40 CFR 51.

Added new regulatory text in 40 CFR 51.308(e)(2)(vi) to provide minimum
elements for cap and trade programs in lieu of BART.

Revised regulatory text in 40 CFR 51.309 to reconcile the optional
framework for certain Western States and Tribes to implement the
recommendations of the Grand Canyon Visibility Transport Commission with
the CEED decision.

State Implementation Plan

In accordance with 40 CFR 51.308(b), Massachusetts submits this SIP to
meet the requirements of EPA’s Regional Haze Rule.  This SIP addresses
the core requirements of 40 CFR 51.308(d).  In addition, this SIP
addresses requirements pertaining to regional planning and state/tribe
and Federal Land Manager (FLM) coordination and consultation.

Pursuant to 40 CFR 51.308(d)(4)(v), Massachusetts also commits to making
periodic updates to the Massachusetts emissions inventory (Section 6).
Massachusetts proposes to complete these updates to coincide with the
progress reports.

40 CFR 51.308(f) requires Massachusetts to submit revisions to its
Regional Haze SIP every ten years.  The first milestone for reasonable
progress is 2018.  Massachusetts commits to submitting a revision to its
Regional Haze SIP by July 31, 2018.

40 CFR 51.308(g) requires Massachusetts to submit a report to EPA every
5 years that evaluates progress toward the reasonable progress goal for
each 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.  Massachusetts commits to submitting the first
progress report in 2013. 

Finally, pursuant to 40 CFR 51.308(h), Massachusetts will submit a
determination of adequacy of its Regional Haze SIP whenever a progress
report is submitted. 

Regional Planning and State/Tribe and Federal Land Manager Coordination

Regional Planning

In 1999, EPA and affected states/tribes agreed to create five Regional
Planning Organizations (RPOs) to facilitate interstate coordination on
Regional Haze SIPs.    REF _Ref196884438 \h  \* MERGEFORMAT  Figure 2 
shows a map of the five RPOs: MANE-VU (Mid-Atlantic/Northeast Visibility
Union), VISTAS (Visibility Improvement State and Tribal Association of
the Southeast), MRPO (Midwest Regional Planning Organization), CenRAP
(Central Regional Air Planning Association), and WRAP (Western Regional
Air Partnership).  As part of regional planning, the RPOs and states and
tribes within each RPO are required to consult on the development of
emission management strategies.  

Figure   SEQ Figure \* ARABIC  2 : US EPA Designated Regional Planning
Organizations

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

MANE-VU’s work is managed by the Ozone Transport Commission (OTC) and
carried out by the OTC, the Mid-Atlantic Regional Air Management
Association (MARAMA), and the Northeast States for Coordinated Air
Quality Management (NESCAUM).  Members of MANE –VU are listed in   REF
_Ref191278736 \h  \* MERGEFORMAT  Table 1 .  The states and tribes,
along with federal agencies and professional staff from OTC, MARAMA and
NESCAUM, are members of the various committees and workgroups
established by MANE-VU.  Policy decisions are made by the MANE-VU Board
of Directors, composed of senior staff from each member state, tribe, or
agency.

Table   SEQ Table \* ARABIC  1 : MANE-VU Members

Connecticut 	Pennsylvania 

Delaware 	Penobscot Nation

District of Columbia 	Rhode Island 

Maine 	St. Regis Mohawk Tribe

Maryland 	Vermont 

Massachusetts 	U.S. Environmental Protection Agency*

New Hampshire 	U.S. National Park Service*

New Jersey	U.S. Fish and Wildlife Service*

New York	U.S. Forest Service*

		* Non-voting member 

Since its inception on July 24, 2001, MANE-VU established an active
committee structure to address both technical and non-technical issues
related to regional haze.  One of the primary committees is the
Technical Support Committee (TSC), charged with assessing 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.  It has three standing working groups, broken down by topic area:
Emissions Inventory, Modeling, and Monitoring/Data Analysis Workgroups. 
The TSC has evolved to function as a valuable sounding board for all the
technical projects and processes of MANE-VU and has established a
process to ensure that important regional haze-related projects are
completed in a timely fashion and members are kept informed of all
MANE-VU tasks and duties.  

The second primary committee is the Communications Committee, charged
with developing approaches to inform the public about the regional haze
problem in the region and making any recommendations to the MANE-VU
Board to facilitate that goal.  It oversaw the development of
MANE-VU’s newsletter and outreach tools, both for stakeholders and for
the public, regarding regional issues within MANE-VU.

Policy decisions are made by the MANE-VU Board.  MANE-VU established a
Policy Advisory Group to provide advice to decision-makers on policy
questions.  Federal Land Managers, EPA, states, and tribes are
represented on the Policy Advisory Group, which met on an as-needed
basis.

Class I Areas Within MANE-VU

MANE-VU contains seven Federal Class I areas in four states (Figure 3). 
Massachusetts does not contain any Class I areas.

Figure   SEQ Figure \* ARABIC  3 : Class I Areas within MANE-VU

Area of Influence for MANE-VU Class I Areas

40 CFR 51.308(d)(3) of the Regional Haze Rule requires states to
determine their respective contribution to visibility impairment at
Class I areas.  Through source apportionment modeling (more fully
described in Section 7), MANE-VU has identified and evaluated the major
contributors to regional haze at MANE-VU Class I areas as well as Class
I areas in nearby RPOs.  The complete findings are contained in a report
produced by the Northeast States for Coordinated Air Quality Management
(NESCAUM) entitled, “Contributions to Regional Haze in the Northeast
and Mid-Atlantic United States,” otherwise known as the Contribution
Assessment (Appendix   SEQ Appendix \* ALPHABETIC  A ).  Based on that
work, MANE-VU concluded that it was appropriate to define an area of
influence including all of the states participating in MANE-VU, plus
other states that modeling indicated contributed at least 2 percent of
the sulfate ion at MANE-VU Class I areas in 2002.  MANE-VU identified
the states in Table 2 as causing or contributing to visibility
impairment in one or more of the following Class I areas: Acadia
National Park, Brigantine Wildlife Refuge, Great Gulf Wilderness Area,
Lye Brook Wilderness Area, Moosehorn Wildlife Refuge, Presidential
Range-Dry River Wilderness Area, and Roosevelt-Campobello International
Park.

Table   SEQ Table \* ARABIC  2 : States that Contribute to Visibility
Impairment at One or More of the MANE-VU Class I Areas of Acadia,
Moosehorn, Roosevelt-Campobello, Great Gulf, Presidential Range-Dry
River, Lye Brook, and Brigantine

State 	RPO

Connecticut	MANE-VU

Delaware	MANE-VU

Maine	MANE-VU

Maryland	MANE-VU

Massachusetts	MANE-VU

New Hampshire	MANE-VU

New Jersey	MANE-VU

New York	MANE-VU

Pennsylvania	MANE-VU

Rhode 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

Massachusetts Impact on MANE-VU Class I Areas

Emission sources within Massachusetts had measurable impacts on
visibility at Class I areas within MANE-VU in the 2002 baseline year. 
The magnitude of these impacts is described in detail in Section 7 and
MANE-VU’s Contribution Assessment (Appendix   REF _Ref191968764 \r \h 
\* MERGEFORMAT  A ).  Table 3 lists the Class I areas affected by
emissions sources in Massachusetts. 

Table   SEQ Table \* ARABIC  3 : Class I Federal Areas Affected by
Emissions from Massachusetts

Class I Federal Area	State

Acadia National Park	Maine

Moosehorn Wildlife Refuge	Maine

Roosevelt Campobello International Park	Maine/Canada

Great Gulf Wilderness Area	New Hampshire

Presidential Range-Dry River Wilderness Area	New Hampshire

Lye Brook Wilderness Area	Vermont

Regional Haze Planning after the Remand of CAIR

On March 10, 2005, EPA issued the Clean Air Interstate Rule (CAIR). 
This important federal rule was designed to achieve major permanent
reductions in SO2 and NOx emissions in the eastern United States through
a cap-and-trade system using emission allowances.  CAIR would
permanently cap emissions originating in 28 eastern states and the
District of Columbia (  REF _Ref236628047 \h  Figure 4 ).  Although
Massachusetts was only designated as a participating CAIR state for the
ozone season, this program would have greatly affected future air
quality in the state.

According to EPA’s CAIR website, SO2 emissions in the affected states
would be reduced by more than 70 percent and NOx emissions by more than
60 percent from 2003 levels upon full implementation of CAIR (see  
HYPERLINK "http://www.epa.gov/cair/"  http://www.epa.gov/cair/ ).  

Figure   SEQ Figure \* ARABIC  4 : Map of CAIR States

On July 11, 2008, the U.S. Court of Appeals for the District of Columbia
Circuit found that CAIR violated basic provisions of the Clean Air Act. 
The court vacated CAIR in its entirety and remanded it to EPA in order
to promulgate a new rule consistent with the court’s opinion.  EPA
appealed the decision amid widespread concern that, despite its flaws,
some form of CAIR was preferable to the sudden regulatory void created
by the Court’s decision.  Upon reconsideration, on December 23, 2008,
the Court stayed the vacatur of CAIR but maintained the remand to EPA to
promulgate a new rule consistent with the Court’s July 11, 2008,
opinion.

Because CAIR formed the regulatory underpinnings for most of the
emission reductions that were to produce visibility improvements in
mandatory Class I areas, the vacatur of CAIR would have represented a
major difficulty for the individual states in attempting to comply with
the Regional Haze Rule.  While all eastern states have depended in
varying degree on CAIR in the preparation of their regional haze SIPs,
some Southeast states have relied almost entirely on CAIR to demonstrate
compliance with the rule.  The vacatur of CAIR also called into question
the validity of MANE-VU’s (and other RPOs’) emission inventories and
air quality modeling studies already completed for the member states’
Regional Haze SIPs.

 

The CAIR Phase I requirements remained in place through 2011.  On August
8, 2011, EPA published the Cross-State Air Pollution Rule (CSAPR) to
replace CAIR.  CSAPR requires 28 states in the eastern half of the
United States to significantly improve air quality by reducing SO2 and
NOx emissions from power plant emissions that cross state lines and
contribute to ground-level ozone and fine particle pollution in other
states.   Massachusetts is not included in CSAPR.

Future emission controls under CSAPR are similar to those as CAIR
originally would have obtained.  Therefore, Massachusetts expects that
future emissions and air quality levels are likely to be not very
different from values predicted by MANE-VU’s completed modeling, even
though that modeling was based on implementation of CAIR as it was
before CSAPR.  Consequently, the long-term strategy developed for
Massachusetts’ SIP represents a reasonable starting point from which
to go forward with measures to improve visibility at MANE-VU’s Class I
Areas.  These measures will be reviewed at the mid-point review in 2013
in consultation with Class I states, who may at that time reassess their
reasonable progress goals.  

Regional Consultation and the “Ask”

40 CFR Section 51.308(d)(3)(i) requires Massachusetts to consult with
other states/tribes to develop coordinated emission management
strategies.  Massachusetts consulted with other states and tribes
through participation in the MANE-VU and inter-RPO processes that
developed the technical information necessary for the development of
coordinated strategies. 

On May 10, 2006, MANE-VU adopted the Inter-RPO State/Tribal and FLM
Consultation Framework.  A full copy of MANE-VU’s Final Interim
Principles for Regional Planning can be found in Appendix   REF
_Ref192042296 \r \h  \* MERGEFORMAT  B .  That document sets forth the
principles listed in   REF _Ref203281748 \h  Figure 5 .  MANE-VU states
and tribes applied these principles to the regional haze consultation
and SIP development processes.  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.

Figure   SEQ Figure \* ARABIC  5 : MANE-VU Principles for Regional Haze
Planning

All State, Tribal, RPO, and Federal participants are committed to
continuing dialogue and information sharing in order to create
understanding of the respective concerns and needs of the parties. 

Continuous documentation of all communications is necessary to develop a
record for inclusion in the SIP submittal to EPA. 

States alone have the authority to undertake specific measures under
their SIP. This inter-RPO framework is designed solely to facilitate
needed communication, coordination, and cooperation among jurisdictions,
but does not establish binding obligation on the part of participating
agencies. 

There are two areas which require State-to-State and/or State-to-Tribal
consultations (“formal” consultations): (i) development of the
reasonable progress goal for a Class I area, and (ii) development of
long-term strategies. While it is anticipated that the formal
consultation will cover the technical components that make up each of
these policy decision areas, there may be a need for the RPOs, in
coordination with their State and Tribal members, to have informal
consultations on these technical considerations.  

During both the formal and informal inter-RPO consultations, it is
anticipated that the States and Tribes will work collectively to
facilitate the consultation process through their respective RPOs, when
feasible. 

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. 

The State with the Class I area retains the responsibility to establish
reasonable progress goals. The RPOs will make reasonable efforts to
facilitate the development of a consensus between the State with a Class
I area and other States affecting that area. In instances where the
State with the Class I area cannot agree with such other States that the
goal provides for reasonable progress, actions taken to resolve the
disagreement must be included in the State’s regional haze
implementation plan (or plan revisions) submitted to the EPA
Administrator as required under 40 CFR §51.308(d)(1)(iv). 

All States whose emissions are reasonably anticipated to contribute to
visibility impairment in a Class I area must provide the Federal Land
Manager (“FLM”) agency for that Class I area with an opportunity for
consultation, in person, on their regional haze implementation plans.
The States/Tribes will pursue the development of a memorandum of
understanding to expedite the submission and consideration of the
FLM’s comments on the reasonable progress goals and related
implementation plans. As required under 40 CFR §51.308(i)(3), the plan
or plan revision must include a description of how the State addressed
any FLM comments. 

States/Tribes will consult with the affected FLMs to protect the air
resources of the State/Tribe and Class I areas in accordance with the
FLM coordination requirements specified in 40 CFR §51.308(i) and other
consultation procedures developed by consensus. 

The consultation process is designed to share information, define and
document issues, develop a range of options, solicit feedback on
options, develop consensus advice if possible, and facilitate informed
decisions by the Class I States. 

The collaborators, including States, Tribes and affected FLMs, will
promptly respond to other RPO’s/States’/Tribes’ requests for
comments.



The following points highlight many of the ways MANE-VU member states
and tribes have cooperatively addressed regional haze:

Budget Prioritization: MANE-VU developed a process to coordinate MARAMA,
OTC, and NESCAUM staff in developing budget priorities, project
rankings, and the eventual federal grant requests.  

Issue Coordination: MANE-VU established a conference call and meeting
schedule for each of its committees and workgroups.  In addition,
MANE-VU Air Directors regularly discussed pertinent issues. 

SIP Policy and Planning: MANE-VU states/tribes collaborated on the
development of a SIP Template. 

Capacity Building: To educate its staff and members, MANE-VU included
technical presentations on conference calls and organized workshops with
nationally recognized experts.  Presentations on data analysis, BART
work, inventory topics, modeling, control measures, etc., were an
effective education and coordination tool.

Routine Operations:  MANE-VU staff at OTC, MARAMA, and NESCAUM
established a coordinated approach to budgeting, grant
deliverables/due-dates, workgroup meetings, inter-RPO feedback, etc.

In addition to having a set of guiding principles for consultation,
MANE-VU needed a consistent technical basis for emission control
strategies to reduce regional haze to meet the reasonable progress goals
for 2018.  After much research and analysis, on June 20, 2007, MANE-VU
adopted the following pair of documents, which provide the technical
basis for consultation among the interested parties and define the basic
strategies for controlling pollutants that cause visibility impairment
at Class I areas in the eastern United States.  Together, these
documents are known as the MANE-VU “Ask” (Appendix   REF
_Ref194379259 \r \h  \* MERGEFORMAT  C ).

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

“Statement of the Mid-Atlantic / Northeast Visibility Union (MANE-VU)
Concerning a Request for a Course of Action by States outside of MANE-VU
toward Assuring Reasonable Progress.”

The consultations among MANE-VU states and other states/tribes and
provinces occurred through much of 2007.  Documentation of consultation
meetings and calls between MANE-VU Class I States and states/tribes both
within and outside MANE-VU can found on the MANE-VU website at  
HYPERLINK "http://www.otcair.org/manevu/consultations.asp?fview=2" 
www.otcair.org/manevu/consultations.asp?fview=2 .  A summary of the
consultation process follows.

MANE-VU Intra-Regional Consultation, March 1, 2007

At this meeting, MANE-VU members reviewed requirements for regional haze
plans, preliminary modeling results, work being done to prepare the
MANE-VU report on reasonable progress factors, and control strategy
options under review.

MANE-VU Intra-State Consultation, June 7, 2007

At this meeting the MANE-VU Class I states adopted a statement of
principles, and all MANE-VU members discussed draft statements
concerning reasonable controls within and outside of MANE-VU.  Federal
Land Managers also attended the meeting, which was open to stakeholders.

MANE-VU Conference Call, June 20, 2007

On this call, 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,” including a statement
concerning controls within MANE-VU, a statement concerning controls
outside MANE-VU, and a statement requesting a course of action by EPA. 
Federal Land Managers also participated in the call.  Upon approval, all
statements as well as the statement of principles adopted on June 7 were
posted and publicly available on the MANE-VU web site. 

MANE-VU Class I States’ Consultation Open Technical Call, July 19,
2007

On this call, the MANE-VU / New Hampshire “Ask” was presented to
states in other RPOs, RPO staff, and Federal Land Managers, and an
opportunity was provided to request further 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 was held at LADCO offices in Chicago, Illinois and 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 “Ask” to MRPO states and to consult with them regarding the
reasonableness of the requested controls.  Federal Land Manager agencies
also attended the meeting.

MANE-VU Consultation Meeting with VISTAS, August 20, 2007

This meeting was held at State of Georgia offices in Atlanta and was
attended by representatives of MANE-VU and VISTAS states, as well as
staff.  The meeting provided an opportunity to formally present the
MANE-VU “Ask” to VISTAS states and to consult with them regarding
the reasonableness of the requested controls.  Federal Land Manager
agencies also attended the meeting.

MANE-VU – Midwest RPO Consultation Conference Call, September 13, 2007

This call was a follow-up to the meeting held on August 6 in Chicago and
provided an opportunity to further clarify what was being asked of the
MRPO states, including explanation of the flexibility in the “Ask.” 
Both MRPO and MANE-VU staff agreed to work together to facilitate
discussion of further controls on ICI boilers and EGUs.

MANE-VU Air Directors’ Consultation Conference Call, September 26,
2007

This call allowed MANE-VU members to clarify their understanding of the
“Ask” and to provide direction to modeling staff as to how to
interpret the “Ask” for purposes of estimating visibility impacts of
the requested controls.

MANE-VU Air Directors’ Conference Call, March 31, 2008

On this call, NESCAUM presented the results of the final 2018 modeling
and described the methods used to represent the impacts of the measures
agreed to by the Class I States.  Federal Land Manager agencies also
participated in this call. 

Meeting the “Ask” – MANE-VU States

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

timely implementation of BART requirements; and

a low sulfur fuel oil strategy in the inner zone States (New Jersey, New
York, Delaware and Pennsylvania, or portions thereof) to reduce the
sulfur content of: distillate oil to 0.05 percent sulfur by weight (500
ppm) by no later than 2012, of #4 residual oil to 0.25 percent sulfur by
weight by no later than 2012, of #6 residual oil to 0.3 – 0.5 percent
sulfur by weight by no later than 2012, and to further reduce the sulfur
content of distillate oil to 15 ppm by 2016; and

a low sulfur fuel oil strategy in the outer zone States (the remainder
of the MANE-VU region) to reduce the sulfur content of distillate oil to
0.05 percent sulfur by weight (500 ppm) by no later than 2014, of #4
residual oil to 0.25 – 0.5 percent sulfur by weight by no later than
2018, and of #6 residual oil to no greater than 0.5 percent sulfur by
weight by no later than 2018, and to further reduce the sulfur content
of distillate oil to 15 ppm by 2018, depending on supply availability;
and

A 90 percent or greater reduction in sulfur dioxide  (SO2) emissions
from each of the top 100 electric generating units (EGUs) identified by
MANE-VU (comprising a total of 167 stacks) as reasonably anticipated to
cause or contribute to impairment of visibility in each mandatory Class
I Federal area in the MANE-VU region.  If it is infeasible to achieve
that level of reduction from a unit, alternative measures will be
pursued in such State; and 

continued evaluation of other control measures including energy
efficiency, alternative clean fuels, and other measures to reduce SO2 
and nitrogen oxide (NOx) emissions from all coal-burning facilities by
2018 and new source performance standards for wood combustion.  These
measures and other measures identified will be evaluated during the
consultation process to determine if they are reasonable and
cost-effective.

Massachusetts supports the SIPs of each of its fellow MANE-VU states
provided that these SIPs incorporate these commitments.

Meeting the “Ask” – Massachusetts

As a MANE-VU member state, Massachusetts also adopted the “Ask” at
the MANE-VU Board meeting on June 7, 2007.  Massachusetts is meeting the
terms of this agreement by implementing an alternative to BART as
described in Section   REF _Ref196801005 \w \h  \* MERGEFORMAT  8 , and
by ensuring reductions in SO2 emissions from the Massachusetts Targeted
EGU stacks, implementing low-sulfur fuel oil regulations, and
implementing controls on outdoor wood-fired boilers as described in
Section   REF _Ref191969839 \r \h  \* MERGEFORMAT  10 .  Massachusetts
also will pursue other reasonable and cost-effective measures as needed.

Meeting the “Ask” – States Outside of MANE-VU

For consulting states outside the MANE-VU region, the MANE-VU “Ask”
requests the pursuit of the adoption and implementation of the following
control strategies, as appropriate and necessary:

timely implementation of BART requirements;

A 90 percent or greater reduction in sulfur dioxide (SO2) emissions from
each of the top 100 electric generating units (comprising a total of 167
stacks) impacting any mandatory Class I Federal area in the MANE-VU
region, or an equivalent SO2 reduction within each State;

the application of reasonable controls on non-EGU sources resulting in a
28 percent reduction in non-EGU SO2 emissions, relative to on-the-books,
on-the-way 2018 projections used in regional haze planning, by 2018,
which is equivalent to the projected reductions MANE-VU will achieve
through its low sulfur fuel oil strategy;

continued evaluation of other measures including measures to reduce SO2
and nitrogen oxide (NOx) emissions from all coal-burning facilities by
2018 and promulgation of new source performance standards for wood
combustion. These measures and other measures identified will be
evaluated through consultation processes to determine if they are
reasonable.

Massachusetts recognizes that non-MANE-VU states may choose not to adopt
the MANE-VU “Ask” due to associated costs, conflicts, and relative
lack of benefit within their jurisdictions.  During consultations, some
non-MANE-VU states were considering not pursuing reductions beyond CAIR
controls and other measures pertaining to BART.  EPA’s CSAPR will
provide reductions similar to CAIR and it is hoped that states in the
mid-west and southeast RPOs will adopt other additional controls. 
Ultimately, the approvability of all states’ SIPs will be determined
by EPA.  

Technical Ramifications of Differing Approaches 

MANE-VU states intended to develop a modeling platform that was common
in terms of meteorology and emissions with each of the other nearby
RPOs.  The RPOs worked diligently to form a common set of emissions with
similar developmental assumptions.  Even with the best of intentions, it
became difficult to keep up with each RPO’s updates and corrections. 
Each rendition of emissions inventory improved its quality, but because
each update made to one RPO’s emissions meant that the other RPOs
needed to incorporate the updates into the full emission set for all the
RPOs and then reprocess them, there was a continuous modeling effort
where each one outdated the last.  Because each rendition put previous
modeling efforts out of date, and a single modeling run could take more
than a month to complete, inventory updates contributed to SIP delays. 
The emission inventory conflicts were excessively time consuming and
caused most states to miss the official SIP filing date of December 17,
2007.

The RPOs also took differing perspectives on which version of the EGU
dispatching model (Integrated Planning Model or IPM) to use.  At the
beginning of the process, IPM version 2.1.9 was available and EPA agreed
to its use for emissions preparation.  Since then, IPM version 3.0
became available and it became EPA’s preferred version since it had
updated fuel costs.  MRPO adopted IPM v3.0 for its use, but VISTAS
stayed with IPM v2.1.9.  Rather than develop non-comparative datasets
for its previous IPM analyses, MANE-VU also stayed with IPM v2.1.9. 
Therefore, of the three eastern RPOs, differing emissions assumptions
eventually worked their way into the final set of modeling assumptions. 

MANE-VU’s best and final modeling not only considers
on-the-way/on-the-books emissions programs for 2018 (listed in Section
10), but also includes additional reasonable controls in its region,
including those contained in the MANE-VU “Ask”.  It should be noted
that other RPOs may not have included such measures in their final
modeling.  In these cases, the modeling results of states in these RPOs
will be inconsistent with meeting the terms of the MANE-VU “Ask” –
a situation that may not be adequately addressed in their SIPs.  These
inconsistencies will need to be resolved by EPA.  

Federal Land Manager Coordination

Massachusetts will continue to coordinate and consult with the Federal
Land Managers (FLMs) during the development of future progress reports
and plan revisions, as well as during the implementation of programs
having the potential to contribute to visibility improvement in the
Class I areas.

Section 51.308(i) of the Regional Haze Rule requires coordination
between states/tribes and the FLMs.  Opportunities have been provided by
MANE-VU for FLMs to review and comment on each of the technical
documents developed by MANE-VU and included in this SIP.  Massachusetts
has provided agency contacts to the FLMs as required.  In the
development of this Plan, the FLMs were consulted in accordance with the
provisions of 51.308(i)(2). 

MassDEP provided previous drafts of this SIP, or portions thereof, to
FLMs and EPA for review and comment on November 25, 2008 and July  31,
2009, and published the draft SIP for public hearing and comment on
January 11, 2011.  MassDEP also published a draft SIP revision for
public hearing and comment on February 17, 2012.  MassDEP provided the
FLMs an opportunity for consultation, in person and at least 60 days
prior to holding a public hearing on the SIP.  The comments submitted by
the FLMs were both general and specific. The reviewing agencies found
Massachusetts’ draft Regional Haze SIP to be well written and
comprehensive.  The uncertainty surrounding CAIR and discrepancies in
modeling (especially inclusion of the MANE-VU Ask) between MANE-VU and
other RPOs were identified as broad topics for further discussion
through the consultation process.  Comments of a specific nature were
focused primarily on requesting additional information in support of
initial BART analyses.  In accordance with 40 CFR 51.308(i)(3), MassDEP
has addressed comments from FLMs regarding the SIP in Appendix   REF
_Ref198002546 \r \h  \* MERGEFORMAT  D  of this plan, as well as
comments submitted by EPA.  

Section 51.308(i)(4) requires procedures for continuing consultation
between states/tribes and FLMs on the implementation of the visibility
protection programs.  In particular, consultations will be conducted
with the designated visibility protection program coordinators for the
National Park Service, the U. S. Fish and Wildlife Service, and the U.S.
Forest Service.  MassDEP will consult periodically with the FLMs as
necessary on the status of the following implementation items:

Implementation of emissions strategies identified in the SIP as
contributing to achieving improvement in the worst-day visibility.

Summary of major new source permits issued.

Status of Massachusetts actions to meet commitments for completing any
future assessments or rulemakings on sources identified as likely
contributors to visibility impairment, but not directly addressed in the
most recent SIP revision. 

Any changes to the status of the monitoring strategy or monitoring
stations that may affect tracking of reasonable progress. 

Work underway for preparing the 5-year review and / or 10-year revision.

Items for FLMs to consider or provide support for in preparation for any
visibility protection SIP revisions (based on the 5-year review or the
10-year revision schedule).  

Summaries of discussions (meetings, emails, other records) covered in
ongoing communications between MassDEP and FLMs regarding implementation
of the visibility program. 

Assessment of Baseline AND Natural Conditions

Under the Clean Air Act, the Regional Haze SIPs must contain measures to
make reasonable progress toward the goal of achieving natural
visibility.  Section 51.308(d)(2) of EPA’s Regional Haze Rule requires
each state containing a Class I area to determine baseline and natural
visibility conditions for their Class I area in consultation with FLMs
and states identified as containing sources whose emissions contribute
to visibility impairment in Class I areas.  Comparing baseline
conditions to natural visibility conditions determines the uniform rate
of progress that must be considered as states set reasonable progress
goals for each Class I area. 

The requirement to assess baseline and natural conditions within Class I
Areas is a responsibility of the state containing those areas. 
Massachusetts does not contain any Class I Areas; however, assessment of
baseline and natural visibility conditions for MANE-VU Class I Areas is
included here as reference.

Calculation Methodology

The Interagency Monitoring of Protected Visual Environments (IMPROVE)
program was established in 1985 to provide the data needed to assess
current visibility conditions, track changes in visibility, and help
determine the causes of visibility impairment in Class I Areas (see
Section 4 for more detailed information about IMPROVE).  IMPROVE data
was used to calculate baseline and natural conditions for MANE-VU Class
I areas.

The IMPROVE monitors listed in   REF _Ref203288011 \h  Table 4  provide
data that are representative of Class I Areas in MANE-VU.  As described
in the Monitoring Section (Section 4) of this SIP, Massachusetts accepts
IMPROVE designation of these sites as representative of Class I areas in
accordance with 40 CFR 51.308(d)(2)(i).

Table   SEQ Table \* ARABIC  4 : IMPROVE Monitors for MANE-VU Class I
Areas

Class I Area	IMPROVE Site	Location (latitude and longitude)	State

Acadia National Park	ACAD1	44.38, -68.26	Maine

Moosehorn Wilderness Area	MOOS1	45.13, -67.27	Maine

Roosevelt/Campobello International Park	MOOS1	45.13, -67.27	Maine

Great Gulf Wilderness Area	GRGU1	44.31, -71.22	New Hampshire

Presidential Range/Dry River Wilderness	GRGU1	44.31, -71.22	New
Hampshire

Lye Brook Wilderness Area	LYBR1	43.15, -73.13	Vermont

Brigantine Wilderness Area	BRIG1	39.47, -74.45	New Jersey

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

In September 2003, EPA issued guidance for the calculation of natural
background and baseline visibility conditions.  The guidance provides a
default method and describes certain refinements that states may wish to
evaluate to tailor these estimates to a specific Class I area if it is
poorly represented by the default method.  At that time, MANE-VU
calculated natural visibility for each of the MANE-VU Class I areas
using the default method for the 20 percent best and worst visibility
days.  MANE-VU also evaluated ways to refine the estimates.  Potential
refinements included: increasing the multiplier used to calculate
impairment attributed to carbon, adjusting the formula used to calculate
the 20 percent best and worst visibility days, and accounting for
visibility impairment due to sea salt at coastal sites.  However,
MANE-VU found that these refinements did not significantly improve the
accuracy of the estimates, and MANE-VU states desired a consistent
approach.  Therefore, default estimates were used with the understanding
that this would be reconsidered when better scientific knowledge
warranted. 

Once the technical analysis was complete, MANE-VU provided an
opportunity to comment to federal agencies and stakeholders.  The
proposed approach was posted on the MANE-VU website on March 17, 2004
and a stakeholder briefing was held on the same day.  Comments were
received from the Electric Power Research Institute, the Midwest Ozone
Group, the Appalachian Mountain Club, the National Parks Conservation
Association, the National Park Service, and the US Forest Service. 

Several comments supported the proposal and other comments addressed
four main topics: the equation used to calculate visibility, the
statistical technique used to estimate the 20 percent best and worst
visibility days, the inclusion of transboundary effects and fires, and
the timing of when new information should be included.  All comments
were reviewed and summarized by MANE-VU.  The MANE-VU Board was briefed
on comments and proposed response options.

The MANE-VU position on natural background conditions was issued in June
2004, and stated that, “Refinements to other aspects of the default
method (e.g., refinements to the assumed distribution or treatment of
Rayleigh extinction, inclusion of sea salt, and improved assumptions
about the chemical composition of the organic fraction) may be warranted
prior to submission of SIPs depending on the degree to which scientific
consensus is formed around a specific approach…”

In 2006, the IMPROVE Steering Committee adopted an alternative
reconstructed extinction equation to revise certain aspects of the
default method. The aspects revised were scientifically well understood,
and the Committee determined that revisions improved the performance of
the equation at reproducing observed visibility at Class I sites. 

In 2006, NESCAUM conducted an assessment of the default and alternative
approaches for calculation of baseline and natural background conditions
at MANE-VU Class I areas.  (See the MANE-VU document, Baseline and
Natural Background Visibility Conditions: Considerations and Proposed
Approach to the Calculation of Baseline and Natural Background
Visibility Conditions at MANE-VU Class I Areas, Appendix   REF
_Ref191968946 \r \h  \* MERGEFORMAT  E .)  Corresponding visibility
improvement targets for 2018 using each approach also were presented in
the document (see Table 3-3 of Appendix   REF _Ref191968946 \r \h  \*
MERGEFORMAT  E ).  Results suggest that the alternative approach leads
to very similar uniform rates of progress in New England with slightly
greater visibility improvement required in the Mid-Atlantic region
relative to the default approach.  Based on that assessment, in December
2006, MANE-VU recommended adoption of the alternative reconstructed
extinction equation for use in SIPs.  MANE-VU will continue to
participate in further research efforts on this topic and will
reconsider the calculation methodology as scientific understanding
evolves.

MANE-VU Baseline and Natural Visibility

The IMPROVE program has calculated the 20 percent best and 20 percent
worst baseline (2000-2004) and natural visibility conditions using the
EPA-approved alternative method described above for each MANE-VU Class I
Area.  The data are posted on the Visibility Information Exchange Web
System (VIEWS) operated by the regional planning organizations.  The
information can be accessed at   HYPERLINK
"http://vista.cira.colostate.edu/views/" 
http://vista.cira.colostate.edu/views/  and is summarized in   REF
_Ref199901597 \h  \* MERGEFORMAT  Table 5  below.  Units are expressed
in deciviews, a log function of the light scattering and absorption
extinction coefficient, as required by 40 CFR 51.308(d)(2).  Generally,
a one deciview change in the haze index is likely to be perceptible
under ideal conditions regardless of background visibility conditions. 
Displayed are the five-year average baseline visibility values for the
period 2000-2004, natural visibility levels, and the difference between
baseline and natural visibility values for each of the MANE-VU Class I
areas.  The difference columns (best and worst) are of particular
interest because they describe the magnitude of visibility impairment
attributable to manmade emissions, which are the focus of the Regional
Haze Rule.

The five-year averages for 20 percent best and worst visibility were
calculated in accordance with 40 CFR 51.308(d)(2), as detailed in
NESCAUM’s Baseline and Natural Background document found in Appendix  
REF _Ref191968946 \r \h  \* MERGEFORMAT  E .

Table   SEQ Table \* ARABIC  5 : Summary of Baseline Visibility and
Natural Visibility Conditions for the 20 Percent Best and 20 Percent
Worst Visibility Days at MANE-VU Class I Areas

Class I Area(s)	2000-2004 Baseline (deciviews)	Natural Conditions
(deciviews)	Difference

(deciviews)

	Best

20%	Worst 20%	Best

20%	Worst 20%	Best

20%	Worst 20%

Acadia National Park	8.8	22.9	4.7	12.4	4.1	10.5

Moosehorn Wilderness and

Roosevelt Campobello International Park	9.2	21.7	5.0	12.0	4.1	9.7

Great Gulf Wilderness and

Presidential Range - Dry River Wilderness 	7.7	22.8	3.7	12.0	3.9	10.8

Lye Brook Wilderness	6.4	24.5	2.8	11.7	3.6	12.7

Brigantine Wilderness	14.3	29.0	5.5	12.2	8.8	16.8

Source: VIEWS (  HYPERLINK "http://vista.circa.colostate.edu/views/" 
http://vista.circa.colostate.edu/views/ ), prepared on 6/22/2007

Monitoring Strategy 

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

In the mid-1980’s, the IMPROVE program was established to measure
visibility impairment in mandatory Class I areas throughout the United
States.  The monitoring sites are operated and maintained through a
formal cooperative relationship between EPA, National Park Service, U.S.
Fish and Wildlife Service, Bureau of Land Management, and U.S. Forest
Service.  In 1991, several additional organizations joined the effort:
State and Territorial Air Pollution Program Administrators, the
Association of Local Air Pollution Control Officials (which now goes by
The National Association of Clean Air Agencies), Western States Air
Resources Council, Mid-Atlantic Regional Air Management Association, and
Northeast States for Coordinated Air Use Management.

IMPROVE Program Objectives

The IMPROVE program provides scientific documentation of the visual air
quality of America’s wilderness areas and national parks.  Many
individuals and organizations – land managers, industry planners,
scientists (including university researchers), public interest groups,
and air quality regulators – use the data collected at IMPROVE sites
to understand and protect the visual air quality resources in Class I
areas.  Major objectives of the IMPROVE program include:

Establish current visibility and aerosol conditions in mandatory Class I
areas, 

Identify chemical species and emission sources responsible for existing
anthropogenic visibility impairment,

Document long-term trends for assessing progress towards national
visibility goals,

Provide regional haze monitoring representing all visibility-protected
federal Class I areas where practical, as required by EPA’s Regional
Haze Rule.

Monitoring Information for Massachusetts

Section 51.308(d)(4)(iii) of the Regional Haze Rule requires for a state
with no Class I areas, such as Massachusetts, the inclusion of
procedures by which monitoring data and other information are used in
determining the contribution of emissions from within the state to
regional haze visibility impairment at Class I areas outside the state. 
Massachusetts’ contribution is documented in the contribution
assessment analysis completed by NESCAUM entitled, Contributions to
Regional Haze in the Northeast and Mid-Atlantic States (Contribution
Assessment) found in Appendix   REF _Ref191968764 \r \h  \* MERGEFORMAT 
A .  The NESCAUM study used various tools and techniques to assess the
contributions of individual states and regions to visibility degradation
in Class I areas within and outside MANE-VU.

Massachusetts agrees that NESCAUM is providing quality technical
information by using the IMPROVE program data and the Visibility
Information Exchange Web System (VIEWS) site.  Information about the use
of the default and alternative approaches to the calculation of baseline
and natural background conditions can be found in Section 3 of this SIP.

Massachusetts does not contain any Class I Areas; therefore no
monitoring plan is required under Section 51.308(d)(4) or Section 51.30
of the Regional Haze Rule.  Massachusetts does, however, have three
IMPROVE monitors that were used in the regional haze modeling: Cape Cod
(CACO), Martha’s Vineyard (MAVI), and Quabbin summit (QURE).  The CACO
IMPROVE monitor is located at Cape Cod National Seashore in Truro and is
operated and maintained by the National Park Service.  It is located
near MassDEP’s monitoring site at latitude 41:58 and longitude -70:01.
 The QURE IMPROVE monitor is located at the Quabbin Reservoir in Ware,
at latitude 42:17 and longitude –72:20, and is operated and maintained
by MassDEP.  The MAVI IMPROVE monitor is located on Martha’s Vineyard
and is operated by the Wampanoag Tribe of Gay Head (Aquinnah). 
Massachusetts commits to continuing these monitoring programs and to
working with the National Park Service, Wampanoag Tribe, and EPA towards
this end.

The following information is for monitoring within Class I areas
determined to be impacted by Massachusetts sources by the Contribution
Assessment contained in Appendix   REF _Ref191968764 \r \h  \*
MERGEFORMAT  A .

Monitoring Information for MANE-VU Class I Areas Impacted by Emissions
from Massachusetts

Acadia National Park, Maine 

rbor, Maine, at elevation 157 meters, latitude 44.38˚, and longitude
-68.26˚ (see Figure 6).  This monitor is operated and maintained by the
National Park Service.  Massachusetts considers the ACAD1 site as
adequate for assessing reasonable progress toward visibility goals at
Acadia National Park, and no additional monitoring sites or equipment
are necessary at this time.  

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

  

  HYPERLINK "http://www.hazecam.net/class1/acadia.html" 
http://www.hazecam.net/class1/acadia.html 

Great Gulf Wilderness Area, New Hampshire

, latitude 44.31˚, and longitude of -71.22˚ (see Figure 8).  This
monitor, which also represents the Presidential Range - Dry River
Wilderness (see Figure 8), is operated and maintained by the U.S. Forest
Service.  Massachusetts considers the GRGU1 site as adequate for
assessing reasonable progress toward visibility goals at the Great Gulf
Wilderness, and no additional monitoring sites or equipment are
necessary at this time.

Figure   SEQ Figure \* ARABIC  8 : Map of Great Gulf and Presidential
Range - Dry River Wilderness Areas Showing IMPROVE Monitor Location

   HYPERLINK
"http://www.maine.gov/dep/air/meteorology/images/NHclass1.jpg" 
http://www.maine.gov/dep/air/meteorology/images/NHclass1.jpg 

Figure   SEQ Figure \* ARABIC  9 : Great Gulf Wilderness Area on Clear
and Hazy Days

  HYPERLINK "http://www.wilderness.net/"  http://www.wilderness.net/ 

Presidential Range - Dry River Wilderness, New Hampshire

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

Presidential Range - Dry River Wilderness in Autumn

 

http://www.wilderness.net

Lye Brook Wilderness, Vermont 

3.15˚, and longitude of -73.13˚ (see Figure 10).  The monitor does not
lie within the wilderness area but is situated on a mountain peak across
the valley to the west of the wilderness area.  The IMPROVE site and the
Lye Brook Wilderness are at similar elevations.  The monitor is operated
and maintained by the U.S. Forest Service.  Massachusetts considers the
LYBR1 site as adequate for assessing reasonable progress toward
visibility goals at the Lye Brook Wilderness, and no additional
monitoring sites or equipment are necessary at this time.

Figure   SEQ Figure \* ARABIC  10 : Location of Lye Brook Wilderness
Monitor

  HYPERLINK
"http://www.wilderness.net/index.cfm?fuse=NWPS&sec=stateView&state=NH&ma
p=menhvt" 
http://www.wilderness.net/index.cfm?fuse=NWPS&sec=stateView&state=NH&map
=menhvt 

Figure   SEQ Figure \* ARABIC  11 : Lye Brook Wilderness Area on Clear
and Hazy Days

  

  HYPERLINK "http://www.hazecam.net/class1/lye.html" 
http://www.hazecam.net/class1/lye.html 



Moosehorn Wilderness Area, Maine 

The IMPROVE monitor for the Moosehorn Wilderness (MOOS1) is located near
McConvey Road, about one mile northeast of the National Wildlife Refuge
Baring (ME) Unit Headquarters, at elevation 78 meters, latitude 45.13˚,
and longitude -67.27˚ (see Figure 12). This monitor also represents the
Roosevelt Campobello International Park in New Brunswick, Canada.  The
monitor is operated and maintained by the U.S. Fish & Wildlife Service. 
Massachusetts considers the MOOS1 site as adequate for assessing
reasonable progress toward visibility goals at the Moosehorn Wilderness,
and no additional monitoring sites or equipment are necessary at this
time.

Figure   SEQ Figure \* ARABIC  12 : Map of the Baring and Edmunds
Divisions of the Moosehorn National Wildlife Refuge Showing the IMPROVE
Monitor Location

   source: The Refuge Manager at Moosehorn Wilderness

Figure   SEQ Figure \* ARABIC  13 : Moosehorn Wilderness Area on a Clear
and a Hazy Day

source: Martha Webster, Maine Department of Environmental Protection –
Bureau of Air Quality

Roosevelt/Campobello International Park, New Brunswick, Canada

The IMPROVE monitor for Roosevelt Campobello International Park is also
the monitor for the Moosehorn Wilderness (MOOS1), as described above. 
Massachusetts considers the MOOS1 site as adequate for assessing
reasonable progress toward visibility goals at Roosevelt Campobello
International Park, and no additional monitoring sites or equipment are
necessary at this time.

Figure   SEQ Figure \* ARABIC  14 : Map of Roosevelt/Campobello
International Park 

 

  HYPERLINK "http://www.maine.gov/dep/air/meteorology/images/rcip.jpg" 
http://www.maine.gov/dep/air/meteorology/images/rcip.jpg 

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

source: Chessie Johnson, Roosevelt Campobello International Park
Commission

Modeling

Section 51.308(d)(3)(iii) of the Regional Haze Rule requires states to
document the technical basis, including modeling, monitoring and
emissions information, on which the state is relying to determine its
apportionment of emissions reduction obligations necessary for achieving
reasonable progress in each Class I area it affects.

Air quality modeling to assess regional haze has been done cooperatively
between Massachusetts and its regional planning organization, MANE-VU,
with major modeling efforts being conducted by NESCAUM and screening
modeling being conducted by the New Hampshire Department of
Environmental Services.  These modeling efforts include emissions
processing, meteorological input analysis, and chemical transport
modeling to conduct regional air quality simulations for calendar year
2002 and several future periods, including the primary target period for
this SIP, calendar year 2018.  Modeling was conducted in order to assess
contribution from upwind areas, as well as Massachusetts’ contribution
to Class I areas in downwind states.  Further, the modeling evaluated
visibility benefits of control measures being considered for achieving
reasonable progress goals and establishing a long-term emissions
management strategy for MANE-VU Class I areas.

The modeling tools utilized for these analyses include the following:

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

The Sparse Matrix Operator Kernel Emissions (SMOKE) emissions modeling
system was used to process and format the emissions inventories for
input into the air quality models.

The Community Mesoscale Air Quality model (CMAQ) was used for the
primary SIP modeling.

The Regional Model for Aerosols and Deposition (REMSAD) was used during
contribution apportionment.

The California Grid Model (CALGRID) and its associated EMSPROC6
emissions processor were used to screen specific control strategies.

The California Puff Model (CALPUFF) was used to assess the contribution
of individual states’ emissions to sulfate levels at selected Class I
receptor sites.

Each of these tools has been evaluated and found to perform adequately. 
The pertinent SIP modeling underwent full performance testing and the
results were found to meet the specifications of EPA modeling guidance.

For more details on the regional haze modeling, please refer to the
NESCAUM report MANE-VU Modeling for Reasonable Progress Goals, Model
Performance Evaluation, Pollution Apportionment, and Control Measure
Benefits (Appendix   REF _Ref201032634 \r \h  \* MERGEFORMAT  F ).  The
detailed modeling approach for the best and final 2018 projected
scenario can be found in the NESCAUM report 2018 Visibility Projections
(Appendix   REF _Ref201032635 \r \h  \* MERGEFORMAT  G ).

Meteorology

The meteorological inputs for the air quality simulations were developed
by the University of Maryland (UMD) using the MM5 meteorological
modeling system.  Meteorological inputs were generated for 2002 to
correspond with the baseline emissions inventory and analysis year.  The
MM5 simulations were performed on a nested grid as illustrated in Figure
16.  As shown in the figure, the modeling domain is comprised of a
36-km, 145 x 102 continental grid and a nested 12-km, 172 x 172 grid
encompassing the eastern United States and parts of Canada.  In
cooperation with the New York State Department of Conservation (NYSDEC),
an assessment was made to compare the MM5 predictions with observations
from a variety of data sources, including: 

surface observations from the National Weather Service (NWS) and the
Clean Air Status and Trends Network (CASTNet), 

wind-profiler measurements from the Cooperative Agency Profilers (CAP)
network,

satellite cloud image data from the UMD Department of Atmospheric and
Oceanic Science, and 

precipitation data from the Earth Observing Laboratory at NCAR.  This
assessment was performed for the period covering May through September
2002. 

Further details regarding the MM5 meteorological processing and the
modeling domain can be found in Appendix   REF _Ref197831308 \r \h  \*
MERGEFORMAT  H , NYSDEC’s Meteorological Modeling Using Penn
State/NCAR 5th Generation Mesoscale Model and Appendix   REF
_Ref201032634 \r \h  \* MERGEFORMAT  F , NESCAUM’s MANE-VU Modeling
for Reasonable Progress Goals.

Figure   SEQ Figure \* ARABIC  16 : Modeling domains used in MANE-VU
air quality modeling studies with CMAQ. 

Outer (blue) domain grid is 36 km and inner (red) domain is 12 km grid.
The gridlines are shown at 180 km intervals (5x5 for 36 km cells/15×15
for 12 km cells).

Emissions Data Preparations

Emissions data were prepared for input into the CMAQ and REMSAD air
quality models using the SMOKE emissions modeling system.  SMOKE
supports point, area, mobile (both on-road and non-road), and biogenic
emissions.  The SMOKE emissions modeling system uses flexible processing
to apply chemical speciation as well as temporal and spatial allocation
to the emissions inventories.  SMOKE incorporates the Biogenic Emission
Inventory System (BEIS) and EPA’s MOBILE6 motor vehicle emission
factor model to process biogenic and on-road mobile emissions,
respectively.  Vector-matrix multiplication is used during the final
processing step to merge the various emissions components into a single
model-ready emissions file.  Examples of processed emissions outputs are
shown in   REF _Ref199909485 \h  \* MERGEFORMAT  Figure 17 .

Further details on the SMOKE processing that was done in support of the
air quality simulations is provided in Appendix   REF _Ref197831308 \r
\h  \* MERGEFORMAT  H  and Appendix   REF _Ref194465893 \r \h  \*
MERGEFORMAT  I , NYSDEC’s Emission Processing for the Revised 2002 OTC
Regional and Urban 12 km Base Case Simulations.  Additional details on
the emission inventory preparation can be found in Section   REF
_Ref194463253 \w \h  \* MERGEFORMAT  6 .

Figure   SEQ Figure \* ARABIC  17 : Examples of processed model-ready
emissions: a) SO2 from Point, b) NO2 from Area, c) NO2 from On-road, d)
NO2 from Non-road, e) ISOP from Biogenic, f) SO2 from all source
categories

Model Platforms

Two regional-scale air quality models, CMAQ and REMSAD, were used for
the air quality simulations that directly supported the Regional Haze
SIP effort.  CMAQ was developed by EPA and was used to perform the
primary SIP-related modeling.  The CMAQ modeling simulations also were
an important tool for the 8-hour ozone SIP process.  REMSAD was
developed by ICF Consulting/Systems Applications International with
support from EPA.  REMSAD was used by NESCAUM to perform a source
apportionment 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 16 above.

NESCAUM performed a model performance evaluation for PM2.5 species,
aerosol extinction coefficient, and the haze index, which is provided in
Appendix   REF _Ref201032634 \r \h  \* MERGEFORMAT  F .  NYSDEC also
performed a model performance analysis to evaluate CMAQ model
predictions against observations of ozone, PM2.5, and other chemical
species, which is contained in Appendix   REF _Ref194465983 \r \h  \*
MERGEFORMAT  J , CMAQ Model Performance and Assessment, 8-Hr OTC Ozone
Modeling. 

CMAQ

The CMAQ air quality simulations were performed cooperatively between
five modeling centers, including NYSDEC, the New Jersey Department of
Environmental Protection (NJDEP) in association with Rutgers University,
the Virginia Department of Environmental Quality (VADEQ), UMD, and
NESCAUM.  NYSDEC also performed an annual 2002 CMAQ simulation on the
36-km domain shown in Figure 16; this simulation was used to derive the
boundary conditions for the inner 12-km eastern modeling domain. 
Boundary conditions for the 36-km simulations were 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 Appendix   REF _Ref194466049 \r \h  \*
MERGEFORMAT  K , NYSDEC’s Eight-Hour Ozone Modeling using the
SMOKE/CMAQ system. Further technical details regarding the CMAQ model
and its execution are also provided in Appendix   REF _Ref201032634 \r
\h  \* MERGEFORMAT  F .

REMSAD

The REMSAD modeling simulations were used to satisfy the haze rule
requirement that a pollution apportionment be performed to assess
contribution to visibility improvement by geographic region or source
sector.  REMSAD’s species tagging capability makes it an important
tool for this purpose.  This allowed for a rough estimation of the total
contribution from elevated point sources in each state to simulated
sulfate concentrations at eastern receptor sites.  Using identical
emission and meteorological inputs to those prepared for the Integrated
SIP (CMAQ) platform, REMSAD was used to simulate the annual average
impact of each state’s SO2 emission sources on the sulfate fraction of
PM2.5 over the northeastern United States using the same 12-km eastern
modeling domain as shown in Figure 16.  Appendix   REF _Ref201032634 \r
\h  \* MERGEFORMAT  F  further describes the REMSAD model and its
application to the Regional Haze SIP efforts. 

CALGRID

In addition to the SIP-quality modeling platforms described above, an
additional modeling platform was developed for use as a screening tool
to evaluate additional control strategies or to perform sensitivity
analyses.  The CALGRID model was selected as the basis for this
platform. CALGRID is a grid-based photochemical air quality model that
is designed to be run in a Windows environment.  In order to make the
CALGRID model the best possible tool to supplement the SIP-quality CMAQ
and REMSAD modeling, the current version of the CALGRID platform was set
up to be run with the same set of inputs as the SIP-quality models.  The
CALGRID air quality simulations were run on the same 12-km eastern
modeling domain that was used for CMAQ and REMSAD.  This model’s
performance was relative to the performance of the already evaluated
CMAQ and REMSAD models and was thus determined to perform adequately.

Conversion utilities were developed to re-format the meteorological
inputs, the boundary conditions, and the emissions for use with the
CALGRID modeling platform.  Pre-merged SMOKE emissions files were
obtained from the modeling centers and re-formatted for input into
EMSPROC6, the emissions pre-processor for the CALGRID modeling system. 
EMSPROC6 allows the CALGRID user to adjust emissions temporally,
geographically, and by emissions category for control strategy analysis.
 The pre-merged SMOKE files that were obtained from the modeling centers
were broken down into the biogenic, point, area, non-road, and on-road
emissions categories.  These files by component were then converted for
use with EMSPROC6, thus giving CALGRID users the flexibility to analyze
a wide variety of emissions control strategies.  Additional information
on the CALGRID modeling platform can be found in Appendix   REF
_Ref194466396 \r \h  \* MERGEFORMAT  L , NHDES’ Modeling Protocol for
the OTC CALGRID Screening-Level Modeling Platform for the Evaluation of
Ozone. 

CALPUFF

CALPUFF is a non-steady-state Lagrangian puff model that simulates the
dispersion, transport, and chemical transformation of atmospheric
pollutants.  Two parallel CALPUFF modeling platforms were developed by
the Vermont Department of Environmental Conservation (VTDEC) and the
Maryland Department of the Environment (MDE). The VTDEC CALPUFF modeling
platform utilized meteorological observation data from the National
Weather Service (NWS) to drive the CALMET meteorological model.  The MDE
platform utilized the same MM5 meteorological inputs that were used in
the modeling done in support of the ozone and Regional Haze SIPs.  These
two platforms were run in parallel to evaluate individual states’
contributions to sulfate levels at Northeast and Mid-Atlantic Class I
areas.  The CALPUFF modeling effort is described in detail in Appendix  
REF _Ref191968764 \r \h  \* MERGEFORMAT  A .

Emissions Inventory

Section 51.308(d)(4)(v) of the Regional Haze Rule requires a statewide
emission 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.
 Massachusetts’ baseline year is 2002.  The pollutants inventoried by
Massachusetts for 2002 include volatile organic compounds (VOCs),
nitrogen oxides (NOx), carbon monoxide (CO), sulfur dioxide (SO2), fine
particles (PM2.5), coarse particles (PM10), and ammonia (NH3).  The
emission inventory consists of the following source categories:
stationary point, area, on-road mobile, off-road mobile, and biogenics. 
These source categories are discussed further below and in Section 7. 

Baseline and Future Year Emission Inventories for Modeling

Section 51.308(d)(3)(iii) of EPA’s Regional Haze Rule requires
Massachusetts to identify the baseline emission inventory on which
strategies are based.  The baseline inventory is used to assess progress
in making emissions reductions.  Based on EPA guidance entitled, 2002
Base Year Emission Inventory SIP Planning: 8-hour Ozone, PM2.5, and
Regional Haze Programs, which identifies 2002 as the anticipated
baseline emission inventory year for regional haze, MANE-VU and
Massachusetts used 2002 as the baseline year.  Future year inventories
were developed for the years 2009 and 2018 based on the 2002 base year. 
These future year emission inventories include emissions growth due to
projected increases in economic activity, as well as the emissions
reductions due to the implementation of control measures.  In many
instances, states already have submitted their 2002 base year SIP
inventories to EPA due to their planning obligations under the ozone
and/or PM programs.  Massachusetts submitted its 2002 inventory to EPA
on January 31, 2008.

Emission inventories are not static documents, but are constantly
revised and updated to reflect the input of better emission estimates as
they become available.  Therefore, even though the 2002 “SIP”
inventories and the 2002 “modeling” inventories both represent
emissions from 2002, they may contain slightly different emission
estimates due to the different time frames they were made available, and
the different purposes each serves.  

Accurate baseline and future emissions inventories are crucial to the
analyses required for the Regional Haze SIP process.  These emissions
inventories were used to drive the air quality modeling simulations that
were performed to assess the visibility improvement of potential control
measures.  Air quality modeling also was used to perform a pollution
apportionment, which evaluates the contribution to visibility impairment
by geographic region and by emission sector.  In order to be used in the
air quality modeling simulations, the baseline and future year emissions
inventories were processed with SMOKE emissions pre-processor for
subsequent input into CMAQ and REMSAD air quality models that were
described in Section 5.

MANE-VU Regional Baseline Inventory

The starting point for the 2002 baseline emissions inventory was the
2002 inventory submittals that were made to EPA by state and local
agencies as part of the Consolidated Emissions Reporting Rule (CERR). 
With contractor assistance (E.H. Pechan & Associates), MANE-VU
coordinated and quality assured the 2002 inventory data, and prepared it
for input into the SMOKE emissions model.  The 2002 emissions from
non-MANE-VU areas within the modeling domain were obtained from other
Regional Planning Organizations for their corresponding areas.  These
RPOs included VISTAS, MWRPO, and CenRAP.

The 2002 baseline inventory went through several iterations.  Work on
Version 1 of the 2002 MANE-VU inventory began in April 2004, and the
final inventory and SMOKE input files were finalized during January
2005.  Work on Version 2 (used from April through September 2005)
involved incorporating revisions requested by some MANE-VU state/local
agencies on the point, area, and on-road categories.  Work on Version 3
(used from December 2005 through April 2006) included additional
revisions to the point, area, and on-road categories as requested by
some states.  Thus, the Version 3 inventory for point, area, and on-road
sources was built upon Versions 1 and 2.  This work also included
development of the biogenic inventory.  In Version 3, the non-road
inventory was completely redone because of changes that EPA made to the
NONROAD2005 non-road mobile emissions model. 

Version 3 of the 2002 base year emissions inventory was used in the
regional air quality modeling simulations.  Further description of the
data sources, methods, and results for this version of the 2002 baseline
inventory is presented in a technical support document, Appendix   REF
_Ref198002744 \r \h  \* MERGEFORMAT  M .  Emissions inventory data files
are available on the MARAMA website at   HYPERLINK
"http://www.marama.org/visibility/EI_Projects/index.html" 
www.marama.org/visibility/EI_Projects/index.html . 

After release of Version 3.0 of the MANE-VU 2002 inventory,
Massachusetts revised its inventory of area source heating oil emissions
due to two changes.  First, the sulfur percent used to derive the
emissions factors was adjusted from 1.0 to 0.3 because the Massachusetts
draft 2002 SO2 emissions methodology for commercial and residential
distillate fuel used the EPA default sulfur content of 1% instead of the
correct 0.3% value that was implemented in 2001 according Massachusetts
regulation 310 CMR 7.05(1) and (2).  Second, the latest DOE-EIA 2002
fuel use data was used instead of the previous version used in 2001. 
These two changes significantly altered the 2002 SO2 emissions for area
source heating oil combustion.  Massachusetts provided revised 2002 PE
and EM tables, which MACTEC used in preparing the 2009/2012/2018
projection inventories. 

Massachusetts Baseline Inventory

Massachusetts submitted to EPA in January 2008 its comprehensive 2002
Base Year Emissions Inventory that serves as a baseline for its 8-Hour
Ozone, Carbon Monoxide (CO), and Regional Haze SIPS.  The 2002 Inventory
was estimated for a typical summer day for the ozone precursors VOC, NOx
and CO.  CO also was estimated for a typical winter day for the CO SIP. 
Annual emissions were estimated for VOCs, NOx, CO, SO2, PM2.5, PM10, and
NH3, as required as a baseline for this Regional Haze SIP. 

 

The complete MA 2002 Base Year Inventory is part of the Massachusetts
8-Hour Ozone Attainment Demonstration SIP and is available on
MassDEP’s web site at:   HYPERLINK "
http://www.mass.gov/dep/air/priorities/sip.htm"  
http://www.mass.gov/dep/air/priorities/sip.htm .   It contains an
extensive narrative explaining the methodology for the development of
the inventory and the extensive data files supporting the emission
estimates.

Massachusetts originally submitted emissions inventory data
electronically to the EPA National Emissions Inventory (NEI) system and
subsequently made revisions as a result of Quality Assurance (QA)
procedures.  The point source submittal included detailed facility level
information, activity data down to the segment level, and annual VOCs,
NOx, CO, SO2, PM2.5, PM10, and NH3 emissions.  Massachusetts also
electronically submitted area source activity data, emission factors,
temporal factors, control factors, annual emissions for all pollutants,
and typical summer day (VOC, NOx and CO) and winter day (CO only)
emissions.  Emissions data for point and area sources were submitted to
EPA in its required NEI format.

For on-road and off-road mobile emissions, Massachusetts estimated
typical summer and winter day emissions in the 2002 Base Year Inventory.
 However, for annual emissions Massachusetts relied on MANE-VU
contractors to perform the twelve monthly model runs from EPA’S
MOBILE6.2 for on-road emissions and the NONROAD model for off-road
emissions.  In order to estimate annual emissions from on-road mobile
sources, Massachusetts submitted to the MANE-VU contractor the necessary
MOBILE6.2 inputs such as monthly temperature and I/M scenarios together
with other transportation parameters such as daily vehicle miles
travelled, vehicle registration data, and speeds by county roadway
class.  Massachusetts also provided temperature and other inputs to
MANE-VU contractors for running the NONROAD model in order to estimate
annual emissions.  The resulting on-road mobile and off-road mobile
annual emissions generated by the MANE-VU contractor were used in the
2002 Base Year Emissions Inventory.

EPA estimated 2002 Biogenic emissions for all counties in the US using
its Biogenic Emissions Inventory System (BEIS-3) and Massachusetts used
these summer day and annual emissions in the 2002 Base Year Emission
Inventory for VOC, NOx, and CO.

The emissions data submitted to EPA-NEI was accessed, analyzed, and
summarized by the MANE-VU contractors and modelers initially as part of
the QA process and modeling for 8-hour Ozone and Regional Haze. 

A summary of the Massachusetts 2002 Base Year Emission Inventory is
presented in   REF _Ref196790899 \h  \* MERGEFORMAT  Table 8 , which is
contained in Section 6.5.  The 2018 projected Massachusetts emissions in
  REF _Ref196790899 \h  \* MERGEFORMAT  Table 8  were adapted from a
MANE-VU summary based on growth and control factors from 2002.  

Future Year Emission Control Inventories 

A technical support document for the future year inventories is included
in Appendix   REF _Ref191969187 \r \h  \* MERGEFORMAT  N  and explains
the data sources, methods, and results for future year emission
forecasts for three years, five emission sectors, three emission control
scenarios, seven pollutants, and eleven states plus the District of
Columbia.  The following is a summary of the future year inventories
that were developed:

Projection years:  2009, 2012, and 2018;

Emission source sectors:  point-source electric generating units (EGUs),
point-source non-electric generating units (non-EGUs), area sources,
non-road mobile sources, and on-road mobile sources.

Emission control scenarios:

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

A beyond-on-the-way (BOTW) scenario to account for controls from
potential new regulations that may be necessary to meet attainment and
other regional air quality goals, mainly for ozone.

An updated scenario (sometimes referred to as “best and final”) to
account for additional potentially reasonable control measures.  For the
MANE-VU region, these include: SO2 reductions at a set of 167 EGU stacks
that were identified as contributing to visibility impairment at
northeast Class I areas; implementation of a low-sulfur fuel strategy
for non-EGU sources; and implementation of a BART strategy for
BART-eligible sources not controlled under other programs.

(Note:  Refer to Section 10, Long-Term Strategy, for detailed
descriptions of specific control strategies, including the uncertainty
inherent in OTB and BOTW strategies)

Pollutants:  ammonia, carbon monoxide (CO), oxides of nitrogen (NOX),
sulfur dioxide (SO2), volatile organic compounds (VOCs), fine
particulate matter (PM2.5, sum of filterable and condensable
components), and coarse particulate matter (PM10, sum of filterable and
condensable components).

States:  Connecticut, Delaware, Maine, Maryland, Massachusetts, New
Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, and
Vermont, plus the District of Columbia (all members of the MANE-VU
region).

Emission Processor Selection and Configuration

The SMOKE Processing System is principally an emissions processing
system, as opposed to a true emissions inventory preparation system, in
which emissions estimates are simulated from “first principles.” 
This means that, with the exception of mobile and biogenic sources, its
purpose is to provide an efficient, modern tool for converting emissions
inventory data into the formatted emissions files required for a
photochemical air quality model. (SMOKE does generate emissions for
on-road mobile and biogenic emissions, however, by driving the MOBILE6
and BEIS emissions models.)

Inside the MANE-VU region, the modeling inventories were processed by
NYSDEC and NESCUAM using the SMOKE (Version 2.1) processor to provide
inputs for the CMAQ model.  A detailed description of all SMOKE input
files such as area, mobile, fire, point and biogenic emissions files,
and the SMOKE model configuration are provided in Appendix   REF
_Ref194466049 \r \h  \* MERGEFORMAT  K .

Inventories for Specific Source Types

There are five emission source classifications in the emissions
inventory:

stationary point 

stationary area

non-road mobile

on-road mobile

biogenic  

Stationary point sources are large sources that emit greater than a
specified tonnage per year. Stationary area sources are those whose
emissions from individual sources are relatively small, but due to the
large number of these sources the collective emissions could be
significant (i.e., dry cleaners, service stations, agricultural sources,
fire emissions, etc.).  Non-road mobile sources are equipment that can
move, but do not use the roadways (i.e., lawn mowers, construction
equipment, railroad locomotives, aircraft, etc.)  On-road mobile sources
are automobiles, trucks, and motorcycles that use the roadway system. 
The emissions from these sources are estimated by vehicle type and road
type.  Biogenic sources are natural sources like trees, crops, grasses,
and the natural decay of plants.  For stationary point sources,
emissions data is tracked at the facility level.  For all other source
types, emissions are summed on the county level.  All emissions were
prepared for modeling in accordance with EPA guidance.

Stationary Point Sources

Point source emissions are emissions from large individual sources.
Generally, point sources have permits to operate and their emissions are
individually calculated based on source specific factors on a regular
schedule.  The largest point sources are inventoried annually.  These
are considered to be major sources having emissions of ≥ 50 to100 tons
per year (tpy) of a criteria pollutant, ≥ 10 tpy of a single hazardous
air pollutant (HAP) or ≥ 25 tpy of total HAPs. Emissions from smaller
stationary point sources in Massachusetts also are calculated
individually, but less frequently, on a triennial basis.  Point sources
are grouped into EGU sources and other non-EGU industrial point sources.

Electric Generating Units

The base year inventory for EGU sources used 2002 continuous emissions
monitoring (CEM) data reported to EPA in compliance with the Acid Rain
program or 2002 hourly emission data provided by stakeholders.  These
data provide hourly emissions profiles that can be used in the modeling
of SO2 and NOx emissions from these large sources.  Emission profiles
are used to estimate emissions of other pollutants (volatile organic
compounds, carbon monoxide, ammonia, and fine particles) based on
measured emissions of SO2 and NOx.

Future year inventories of EGU emissions for 2009 and 2018 were
developed using the IPM model to forecast growth in electric demand and
replacement of older, less efficient and more polluting power plants
with newer, more efficient and cleaner units.  While the output of the
IPM model predicts that a certain number of older plants will be
replaced by newer units to meet future electricity growth and
state-by-state NOx and SO2 caps, Massachusetts did not directly rely
upon the closure of any particular plant in establishing the 2018
inventory upon which the reasonable progress goals were set. 

The IPM model results are not the basis upon which to reliably predict
plant closures. Preliminary modeling was thus performed with unchanged
IPM 2.1.9 model results.  However, prior to the Best and Final Modeling
(Appendix G), future year EGU inventories were modified.

First, IPM predictions were reviewed by MANE-VU permitting and
enforcement staff.  In many cases, staff felt that the IPM shutdown
predictions were unlikely to occur.  In particular, IPM predicted that
many oil-fired EGUs in urban areas would be shutdown.  Similar source
information was solicited from states in both VISTAS and MRPO.  As a
result of this model validation, the IPM modeling output was adjusted
before the Best and Final modeling (Appendix G) to reflect staff
knowledge of specific plant status in MANE-VU, VISTAS, and MRPO states. 
Where EGU operating status was contrary to what was predicted by IPM
modeling, the future year emissions inventory was adjusted to reflect
the operation of those plants expected by state staff.

Second, as a result of inter- and intra- RPO consultations, MANE-VU
agreed to pursue certain control measures as described in the Long-Term
Strategy section.  For EGUs, the agreed upon approach was to reduce
emissions from 167 stacks located in MANE-VU, MRPO and VISTAS by 90
percent, as described further in the Long-Term Strategy.

Non-EGU Point Sources

The primary basis for the 2002 baseline non-EGU emissions were those
that were reported by state and local agencies for the CERR.  As
described above, MANE-VU’s contractor, E.H. Pechan & Associates
(Pechan) coordinated the QA of the inventory and prepared the necessary
files for input into the SMOKE emissions model.  Further information on
the preparation of the MANE-VU 2002 baseline point source modeling
emissions inventory can be found in Chapter II of the Technical Support
Document for 2002 MANE-VU SIP Modeling Inventories (Appendix   REF
_Ref198002744 \r \h  M ).

Projected non-EGU point source emissions were developed for the MANE-VU
region by MACTEC Federal Programs, Inc. under contract to MARAMA.  The
specific methodologies that were used are described in Appendix   REF
_Ref191969187 \r \h  \* MERGEFORMAT  N , Development of Emissions
Projections For 2009, 2012, and 2018 For NonEGU Point, Area, and Nonroad
Source In the MANE-VU Region.  MACTEC used state-supplied growth factor
data where available to project future year emissions.  Where
state-supplied data was not available, MACTEC used EPA’s Economic
Growth and Analysis System Version 5.0 (EGAS 5.0) to develop applicable
growth factors for the non-EGU component.  MACTEC also incorporated the
applicable federal and state emissions control programs to account for
the expected emissions reductions that will take place under the OTB/OTW
and BOTW scenarios.

Stationary Area Sources

Stationary area sources include sources whose individual emissions are
relatively small but due to the large number of these sources, their
collective emissions are significant.  Some examples include dry
cleaners, service stations, and the combustion of fuels for heating. 
Area source emissions are estimated by multiplying an emission factor by
some known indicator of collective activity, such as fuel use, number of
households, or population.

The area source emissions inventory submittals made for the CERR became
the basis for the area source portion of the 2002 baseline inventory. 
Similar to the point source category, Pechan, on behalf of MANE-VU,
prepared the area source modeling inventory using the CERR submittals as
a starting point.  Pechan quality assured the inventory and augmented it
with additional data, including MANE-VU-sponsored inventories for
categories such as residential wood combustion and open burning. 
Detailed information on the preparation of the MANE-VU 2002 baseline
area source modeling emissions inventory can be found in Chapter III of
Appendix   REF _Ref198002744 \r \h  M .

Similar to non-EGU point sources, future year area source emissions were
projected for the MANE-VU region by MACTEC.  The specific methodologies
used are described in Section 3 of Appendix   REF _Ref191969187 \r \h  N
.  MACTEC applied growth factors to the 2002 baseline area source
inventory using state-supplied data where available or by using the EGAS
5.0 growth factor model.  MACTEC also accounted for the appropriate
control strategies in the future year projections.

Non-Road Mobile Sources

Non-road mobile sources are equipment that can move but do not use the
roadways, such as construction equipment, aircraft, railroad
locomotives, and lawn and garden equipment.  For the majority of
non-road mobile sources, emissions are estimated using the EPA’s
NONROAD model.  Aircraft, railroad locomotives, and commercial marine
vessels are not included in the NONROAD model, and their emissions are
estimated using applicable references and methodologies.  Again, Pechan
prepared the 2002 baseline modeling inventory using the state and local
CERR submittals as a starting point.  Details on the preparation of the
2002 baseline non-road inventory are described in Chapter IV of Appendix
  REF _Ref198002744 \r \h  M . 

Future year non-road mobile source emissions were projected for the
MANE-VU region by MACTEC.  The methodologies that were used are
discussed in Section 4 of Appendix   REF _Ref191969187 \r \h  N .  In
summary, MACTEC used EPA’s NONROAD2005 non-road vehicle emissions
model as contained in EPA’s National Mobile Inventory Model.  Since
calendar year is an explicit input into the NONROAD model, future year
emissions for non-road vehicles could be calculated for the applicable
projection years.  For the non-road vehicle types that are not included
in the NONROAD model (i.e. aircraft, locomotives, and commercial marine
vessels), MACTEC used the 2002 baseline inventory and the projected
inventories that EPA developed for these categories for the Clean Air
Interstate Rule (CAIR) to develop emission ratios and subsequent
combined growth and control factors.  Since the future years for the
CAIR projections did not directly match those required for the purposes
of ozone, particulate matter, and regional haze analyses (i.e., 2009,
2012, and 2018), MACTEC used linear interpolation to develop factors for
the required future years.

On-Road Mobile Sources

The on-road emissions source category is comprised of those vehicles
that are meant to travel on public roadways, including cars, trucks,
buses, and motorcycles.  The basic methodology used for on-road mobile
source calculations is to multiply vehicle-miles-traveled (VMT) data by
emission factors developed using EPA’s MOBILE6 motor vehicle emission
factors model.  Unlike the other emissions source categories, the
on-road mobile category requires that SMOKE model inputs be prepared,
rather than emissions data in SMOKE/IDA format that the other categories
require.  Therefore, for the 2002 baseline inventory, Pechan prepared
the necessary VMT and MOBILE6 inputs in SMOKE format.

Projected on-road mobile source inventories were developed by NESCAUM
for the MANE-VU region for ozone, particulate matter, and Regional Haze
SIP purposes.  As with the other emissions source categories, projected
on-road mobile inventories were developed for calendar years 2009, 2012,
and 2018.  As part of this effort, MANE-VU member states were asked to
provide VMT data and MOBILE6 model inputs for the applicable calendar
years.  Using the inputs supplied by the MANE-VU member states, NESCAUM
compiled and generated the required SMOKE/MOBILE6 emissions model
inputs.  Further details regarding the on-road mobile source projection
can be found in Appendix   REF _Ref218496233 \r \h  O , Development of
MANE-VU Mobile Source Projection Inventories for SMOKE/MOBILE6
Application.

Biogenic Emission Sources

For the purposes of the 2002 baseline modeling emissions inventory,
biogenic emissions were calculated for the modeling domain by the New
York State Department of Environmental Conservation (NYSDEC).  NYSDEC
used the BEIS Version 3.12 as contained within the SMOKE emissions
processing model.  Biogenic emissions estimates were made for CO,
nitrous oxide (NO) and VOC.  Further details about the biogenic
emissions processing can be found in NYSDEC’s Technical Support
Document 1c, Emission Processing for the Revised 2002 OTC Regional and
Urban 12 km Base Case Simulations, September 19, 2006, and in Chapter VI
(Biogenic Sources) of the Technical Support Document for 2002 MANE-VU
SIP Modeling Inventories, Version 3, November 20, 2006.  Biogenic
emissions were assumed to remain constant for the future analysis years.

Summary of MANE-VU 2002 and 2018 Emissions Inventory

  REF _Ref191279648 \h  \* MERGEFORMAT  Table 6  and Table 7 summarize
the emissions inventories for the MANE-VU region compiled for 2002 and
projected for 2018.  The amount of pollutants (in tons per year) emitted
from the various source categories is presented.  This information was
useful in setting reasonable progress goals by states containing Class I
areas (Section 9) and in determining the long-term strategy (Section 10)
to address the contribution of Massachusetts to regional haze in Class 1
areas.  

Table   SEQ Table \* ARABIC  6 : MANE-VU 2002 Emissions Inventory
Summary (tons)

 	VOC	NOx	CO	PM2.5	PM10	NH3	SO2

Point	97,300	673,660	367,645	55,447	89,150	6,194	1,907,634

Area	1,528,141	262,477	1,325,853

	332,729

	1,455,311	249,795	316,357

On-Road Mobile	789,560	1,308,233	11,749,819	22,107	31,561	52,984	40,091

Non-Road Mobile	572,751	431,631	4,553,124	36,084	40,114	287	57,257

Biogenics	2,575,232	28,396	274,451	-	-	-	-

TOTAL	5,562,984	2,704,397	18,260,892	446,367	1,616,136	309,260	2,321,339

Source: Pechan, 2006. "Technical Support Document for 2002 MANE-VU SIP
Modeling Inventories, Version 3." November 20, 2006. Appendix   REF
_Ref198002744 \r \h  \* MERGEFORMAT  M 

Table   SEQ Table \* ARABIC  7 : MANE-VU 2018 Emissions Inventory
Summary (in tons)

 	VOC	NOx	PM2.5	PM10	NH3	SO2

Point	114,290	374,952	93,267	128,483	11,136	598,520

Area 	1,334,038	263,031	243,321	720,462	341,746	129,656

On-Road Mobile	269,981	303,955	9,189	9,852	66,476	8,757

Non-Road Mobile	380,076	271,181	23,933	27,055	360	8,643

Biogenics	2,575,232	28,396	-	-	-	-

TOTAL	4,673,617	1,241,515	369,710	885,852	419,718	745,576

Source: MACTEC, 2007. "Development of Emission Projections for 2009,
2012, and 2018 for non-EGU Point, Area, and Nonroad Sources in the
MANE-VU Region." February 28, 2007.  Appendix   REF _Ref191969187 \r \h 
\* MERGEFORMAT  N 

EGU Point Emissions: VISTAS_PC_1f  IPM Run, Appendix   REF _Ref197835294
\r \h  \* MERGEFORMAT  W   

Summary of Massachusetts 2002 Base and 2018 Projected Emissions and
Reductions 

  REF _Ref196790899 \h  \* MERGEFORMAT  Table 8  presents the
Massachusetts inventories for the 2002 base year and for the 2018
projected emissions and expected reductions.  The MANE-VU 2002 and 2018
emission summary and reductions, derived from   REF _Ref191279648 \h 
Table 6  and Table 7, also are presented for comparison.   REF
_Ref196790899 \h  Table 8  shows that Massachusetts’ overall projected
reduction of total regional haze pollutants between 2002 and 2018 is 38
percent.  This is closely comparable to MANE-VU’s overall reduction of
36 percent for the same period.  Thus, actions taken to reduce
Massachusetts’ emissions are projected to meet the objectives of the
MANE-VU Reasonable Progress Goals.

Table   SEQ Table \* ARABIC  8 : Massachusetts 2002 Base Year and 2018
Projected Emissions and Reductions (in tons)

	VOC	NOx	CO	SO2	PM10	PM2.5	NH3	RH TOTAL

MA 2002 BASE YEAR









POINT > 1 TPY1	                5,647 	              45,590 	            
    21,403 	              101,049 	             5,852 	             
4,161 	             1,526 

	AREA2	            159,753 	               34,371 	              
137,278 	              25,585 	          191,369 	         43,203 	     
    16,786 

	ON-ROAD MOBILE3	               57,186 	            143,368 	           
1,039,100 	                 4,399 	             3,408 	            
2,410 	            5,499 

	OFF-ROAD MOBILE4	              56,749 	              42,769 	          
     461,514 	                  3,791 	              3,531 	           
3,226 	                  28 

	BIOGENICS5	             113,957 	                 1,257 	              
   11,594 	 - 	 - 	 - 	 - 

	MA 2002 ANTHROPOGENIC	    279,335 	    266,098 	    1,659,295 	    
134,824 	   204,160 	   53,000 	   23,839 

	MA 2002 WITH  BIOGENICS	    393,292 	    267,355 	    1,670,889 	    
134,824 	   204,160 	   53,000 	   23,839 	   1,076470 



MA 2018 PROJECTED YEAR









POINT > 1 TPY6	               10,902 	              40,458 	            
   27,286 	              55,878 	              9,137 	            6,827 
             1,622 

	AREA7	            134,963 	               36,199 	              
125,205 	                  1,804 	           82,027 	          31,237 	 
        19,552 

	ON-ROAD MOBILE8	               17,056 	               22,813 	         
     515,460 	                  1,937 	                 893 	           
   840 	             5,817 

	OFF-ROAD MOBILE9	              36,306 	              27,040 	          
   546,373 	                    442 	             2,246 	           
2,052 	                  36 

	BIOGENICS10	             113,958 	                 1,257 	             
    11,594 	 - 	 - 	 - 	 - 

	MA 2018 ANTHROPOGENIC	     199,227 	      126,510 	    1,214,324 	     
 60,061 	    94,303 	   40,956 	   27,027 

	MA 2018 WITH BIOGENICS	      313,185 	     127,767 	    1,225,918 	    
  60,061 	    94,303 	   40,956 	   27,027 	     663,299 

MA 2002-2018 REDUCTION	               80,107 	            139,588 	     
         444,971 	              74,763 	         109,857 	         
12,044 	           (3,188)	       413,171 

MA 2002-2018 REDUCTION %	20.4%	52.2%	26.6%	55.5%	53.8%	22.7%	-13.4%
38.4%











MANEVU 2002 WITH BIOGENICS11	 5,562,984 	 2,704,397 	  18,260,892 	 
2,321,339 	 1,616,136 	 446,367 	 309,260 	   12,960,483 

MANEVU 2018 WITH BIOGENICS11	  4,673,617 	   1,241,515 	  13,728,087 	  
  745,576 	  885,852 	  369,710 	   419,718 	 8,335,988 

MANEVU 2002-18 REDUCTION %	16.0%	54.1%	24.8%	67.9%	45.2%	17.2%	-35.7%
35.7%











 1. VOC & NOx Point emissions are from MA 2002 Base Year Inventory with
cut-offs at >10 TPY.  Because CO, SO2, PM10, PM2.5 and NH3 Point
emissions 

     cut-off was 100 TPY for the MA 2002 Inventory, Massachusetts used
MANE-VU's Point emissions that were counted down to 1 TPY.  MANE-VU

     used EPA-NEI, in which EPA 'gap-filled' and augmented the Primary
PM10 and PM2.5 emissions to include condensables (which most states do
not report).

     This is explained in EPA's Point Source Inventory Documentation:
http://www.epa.gov/ttn/chief/net/2002inventory.html (EI QA and Data
Augmentation)

 2. Area Source 2002 emissions from MA 2002 Base Year Inventory.  MA
original Area fuel SO2 was 54,924 TPY and was revised to 25,585 TPY. 

     This revision was due to a change in the assumed sulfur content,
but was not included in MANE-VU Version 3 inventory; hence the original
value was modeled.

 3. From Pat Davis (MARAMA) April 25 2006 e-mail attachments 'V3 2002
MANEVU OnRoad Source filed in ks/MANEVU-Projections.



 4. From MACTEC 2009-12-18 Projections, Tables 4.2a to 4.8c, Feb.07
http://marama.org/visibility/Inventory%20Summary/FutureEmissionsInventor
y.htm 

 5. 2002 emissions- MA 2002 Base Year Emission Inventory -Originally
from Pat Davis 4/25/2006 e-mail attachment "V3 2002 MANE-VU Biogenic
Sources"

 6. Non-EGU from MACTEC 2009, 2012 & 2018 Projections Report Tables 5-6
to 5-12, Feb.2007 http://marama.org/visibility/inventory%20Summary/ 

      Future/EmissionsInventory.htm. EGU projections from MACTEC FTP
Website & http://marama.org/visibility/EI-Projects/index.html 

	      StateLevelSummarym02.xls Emissions 08/04/2005. 







 7. From MARAMA/MACTEC 2009, 2012 & 2018 Projections Report Tables 5-17
to 5-23, Feb.2007. SO2 and other pollutants were adjusted for the
effects 

      of RPG Low Sulfur %. Pat Davis 3/28/08 e-mail attachment: 2108
Best & Final-All-Pollutants-Emiss-032808.xls. Julie McDill 3/17/2008
e-mail re RPG. 

 8. From Pat Davis e-mail Mar-11-2008 NESCAUM 2018 MOBILE6.2 annual
runs. File:ks/RH-SIP-Mobile-2018-sum-MV. 



 9. From MACTEC 2009-12-18 Projections, Tables 4.2a to 4.8c, Feb.07
http://marama.org/visibility/Inventory%20Summary/FutureEmissionsInventor
y.htm 

10. From MA 2002 Base Year Emission Inventory -originally from Pat Davis
4/25/2006 e-mail attachment "V3 2002 MANE-VU Biogenic Sources"

11. From MANE- VU Draft SIP Inventory Template Section 7.6, October
2007. From MACTEC 2/07 "Development Emissions Projections 2009, 2012 &
2018

     & Julie McDill's (MARAMA) 3/17/08 e-mail with revised 2018 SO2
emissions due to RPG low sulfur %.







Understanding the Sources of Visibility-Impairing 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.

Visibility-Impairing Pollutants

The pollutants primarily responsible for fine particle formation, and
thus contributing to regional haze, include SO2, NOx, VOCs, NH3, PM10,
and PM2.5.  The MANE-VU Contribution Assessment (Appendix   REF
_Ref191968764 \r \h  \* MERGEFORMAT  A ), finalized in August 2006,
reflects a conceptual model in which sulfate emerges as the most
important single constituent of haze-forming fine particle pollution and
the principle cause of visibility impairment across the Northeast
region.  Sulfate alone accounts for anywhere from one-half to two-thirds
of total fine particle mass on the 20 percent haziest days at MANE-VU
Class I sites.  This translates to about two-thirds to three-fourths of
visibility extinction on those days.  Organic carbon was shown to be the
second largest contributor to haze.  As a result of the dominant role of
sulfate in the formation of regional haze in the Northeast and
Mid-Atlantic Regions, MANE-VU concluded that an effective emissions
management approach would rely heavily on broad-based regional SO2
control measures in the eastern United States.

Visibility extinction is a measure of the ability of particles to
scatter and absorb light. Extinction is expressed in units of inverse
mega-meters (Mm-1).    REF _Ref199911487 \h  \* MERGEFORMAT  Figure 18 
shows the dominance of sulfate (bottom yellow bar) in visibility
extinction calculated from 2000-2004 baseline data.

Figure   SEQ Figure \* ARABIC  18 : Contributions to PM2.5 Extinction at
Seven Class I Sites

Contributing States and Regions

The MANE-VU Contribution Assessment used various modeling techniques,
air quality data analysis, and emissions inventory analysis to identify
source categories and states that contribute to visibility impairment in
MANE-VU Class I areas.  With respect to sulfate, based on estimates from
four different techniques, the Contribution Assessment estimated that
emissions from within MANE-VU in 2002 were responsible for about 25-30
percent of the sulfate at MANE-VU and nearby Class I areas. (Emissions
from other regions, Canada, and outside the modeling domain also were
important).    REF _Ref194726328 \h  \* MERGEFORMAT  Table 9  shows the
results of one of the four methods of assessing state-by-state
contributions to sulfate impacts (the REMSAD model).  This table
highlights the importance of emissions from outside the MANE-VU region. 
Note that percentage contributions differ between methods. 

Table   SEQ Table \* ARABIC  9 : Percent of Annual Average Modeled
Sulfate Due to Emissions from Listed States

Contributing States or Areas	

Acadia, Maine

(%)	

Brigantine, New Jersey

(%)	

Dolly Sods, West Virginia

(%)	Great Gulf and Presidential Range Dry River, New Hampshire

(%)	

Lye Brook, Vermont

(%)	

Moosehorn

and Roosevelt Campobello,Maine

(%)	

Shenandoah, Virginia

(%)

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

Midwest RPO	11.98	18.16	30.26	20.10	21.48	10.40	26.84

VISTAS	8.49	21.99	36.75	12.04	13.65	6.69	33.86

Other	43.36	25.02	18.18	40.03	33.09	52.83	18.71



Figures 19 and 20 are from the Contribution Assessment and show another
method used to identify and rank states’ contributions to sulfate at
MANE-VU and nearby Class I areas using 2002 data.  This simple technique
for deducing the relative impact of emissions from specific point
sources on a specific receptor site involves calculating the ratio of
annual emissions (Q) to source-receptor distance (d).  This Q/d ratio is
then multiplied by a factor designed to account for the effects of
prevailing winds and to convert units.  The use of this technique is
explained in the Contribution Assessment.

Based on the results of the Q/d technique, Figures 19 and 20 show the
resulting rankings across a set of northern and southern Class I areas
in or near MANE-VU.  Figure 19 covers the four northern Class I areas in
MANE-VU (Lye Brook, Great Gulf, Acadia, and Moosehorn).  Figure 20
covers one Class I area in the southern part of MANE-VU (Brigantine) as
well as two neighboring Class I areas in the VISTAS region (Dolly Sods
and Shenandoah).  Massachusetts ranks tenth in annual average sulfate
contributions to Northeast Class I areas in Figure 19 and 23rd for the
Mid-Atlantic Class I areas in Figure 20.  For more details about the
methods used to identify contributing states and regions, please see the
Contribution Assessment.  Note the importance of emissions from Canada
and from various states outside of the MANE-VU region.  

Figure   SEQ Figure \* ARABIC  19 : Ranked state percent sulfate
contributions to Northeast Class I receptors based on emissions divided
by distance (Q/d) results

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

The ranking of emission contributions to visibility impairment in the
MANE-VU Class I areas by methods such as these has direct relevance to
the consultation process described previously in Section 3.  Using
results from the REMSAD model, MANE-VU applied the following three
criteria to identify states and regions for the purposes of consultation
on regional haze:

Any state/region that contributed 0.1 (g/m3 sulfate or greater on the 20
percent worst visibility days in the base year (2002)

Any state/region that contributed at least 2 percent of total sulfate
observed on the 20 percent worst visibility days in 2002

Any state/region among the top ten contributors on the 20 percent worst
visibility days in 2002.

For the purposes of deciding how broadly to consult, the MANE-VU States
settled on the second of the three criteria: any state/region that
contributed at least 2 percent of total sulfate observed on the 20
percent worst visibility days in 2002.

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

On the left is a single bar graph of the IMPROVE-monitored PM2.5 mass
concentration ((g/m3) by constituent species for the baseline years
2000-2004.  The bottom (yellow) portion of the bar represents the
measured sulfate concentration.

The middle component of each figure provides a bar graph of the 2002
total sulfate contribution of each state or region as estimated by
REMSAD.

Finally, the right segment contains three maps showing which states meet
the criteria described above.  The three arrows from the bar graph in
the middle component indicate the cut-offs for state inclusion in the
maps in the right segment.

Connecticut, Rhode Island, Vermont, and the District of Columbia were
not identified as being among the political or regional units
contributing at least 2 percent of sulfate at any of the seven Class I
areas.  However, as participants in MANE-VU, those entities have agreed
to pursue adoption of regional control measures aimed at visibility
improvement on the haziest days and prevention of visibility degradation
on the clearest days.

Based on the MANE-VU Contribution Assessment, emissions from
Massachusetts contribute to visibility degradation in the following
Class I areas:  Acadia National Park, Great Gulf Wilderness, Lye Brook
Wilderness, Presidential Range/Dry River Wilderness, Moosehorn
Wilderness, and Roosevelt/Campobello International Park.    REF
_Ref202755715 \h  \* MERGEFORMAT  Figure 21 ,   REF _Ref202755752 \h 
\* MERGEFORMAT  Figure 26 , and   REF _Ref218497188 \h  Figure 27 ,
respectively, illustrate that emissions from Massachusetts do not
contribute greater than 0.1 (g/m3 sulfate or 2% of sulfate to the
Brigantine, Shenandoah, and Dolly Sods Class I areas.

Figure   SEQ Figure \* ARABIC  21 : Modeled 2002 Contributions to
Sulfate by State at Brigantine

Figure   SEQ Figure \* ARABIC  22 : Modeled 2002 Contributions to
Sulfate by State at Lye Brook

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

Figure   SEQ Figure \* ARABIC  24 : Modeled 2002 Contributions to
Sulfate by State at Acadia

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

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

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

Emissions Sources and Characteristics

The major pollutants responsible for regional haze are SO2, NOX, VOCs,
NH3, PM10, and PM2.5.  The following is a description of the sources
(e.g., point, area, and mobile) and characteristics of pollutant
emissions contributing to haze in the eastern United States.  Emissions
data and graphics presented in this section are taken from the MANE-VU
2002 Baseline Emissions Inventory, Version 2.0 (note that the more
recent MANE-VU 2002 Baseline Emissions Inventory, Version 3.0, released
in April 2006, has superseded Version 2.0 for modeling purposes). 
Although the emissions inventory database also includes carbon monoxide
(CO), this primary pollutant is not considered here because it does not
contribute to regional haze.  

In addition to the MANE-VU inventory, useful emissions inventories
include the 1996 EPA National Emissions Trends database (NET) and the
1999 National Emissions Inventory (NEI). Trends among the three
emissions inventories – NET 1996, NEI 1999, and MANE-VU 2002 – are
highlighted in the text and graphics presented below.

Sulfur Dioxide (SO2)

SO2 is the primary precursor pollutant for sulfate particles.  Sulfate
particles commonly account for more than 50 percent of particle-related
light extinction at northeastern Class I areas on the clearest days and
for as much as or more than 80 percent on the haziest days.  Hence, SO2
emissions are an obvious target for reducing regional haze in the
eastern United States.  Combustion of coal and, to a lesser extent, of
certain petroleum products accounts for most anthropogenic SO2
emissions.  In fact, in 1998 a single source category, coal-burning
power plants, was responsible for two-thirds of total SO2 emissions
nationwide (Appendix   REF _Ref218496886 \r \h  P ).  REF _Ref191279164
\h  \* MERGEFORMAT  Figure 28  shows SO2 emissions trends in the MANE-VU
states extracted from the NEI for the years 1996, 1999, and from the
2002 MANE-VU inventory. Most of the states show declines in year 2002
annual SO2 emissions as compared to 1996 emissions.  The decline can be
attributed to implementation of the second phase of the EPA Acid Rain
Program, which in 2000 further reduced allowable emissions and extended
emissions limits to more power plants. 

Figure   SEQ Figure \* ARABIC  28 : Trends in Annual Sulfur Dioxide
Emissions by State

Figure 29 shows the percent contribution from different source
categories to overall, annual 2002 SO2 emissions in the MANE-VU states. 
The chart shows that point sources dominate SO2 emissions, which
primarily consist of stationary combustion sources for generating
electricity, industrial energy, and heat.  Smaller stationary combustion
sources called “area sources” (primarily commercial and residential
heating, and smaller industrial facilities) are another important source
category in the MANE-VU states.  By contrast, on-road and non-road
mobile sources make only a relatively small contribution to overall SO2
emissions in the region (Appendix   REF _Ref218496886 \r \h  P ).



Figure   SEQ Figure \* ARABIC  29 : 2002 Sulfur Dioxide Emissions (SO2)
by State

Bar Graph: Percentage Fractions of the Four Source Categories

       (-o-) Line Graph: Total State Annual Emissions (106 tpy)

Volatile Organic Compounds (VOCs)

Existing emissions inventories generally refer to volatile organic
compounds (VOCs) for hydrocarbons whose volatility in the atmosphere
makes them particularly important from the standpoint of ozone
formation.  From a regional haze perspective, there is less concern with
the volatile organic gases emitted directly to the atmosphere and more
with the secondary organic aerosol (SOA) that the VOCs form after
condensation and oxidation processes.  Thus the VOC inventory category
is of interest primarily because of the organic carbon component of
PM2.5.  

After sulfate, organic carbon (OC) generally accounts for the next
largest share of fine particle mass and particle-related light
extinction at northeastern Class I sites.  The term organic carbon
encompasses a large number and variety of chemical compounds that may
come directly from emission sources as a part of primary PM or may form
in the atmosphere as secondary pollutants.  The organic carbon present
at Class I sites includes a mix of species, including pollutants
originating from anthropogenic (i.e., manmade) sources as well as
biogenic hydrocarbons emitted by vegetation.  Recent efforts to reduce
manmade organic carbon emissions have been undertaken primarily to
address summertime ozone formation in urban centers.  Future efforts to
further reduce organic carbon emissions may be driven by programs that
address fine particles and visibility.  Massachusetts will continue to
evaluate methods to reduce the contribution of organic carbon emissions
to regional haze; however, significant visibility improvements will not
occur until sulfate-dominated visibility impairment has been reduced.

Understanding the transport dynamics and source regions for organic
carbon in northeastern Class I areas is likely to be more complex than
for sulfate.  This is partly because of the large number and variety of
OC species, the fact that their transport characteristics vary widely,
and the fact that a given species may undergo numerous complex chemical
reactions in the atmosphere.  Thus, the organic carbon contribution to
visibility impairment at most Class I sites in the East is likely to
include manmade pollution transported from a distance and from nearby
sources, and biogenic emissions, especially terpenes, from coniferous
forests 

As shown in   REF _Ref191279294 \h  \* MERGEFORMAT  Figure 30 , the VOC
emissions inventory is dominated by mobile and area sources. On-road
mobile sources of VOCs include exhaust emissions from gasoline passenger
vehicles and diesel-powered heavy-duty vehicles, as well as evaporative
emissions from transportation fuels.  VOC emissions also may originate
from a variety of area sources (including solvents, architectural
coatings, and dry cleaners) and from some point sources (e.g.,
industrial facilities and petroleum refineries).  

Biogenic VOCs may play an important role within the rural settings
typical of Class I sites. The oxidation of hydrocarbon molecules
containing seven or more carbon atoms is generally the most significant
pathway for the formation of light-scattering organic aerosol particles.
 Smaller reactive hydrocarbons that may contribute significantly to
urban smog (ozone) are less likely to play a role in organic aerosol
formation, though it was noted that high ozone levels can have an
indirect effect on visibility by promoting the oxidation of other
available hydrocarbons, including biogenic emissions (Appendix   REF
_Ref218496886 \r \h  P ).  In short, further work is needed to
characterize the organic carbon contribution to regional haze in the
Northeast and Mid-Atlantic states and to develop emissions inventories
that will be of greater value for visibility planning purposes.

Figure   SEQ Figure \* ARABIC  30 : 2002 Volatile Organic Carbon (VOC)
Emissions by State

Bar Graph: Percentage Fractions of the Four Source Categories

       (-o-) Line Graph: Total State Annual Emissions (106 tpy)

Oxides of Nitrogen (NOX)

NOx emissions contribute to visibility impairment in the eastern U.S. by
forming light-scattering nitrate particles.  Nitrate generally accounts
for a substantially smaller fraction of fine particle mass and related
light extinction than sulfate and organic carbon at northeastern Class I
sites.  Notably, nitrate may play a more important role at urban sites
and in the wintertime.  In addition, NOx may have an indirect effect on
summertime visibility by virtue of its role in the formation of ozone,
which in turn promotes the formation of secondary organic aerosols
(Appendix   REF _Ref218496886 \r \h  P ). 

Figure 31 shows NOx emissions in the MANE-VU region at the state level. 
Since 1980, nationwide emissions of NOx from all sources have shown
little change.  In fact, emissions increased by 2 percent between 1989
and 1998.  This increase is most likely due to industrial sources and
the transportation sector, since power plant combustion sources had
implemented modest emissions reductions during the same time period. 
Most states in the MANE-VU region experienced declining NOX emissions
from 1996 through 2002.  Exceptions include Massachusetts, Maryland, New
York, and Rhode Island, which show an increase in NOx emissions in 1999
before declining in 2002 to levels below 1996 emissions.  For
Massachusetts, the increase in NOx emissions from 1996 to 1999 was due
largely to increases in emissions from off-road and stationary point
sources.  The subsequent decline in NOx emissions from 1999 to 2002 is
mainly attributable to controls in the on-road mobile category,
including Enhanced Inspection and Maintenance (I/M) and California Low
Emission Vehicle (CA-LEV) programs.  There also were significant
reductions in the stationary point source category, mainly power plants,
that are attributable to NOx RACT.

Figure   SEQ Figure \* ARABIC  31 : Trends in Annual Nitrogen Oxide
(NOx) Emissions by State

Power plants and mobile sources generally dominate state and national
NOx emissions inventories.  Nationally, power plants account for more
than one-quarter of all NOx emissions, amounting to over six million
tons.  The electric sector plays an even larger role, however, in parts
of the industrial Midwest where high NOx emissions have a particularly
significant power plant contribution.  By contrast, mobile sources
dominate the NOx inventories for more urbanized Mid-Atlantic and New
England states to a far greater extent, as shown in Figure 32.  In these
states, on-road mobile sources represent the most significant NOx source
category.  Emissions from non-road mobile sources, primarily
diesel-fired engines, also represent a substantial fraction of the
inventory.  While there are fewer uncertainties associated with
available NOx estimates than in the case of other key haze-related
pollutants, including primary fine particle and ammonia emissions,
further efforts could improve current inventories in a number of areas
(Appendix   REF _Ref218496886 \r \h  P ). 

Figure   SEQ Figure \* ARABIC  32 : 2002 Nitrogen Oxide (NOx) Emissions
by State

Bar Graph: Percentage Fractions of the Four Source Categories

       (-o-) Line Graph: Total State Annual Emissions (106 tpy)

Primary Particle Matter (PM10 and PM2.5)

Directly emitted or “primary” particles include both filterable and
condensable particulates.  These are distinct from secondary particles
that form in the atmosphere through chemical reactions involving
precursor pollutants like SO2 and NOX.  Both primary and secondary
particles can contribute to regional haze.  For regulatory purposes, a
distinction is made between particles with an aerodynamic diameter less
than or equal to 10 micrometers and smaller particles with an
aerodynamic diameter less than or equal to 2.5 micrometers (i.e.,
primary PM10 and PM2.5, respectively).  Figure 33 and Figure 34 show
PM10 and PM2.5 emissions for the MANE-VU states for the years 1996,
1999, and 2002.  Most states show a steady decline in annual PM10
emissions over this time period, with the exception of Maine.  By
contrast, emission trends for primary PM2.5 are more variable.  For
Massachusetts, both PM10 and PM2.5 emissions increased from 1996 to
1999, then declined to 2002.  Similar to trends in NOx emissions, the
increase was due largely to increases in emissions from off-road and
stationary point sources.  The subsequent decline in PM emissions from
1999 to 2002 is mainly attributable to controls in the on-road mobile
category, including Enhanced I/M and CA-LEV.  There also were
significant reductions in the stationary point source category, mainly
power plants, that are attributable to NOx RACT.

Figure   SEQ Figure \* ARABIC  33 : Trends in Primary Coarse Particle
(PM10) Emissions by State

Figure   SEQ Figure \* ARABIC  34 : Trends in Primary Fine Particle
(PM2.5) Emissions by State

Crustal sources are significant contributors of primary PM emissions. 
This category includes fugitive dust emissions from construction
activities, paved and unpaved roads, and agricultural tilling. 
Typically, monitors estimate PM10 emissions from these types of sources
by measuring the horizontal flux of particulate mass at a fixed downwind
sampling location within perhaps 10 meters of a road or field. 
Comparisons between estimated emission rates for fine particles using
these types of measurement techniques and observed concentrations of
crustal matter in the ambient air at downwind receptor sites suggest
that physical or chemical processes remove a significant fraction of
crustal material relatively quickly.  As a result, it rarely entrains
into layers of the atmosphere where it can transport to downwind
receptor locations.  Because of this discrepancy between estimated
emissions and observed ambient concentrations, modelers typically reduce
estimates of total PM2.5 emissions from all crustal sources by applying
a factor of 0.15 to 0.25 to the total PM2.5 emissions before including
it in modeling analyses.

From a regional haze perspective, crustal material generally does not
play a major role.  On the 20 percent best-visibility days during the
baseline period (2000-2004), it accounted for six to eleven percent of
particle-related light extinction at MANE-VU Class 1 sites.  On the 20
percent worst-visibility days, however, crustal material generally plays
a much smaller role relative to other haze-forming pollutants, ranging
from two to three percent.  Moreover, the crustal fraction includes
material of natural origin (such as soil or sea salt) that is not
targeted under the Regional Haze Rule.  Of course, the crustal fraction
can be influenced by certain human activities, such as construction,
agricultural practices, and road maintenance (including wintertime
salting), and thus to the extent that these types of activities are
found to affect visibility at northeastern Class I sites, control
measures targeted at crustal material may prove beneficial.  

Experience from the western United States, where the crustal component
has generally played a more significant role in driving overall
particulate levels, may be helpful to the extent that it is relevant in
the eastern context.  In addition, a few areas in the Northeast, such as
New Haven, Connecticut and Presque Isle, Maine, have some experience
with the control of dust and road-salt as a result of regulatory
obligations stemming from their past non-attainment status with respect
to the National Ambient Air Quality Standard (NAAQS) for PM10.

Current emissions inventories for the entire MANE-VU area indicate
residential wood combustion represents 25 percent of primary fine
particulate emissions in the region.  This implies that rural sources
can play an important role in addition to the contribution from the
region’s many highly populated urban areas.  An important
consideration in this regard is that residential wood combustion occurs
primarily in the winter months, while managed burning activities occur
largely in other seasons.  Managed burning includes agricultural and
prescribed fires, as well as use of naturally ignited fires to achieve
resource benefits and slash burning of logging debris (which is
prohibited in Massachusetts).  Particulate emissions from managed burns
can be limited by confining burning activities to times when favorable
meteorological conditions can efficiently disperse the emissions.

Wood smoke impacting MANE-VU Class I areas is more local in origin than
sources of SO2, except for major transport events.    REF _Ref194726558
\h  Figure 35  below is from the MANE-VU Contribution Assessment
(Appendix A; see Appendix B) and represents the results of source
apportionment and trajectory analyses.  It illustrates that the impacts
of wood smoke on MANE-VU Class I areas are more likely due to emissions
from within MANE-VU and Canada.  The green-highlighted portion of the
map depicts the wood smoke source region in the Northeast states.  The
stars on the map represent air monitor sites (including those at several
Class I areas) whose data sets were determined to be useful to the
modeling analysis used to attribute wood smoke impacts.

The MANE-VU Technical Support Document on Agricultural and Forestry
Smoke Management in the MANE-VU Region (Appendix   REF _Ref197851758 \r
\h  \* MERGEFORMAT  Q ) concluded that fire from land management
activities (agricultural, prescribed, and slash burning, and managed
wildfires) was not a major contributor to regional haze in MANE-VU Class
I areas, and that the majority of emissions from fires were from
residential wood combustion.  

Although data are currently lacking, Massachusetts is concerned about
the growing use of residential wood stoves by homeowners seeking
alternatives to petroleum-based fuels for home heating.  Recent,
localized problems with smoke emissions from outdoor wood boilers
(wood-fired hydronic heaters) led MassDEP to promulgate regulations that
tighten requirements on the sale, installation, and use of these
devices.  MassDEP will keep close watch on smoke emissions from the
residential sector to determine whether additional control measures on
this source category may be necessary in the next few years.

Figure   SEQ Figure \* ARABIC  35 : Wood Smoke Source Regional
Aggregations

NE: ACAD, PMRC, LYBR

MA: WASH, SHEN, JARI

SE: GRSM, MACA

  REF _Ref204413763 \h  Figure 36  and   REF _Ref191279547 \h  \*
MERGEFORMAT  Figure 37  show that area and mobile sources dominate
primary PM emissions.  (The NEI inventory categorizes residential wood
combustion and some other combustion sources as area sources.)  The
relative contribution of point sources is larger in the primary PM2.5
inventory than in the primary PM10 inventory since the crustal component
(which consists mainly of larger or “coarse-mode” particles)
contributes mostly to overall PM10 levels.  At the same time, pollution
control equipment commonly installed at large point sources is usually
more efficient at capturing coarse-mode particles. 

Figure   SEQ Figure \* ARABIC  36 : 2002 Primary PM10 Emissions by
State

Bar Graph: Percentage Fractions of the Four Source Categories

       (-o-) Line Graph: Total State Annual Emissions (106 tpy)

Figure   SEQ Figure \* ARABIC  37 : 2002 Primary PM2.5 Emissions by
State

	

       Bar Graph: Percentage Fractions of the Four Source Categories

                    (-o-) Line Graph: Total State Annual Emissions (106
tpy)

Ammonia Emissions (NH3)

Because ammonium sulfate [(NH3)2SO4]and ammonium nitrate (NH3NO3) are
significant contributors to atmospheric light scattering and fine
particle mass, knowledge of ammonia emission sources is important to the
development of effective regional haze reduction strategies.  According
to 1998 estimates, livestock agriculture and fertilizer use accounted
for approximately 86 percent of all ammonia emissions to the atmosphere.
 However, better ammonia inventory data is needed for the photochemical
models used to simulate fine particle formation and transport in the
eastern United States.  States were not required to include ammonia in
their air emissions data collection efforts until fairly recently (see
Consolidated Emissions Reporting Rule, 67 FR 39602; 6/10/2002), and so
it will take time for the quality of ammonia inventory data to match the
quality of the data for the other criteria pollutants. 

Ammonium ion (formed from ammonia emissions to the atmosphere) is an
important constituent of airborne particulate matter, typically
accounting for 10–20 percent of total fine particle mass.  Reductions
in ammonium ion concentrations can be extremely beneficial because a
more-than-proportional reduction in fine particle mass can result. 
Ansari and Pandis showed that a 1 (g/m3 reduction in ammonium ion could
result in up to a 4 (g/m3 reduction in fine particulate matter. 
Decision makers, however, must weigh the benefits of ammonia reduction
against the significant role it plays in neutralizing acidic aerosol.

To address the need for improved ammonia inventories, MARAMA, NESCAUM,
and EPA funded researchers at Carnegie Mellon University (CMU) in
Pittsburgh to develop a regional ammonia inventory.  This study focused
on three issues with respect to current emissions estimates: (1) a wide
range of ammonia emission factor values, (2) inadequate temporal and
spatial resolution of ammonia emissions estimates, and (3) a lack of
standardized ammonia source categories.

The CMU project established an inventory framework with source
categories, emissions factors, and activity data that are readily
accessible to the user.  With this framework, users can obtain data in a
variety of formats and can make updates easily, allowing additional
ammonia sources to be added or emissions factors to be replaced as
better information becomes available.10 

Figure 38 shows that estimated ammonia emissions were fairly stable in
the 1996 NEI, 1999 NEI, and 2002 Version 3 MANE-VU inventories for
MANE-VU states, with some slight increases observed for most states in
MANE-VU.  This apparent increase in emissions from 1999 to 2002 is due
to a difference in the models used to generate the emissions data.  1999
emissions were generated using an EPA model, whereas the 2002 emissions
were generated using the CMU ammonia model described above.  The CMU
ammonia model incorporates categories such as humans, house pets, wild
animals, fertilizers, soils, and miscellaneous animals that are not
incorporated into the EPA model. 

Area and on-road mobile sources dominate ammonia emissions (Figure 39). 
Specifically, emissions from agricultural sources and livestock
production account for the largest share of estimated ammonia emissions
in the MANE-VU region, except in the District of Columbia.  The two
remaining sources with a significant emissions contribution are
wastewater treatment systems and gasoline exhaust from highway vehicles.


Figure   SEQ Figure \* ARABIC  38 : Trends in Ammonia Emissions by State

Figure   SEQ Figure \* ARABIC  39 : 2002 NH3 Emissions by State

Bar Graph: Percentage Fractions of the Four Source Categories

(-o-) Line Graph: Total State Annual Emissions (106 tpy)

Best Available Retrofit Technology

In the Regional Haze Rule, EPA included provisions designed specifically
to reduce emissions of visibility-impairing pollutants from large
sources that, because of their age, were exempted from new source
performance standards (NSPS) established under the Clean Air Act.  These
provisions, known as Best Available Retrofit Technology, or BART, are
located at 40 CFR 51.308(e).

Massachusetts is required by 40 CFR 51.308(e) to submit an
implementation plan containing emission limits representing BART and
schedules for compliance with BART for each eligible source that may
reasonably be anticipated to cause or contribute to any impairment of
visibility in any mandatory Class I Federal area.  This requirement
applies unless Massachusetts demonstrates that an emission trading
program or other alternative will achieve greater reasonable progress
toward natural visibility conditions.  

BART requirements apply to 26 specified major point source categories,
including power plants, industrial boilers, paper and pulp plants,
cement kilns, and other large stationary sources.  To be considered
BART-eligible, emission units from these specified categories must have
commenced operation or come into existence in the 15-year period prior
to August 7, 1977 (the date of passage of the 1977 Clean Air Act
Amendments, which first required new source performance standards).  In
addition, the cumulative “potential to emit” levels of all
BART-eligible units at a facility must be at least 250 tons per year of
any visibility-impairing pollutant.  Visibility-impairing pollutants
include, but are not limited to, sulfur dioxide (SO2), nitrogen oxides
(NOx), particulate matter less than or equal to 10 microns in diameter
(PM10), volatile organic chemicals (VOCs), and ammonia.

BART Overview

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

Cost of compliance,

Energy and non-air quality environmental impacts of compliance,

Existing pollution control technology in use at the source,

Remaining useful life of the source, and

Degree of improvement in visibility reasonably anticipated from use of
BART.

In July 2005, EPA adopted the final BART rule.  Under the final rule,
the BART program requires states to develop an inventory of sources
within each state that could be subject to control.  Specifically, the
rule:

Outlined methods to determine if a source is “reasonably anticipated
to cause or contribute to haze;” 

Defined the methodology for conducting a BART control analysis;

Provided presumptive control limits for electricity generating units
(EGUs) larger than 750 Megawatts (i.e. “presumptive BART”);

Provided a justification for the use of the Clean Air Interstate Rule
(CAIR) as BART for CAIR state EGUs.

Beyond the specific elements listed above, EPA provided the states with
a great degree of flexibility in how they choose to implement the BART
program. 

As set forth in 40 CFR 51.308(e)(2), states may choose to implement or
require participation by BART sources in an emissions trading program or
an alternative measure that will achieve greater reasonable progress
than BART implementation at all sources subject to BART.  In addition,
if such alternative measure has been designed primarily to meet a
Federal or State requirement other than BART, a more simplified approach
can be used to demonstrate that the alternative measure will make
greater reasonable progress than implementing BART alone.

BART-Eligible Sources in Massachusetts

Massachusetts identified its BART-eligible sources using the methodology
in the Guidelines for Best Available Retrofit Technology (BART)
Determinations under the Regional Haze Rule, 40 CFR Part 51, Appendix Y.
 Seventeen sources were found to be eligible for BART and are listed in
Table 10. These include nine electric generating units (EGUs), four
industrial/commercial/ institutional (ICI) boilers/chemical processing
plants, one municipal waste combustor (MWC), and three petroleum storage
facilities.

Table   SEQ Table \* ARABIC  10 : BART-Eligible Facilities in
Massachusetts

I.D.	Source	Units	Type

1190012	Boston Generating - New Boston	Unit 1	EGU

1190128	Boston Generating – Mystic	Unit 7	EGU

1190491	Braintree Electric	Unit 3	EGU

1200061	Dominion - Brayton Point	Units 1, 2, 3, and 4	EGU

1190194	Dominion - Salem Harbor	Unit 4	EGU

1190092	Harvard University - Blackstone	Units 11 and 12	EGU

1200054	Mirant - Canal Station	Units 1 and 2	EGU

1190093	Mirant - Kendall LLC	Units 1 and 2	EGU

1200067	Taunton Municipal Light Plant

(TMLP) - Cleary Flood	Units 8 and 9	EGU

1190175	Eastman Gelatin	Units 1, 2, 3 and 4	ICI Boilers/Chemical
Processing

1190138	General Electric Aircraft - Lynn	Unit 3	ICI Boilers/Chemical
Processing

420086	Solutia	Units 9 and 10	ICI Boilers/Chemical Processing

1190507	Trigen - Kneeland St	Unit 3	ICI Boilers/Chemical Processing

1197654	Wheelabrator – Saugus	Units 1 and 2	Municipal Incinerator

1190484	Exxon Mobil – Everett	All Process Units	Petroleum Storage

1190487	Global Petroleum – Revere	All Process Units	Petroleum Storage

1190483	Gulf Oil – Chelsea	All Process Units	Petroleum Storage

Determination of which BART-eligible sources are subject to BART

Massachusetts is a member of the Mid-Atlantic/Northeast Visibility Union
(MANE-VU).  As part of the consultation process among MANE-VU states a
policy decision was made by the MANE-VU Board in June 2004 that all
BART-eligible sources are subject to BART.  As such, no BART exemptions
will be given, meaning all BART-eligible sources are included in the
BART review process.

Pollutants Covered by BART

As allowed under BART, Massachusetts has determined that SO2, NOx and PM
are the contributing visibility-impairing pollutants most appropriate to
target under its BART approach.  Massachusetts did not include either
VOCs or ammonia because of the lack of tools to estimate emissions and
subsequently to model VOCs and ammonia, and because Massachusetts is
aggressively addressing VOCs through its ozone SIPs.  This conclusion is
consistent with discussions in the MANE-VU consultation process. 
Therefore, Massachusetts did not further consider BART for the three
petroleum storage facilities identified in Table 10 above.

Modeling of BART Visibility Impacts

MANE-VU conducted modeling analyses of BART-eligible sources using
CALPUFF in order to provide a regionally-consistent foundation for
assessing the degree of visibility improvement which could result from
installation of BART controls (see Attachment R).

MANE-VU modeled BART visibility impacts using 2002 emissions of SO2,
NOx, and PM10 from all BART-eligible units in the region, including all
BART-eligible sources in Massachusetts.  The NWS and MM5 meteorological
platforms were both used to model each BART-eligible unit’s maximum
24-hr, 8th highest 24-hr, and annual average impact at the Class I area
most heavily impacted, as well as the total impact from all BART sources
on each Class I area.  These visibility impacts were modeled relative to
20 percent best days, 20 percent worst days, and annual average natural
background conditions.  For the purposes of this analysis, MANE-VU
examined the 24-hr maximum visibility impact relative to the 20 percent
best days.  In accordance with EPA guidance, which allows the use of
either estimates of the 20 percent best or annual average natural
background visibility conditions as the basis for calculating the
deciview difference that individual sources would contribute for BART
modeling purposes, MANE-VU opted to use the more conservative best
conditions estimates approach because it is more protective to the
region.

In addition to modeling the maximum potential improvement from BART,
MANE-VU also determined that 98 percent of the cumulative visibility
impact from all MANE-VU BART eligible sources corresponds to a maximum
24-hr impact of 0.22 dv from the NWS-driven data and 0.29 dv from the
MM5 data.  As a result, MANE-VU concluded that, on the average, a range
of 0.2 to 0.3 dv would represent a significant impact at MANE-VU Class I
areas, and sources having less than 0.1 dv impact are unlikely to
warrant additional controls under BART.

Visibility Impacts of Massachusetts BART-Eligible Sources

The results of CALPUFF modeling using MM5 and NWS meteorological
platforms for Massachusetts BART-eligible facilities (excluding VOC
sources) are found in Table 11 and Table 12, respectively.  These
results display facility-wide impacts on the worst day at the site
experiencing the largest impact relative to the 20 percent best natural
background conditions.

Table   SEQ Table \* ARABIC  11 : CALPUFF Visibility Modeling Results
using MM5 Platform

	MM5- Impact on Worst Day Relative to 20 Percent Best Natural Conditions
(delta deciview; ddv)

Facility	Class I Site	Total	SO4	NO3	PM10

Dominion - Brayton Point	Acadia	11.152	9.740	3.354	0.031

Mirant - Canal Station	Acadia	6.643	6.018	1.310	0.000

Mystic Station	Moosehorn Wilderness	1.023	0.943	0.117	0.002

Dominion - Salem Harbor	Moosehorn Wilderness	0.982	0.886	0.151	0.001

Trigen - Kneeland Station	Acadia	0.146	0.023	0.127	0.001

Wheelabrator-Saugus	Acadia	0.250	0.026	0.232	0.000

General Electric Aircraft - Lynn	Acadia	0.239	0.148	0.092	0.000

TMLP - Cleary Flood	Acadia	0.103	0.028	0.076	0.003

Mirant - Kendall	Acadia	0.095	0.015	0.082	0.000

Harvard University - Blackstone	Acadia	0.060	0.039	0.027	0.001

New Boston	Presidential Range	0.044	0.000	0.044	0.000

Braintree Electric	Acadia	0.031	0.004	0.029	0.000

Eastman Gelatin	Acadia	0.029	0.002	0.026	0.000

Solutia	Presidential Range	0.003	0.000	0.003	0.000



Table   SEQ Table \* ARABIC  12 : CALPUFF Visibility Modeling Results
using NWS Platform

	NWS- Impact on Worst Day Relative to 20 Percent Best Natural Conditions
(ddv)

Facility	Class I Site	Total	SO4	NO3	PM10

Dominion - Brayton Point	Moosehorn Wilderness	7.200	6.206	1.754	0.026

Mirant - Canal Station	Acadia  	3.485	3.251	0.427	0.000

Mystic Station	Moosehorn Wilderness	0.660	0.556	0.108	0.003

Dominion - Salem Harbor	Acadia  	0.545	0.488	0.108	0.001

Trigen - Kneeland Station	Lye Brook Wilderness	0.097	0.005	0.092	0.002

Wheelabrator - Saugus	Lye Brook Wilderness	0.183	0.004	0.179	0.000

General Electric Aircraft - Lynn	Acadia  	0.159	0.118	0.085	0.000

TMLP – Cleary Flood	Moosehorn Wilderness	0.061	0.022	0.037	0.002

Mirant - Kendall	Lye Brook Wilderness	0.059	0.003	0.057	0.000

Harvard University - Blackstone	Acadia  	0.034	0.023	0.010	0.001

New Boston	Lye Brook Wilderness	0.028	0.000	0.027	0.001

Eastman Gelatin	Acadia  	0.025	0.002	0.024	0.000

Braintree Electric	Moosehorn Wilderness	0.014	0.002	0.012	0.000

Solutia	Acadia  	0.003	0.000	0.003	0.000

Overview of Massachusetts BART-Eligible Sources

There are three categories of BART-eligible sources in Massachusetts
that emit SO2, NOx, and PM:  a “cap out” source, sources with de
minimis visibility impacts, and sources that contribute significantly to
visibility impairment.

“Cap Out” Source

BART eligibility is limited to sources in one of 26 source categories
that had units installed and operating between 1962 and 1977 with the
current cumulative potential to emit more than 250 tons per year of a
visibility impairing pollutant.  EPA guidance allows BART-eligible
sources to adopt a federally enforceable permit limit to permanently
limit emissions of visibility impairing pollutants to less than 250 tons
per year, thereby “capping-out” of BART.   General Electric – Lynn
has actual emissions of visibility impairing pollutants of fewer than
250 tons per year and was BART-eligible only because its potential
emissions exceed the statutory BART threshold of 250 tons per year. 
MassDEP has issued a permit to General Electric – Lynn establishing
caps of less than 250 tpy for NOx and SO2 emissions from Unit 3 in order
to cap-out of BART requirements (Appendix BB); PM10 potential emissions
already are less than 250 tpy.  Therefore, General Electric – Lynn
Unit 3 is no longer BART-eligible.

Sources with De Minimis Impacts on Visibility

According to the 2005 Regional Haze Rule, once a state has compiled its
list of BART-eligible sources, it needs to determine whether to make
BART determinations for all of the sources or to consider exempting some
of them from BART because they may not reasonably be anticipated to
cause or contribute to any visibility impairment in a Class I area. 
MANE-VU has identified a set of sources whose potential “degree of
visibility improvement” is so small (<0.1 ddv) that no reasonable
weighting could justify additional controls under BART. (Note that the
cumulative impact of all of these MANE-VU sources combined is lower than
EPA’s guidance, which states that the threshold for determining
whether a source “contributes” to visibility impairment should be
≤0.5 dv.)  A description of this modeling can be found in Appendix R,
Section 4.1, and the modeling results can be found in Appendices R-1 and
R-2.  MANE-VU has termed these sources to have a “de minimis
visibility impact.”

For Massachusetts, sources meeting this criterion are listed in Table
13.  Trigen – Kneeland has been added to this list, despite its
modeled impact of 0.146 ddv (0.127 ddv from NO3) using the MM5 modeling
platform, due to two significant errors in the 2002 input data used by
MANE-VU to screen facilities for their impact on visibility.  First,
Units 1-4 were included in the modeling when only Unit 3 is
BART-eligible.  Second, the 2002 modeled NOx emissions from Unit 3 were
396 tons, rather than the actual 96 tons of NOx emissions. 
Massachusetts believes that modeling using the corrected 2002 NOx
emissions from Trigen - Kneeland would indicate a total visibility
impact of <0.1 ddv; therefore Trigen – Kneeland is being considered a
source with de minimis impact on visibility. 

Table   SEQ Table \* ARABIC  13 : Massachusetts Sources with De Minimis
Visibility Impact

I.D.	Source	Type

1190491	Braintree Electric	EGU

1190092	Harvard University - Blackstone	EGU

1190093	Mirant - Kendall LLC	EGU

1190012	New Boston	EGU

1190175	Eastman Gelatin 	ICI Boilers/Chemical Process

420086	Solutia	ICI Boilers/Chemical Process

1190507	Trigen – Kneeland	ICI Boilers



MassDEP has determined that the visibility improvement that would be
achieved by the installation of BART controls at these sources does not
justify the installation of such controls.  

Sources that Contribute to Visibility Impairment

Massachusetts BART-subject sources with greater than a de minimis impact
on visibility include three coal-fired EGUs (Brayton Point Units 1-3),
seven oil-fired EGUs (Brayton Point Unit 4, Canal Station Units 1-2,
Mystic Station Unit 7, Salem Harbor Unit 4, and Cleary Flood Units 8 and
9) and two MWC units (Wheelabrator – Saugus).  An overview of these
sources is contained in Table 14. 

It should be noted that all of these sources are subject to MassDEP
pollution control requirements that limit SO2 and NOx.  All of the these
sources, except Cleary Flood and Wheelabrator-Saugus, are subject to 310
CMR 7.29, Emissions Standards for Power Plants, which MassDEP adopted in
2001 to control the emissions of NOx, SO2, mercury, and carbon dioxide
from the state’s largest EGUs.  In addition, these sources, as well as
Cleary Flood, are subject to MassDEP’s NOx RACT rules and ozone season
MassCAIR control program, 310 CMR 7.32.  Wheelabrator-Saugus is subject
to 310 CMR 7.08(2): Municipal Waste Combustors and 310 CMR 7.19(9) (NOx
RACT for Municipal Waste Combustor Units). 

The Regional Haze Rule allows Massachusetts to either make individual
BART determinations or to implement an alternative that will achieve
greater reasonable progress toward natural visibility conditions.  
Massachusetts has developed a BART determination for the Wheelabrator
units and has adopted an alternative to BART for the remaining EGU BART
sources. 

Table   SEQ Table \* ARABIC  14 : Overview of BART-Eligible EGUs & MWCs

Source Type	Source	Unit	Subject to Presumptive BART?	Primary Fuel
Secondary Fuel(s)	Unit Type	Built Year

EGU	Brayton Point	1	yes	Coal (1.5%S)	Natural Gas, Residual Oil
Tangentially-fired	1963

EGU	Brayton Point	2	yes	Coal (1.5%S)	Natural Gas, Residual Oil
Tangentially-fired	1964

EGU	Brayton Point	3	yes	Coal (1.5%S)	Natural Gas, Residual Oil	Dry
bottom wall-fired boiler	1969

EGU	Brayton Point	4	yes	Residual Oil	Natural Gas	Dry bottom wall-fired
boiler	1974

EGU	Canal Station	1	yes	Residual Oil	Diesel Oil	Dry bottom wall-fired
boiler	1970

EGU	Canal Station	2	yes	Residual Oil	Diesel Oil,       Natural Gas	Dry
bottom wall-fired boiler	1976

EGU	Mystic Station	7	yes	Residual Oil	Natural Gas	Tangentially-fired
1974

EGU	Salem Harbor	4	yes	Residual Oil	 	Dry bottom wall-fired boiler	1972

EGU	Cleary Flood	8	no	Residual Oil	Diesel Oil	Dry bottom wall-fired
boiler	1966

EGU	Cleary Flood	9	no	Natural Gas	Diesel Oil,      Residual Oil	Other
boiler	1976

MWC	Wheelabrator - Saugus	1	no	Municipal Solid Waste	Mass burn waterwall
boiler	1975

MWC	Wheelabrator - Saugus	2	no	Municipal Solid Waste	Mass burn waterwall
boiler	1975

BART Determination for Wheelabrator - Saugus

Massachusetts has one BART-eligible incinerator, Wheelabrator –
Saugus, which contains two mass burn incinerators with water wall
boilers, each rated at 325 MMBtu/hr heat input.  Each boiler can produce
up to 195,000 lbs/hr of steam at 650 psi and 850º F.  Both incinerator
units are BART-eligible, with reported combined 2002 emissions of 84
tons of SO2 and 721 tons of NOx

Wheelabrator – Saugus is subject to MassDEP’s 1995 NOx Reasonably
Available Control Technology (RACT) regulation, 310 CMR 7.19(9). 
Wheelabrator – Saugus also is subject to more stringent NOx emissions
limitations in MassDEP’s Municipal Waste Combustor regulation, 310
CMR.7.08(2), which was promulgated in 1998 (and amended in 2001) to
implement EPA’s 1995 Emissions Guidelines for existing large (greater
than 250 tons) Municipal Waste Combustors pursuant to Sections 111(d)
and 129 of the federal Clean Air Act.  Section 129 requires that these
guidelines must be based on Maximum Achievable Control Technology
(MACT).  In 2006, EPA revised its Emissions Guidelines for large
Municipal Waste Combustors, lowering the PM emission guidelines (as well
as for other non-BART relevant pollutants), but leaving the SO2 and NOx
emissions guidelines unchanged.   In 2012, MassDEP plans to propose
revisions to 310 CMR 7.08(2) to adopt the lowered 2006 Emissions
Guidelines.   In addition, MassDEP has committed in its 2008 Ozone SIP
to conduct additional analysis as to whether existing NOx controls still
constitute RACT, and will consider including more stringent NOx
limits in 310 CMR 7.19 when it proposes revisions to 310 CMR 7.08(2)
in 2012.  Wheelabrator – Saugus will be required to comply with any
more stringent emissions limits included in 310 CMR 7.08(2) and 310 CMR
7.19.

NOx

Wheelabrator has NOx control equipment for both units that includes
low-NOx burners and Selective Non-Catalytic Reduction (SNCR). 
MassDEP’s NOx emission limit under 310 CMR 7.08(2)(f)3 is 205 ppm (by
volume at 7 percent oxygen dry basis, 24-hr daily arithmetic average). 
Compliance is determined by continuous emissions monitors (CEMs). 
MassDEP’s regulatory limit is consistent with EPA’s Emissions
Guidelines (both 1995 and 2006).  However, MassDEP believes that the
capabilities of current NOx control technologies can achieve emissions
lower than EPA’s MACT.  

At MassDEP’s request, Wheelabrator performed furnace gas temperature
profiling and conducted SNCR optimization testing to determine the
capability of further reducing NOx emissions while minimizing ammonia
slip (see Appendix Z).  The optimization test results indicate that a
reduced NOx emissions target of 185 ppm (dry, 7% O2) at current boiler
operating loads of approximately 150,000 lbs/hr could be achieved with
the existing SNCR system.  Based on MassDEP’s review of Wheelabrator
– Saugus’ existing control technologies, MassDEP determined that the
NOx emissions rate target of 185 ppm (30-day average) for each of
Wheelabrator’s units represents BART.  MassDEP issued a modified
Emission Control Plan Final Approval for Wheelabrator with the BART NOx
limit in March 2012 (Appendix JJ).

As described in Tables 11 and 12, Wheelabrator – Saugus’ visibility
impacts on Class I areas based on 2002 emissions was 0.232 ddv and 0.179
ddv, depending on the modeling platform, which are close to MANE-VU’s
de minimis level (0.1 ddv) and are well below EPA’s threshold guidance
of 0.5 ddv for determining whether a source “contributes” to
visibility impairment.  Therefore, no detailed visibility modeling was
performed to determine the benefit of achieving the lower NOx emission
rate, although  MassDEP expects a modest visibility improvement to
result from a lower NOx emission rate.   

Additional technologies and costs were not evaluated because MassDEP
believes that low-NOx burners and SNCR are state of the art for
municipal waste combustors, and through optimization can achieve a NOx
emissions limit lower than the current federal MACT limit.   

SO2

Wheelabrator’s existing control technology for SO2 emissions includes
a spray dry absorber (SDA) with lime slurry injection.  Wheelabrator’s
permitted SO2 emission limit under 310 CMR 7.08(2)(f)2 is 29 ppm (by
volume at 7 percent oxygen dry basis) or 75 percent reduction by weight
from uncontrolled SO2 levels.  Compliance is based on a 24-hour
geometric mean.  MassDEP’s regulatory limit is consistent with EPA’s
Emissions Guidelines (both 1995 and 2006).  

CALPUFF modeling suggests that visibility impacts from 2002 SO2
emissions from Wheelabrator - Saugus are below 0.1 ddv on the worst day
at any Class I area (see Tables 11 and 12).  MassDEP has determined that
further controls for SO2 are not warranted given the additional cost
required to install supplementary SO2 controls because Wheelabrator
already has control equipment equivalent to MACT and the degree of
visibility improvement that could be achieved (<0.1 ddv) is de minimis.

PM

Each of Wheelabrator’s units are equipped with 10-module fabric
filters (baghouses) and are subject to 310 CMR 7.08 (2)(f)2 limits for
PM of 27 mg/dscm or less at 7 percent oxygen (dry basis). This emissions
limit is consistent with EPA’s 1995 Emissions Guidelines for MWCs.  In
2006, EPA lowered the Emissions Guideline for PM to 25 mg/dscm.  MassDEP
has determined that a PM emissions rate of 25 mg/dscm for each of
Wheelabrator’s units represents BART.  MassDEP has determined that a
PM emissions limit lower than 25 mg/dscm is not warranted given the
additional cost required to install supplementary PM controls because
Wheelabrator already has control equipment equivalent to MACT and the
degree of visibility improvement that could be achieved is de minimis. 
MassDEP issued a modified Emission Control Plan Final Approval for
Wheelabrator with the 25 mg/dscm PM emission rate in March 2012
(Appendix JJ).

 

Energy and Non-air Quality Impacts

There are no significant energy and non-air quality impacts associated
with the proposed BART for Wheelabrator-Saugus.  One environmental
benefit of a lower NOx emissions limit, in addition to improved
visibility, is the impact on acid deposition in Massachusetts and
Northern New England.  Reductions in ambient concentrations of NOx will
reduce acid deposition as well as excess nitrogen deposition, thereby
reducing the acidification of lakes, streams and soils and material
damage to buildings, and the eutrophication of inland and coastal
waters.

Remaining Useful Life

As a member of MANE-VU, Massachusetts has determined that a
BART-eligible source that is found to have reasonable control options
available to it should either control emissions from that BART-eligible
source prior to July 1, 2013, or accept a federally enforceable permit
limitation or retirement date prior to adoption of this SIP.

Schedule for BART determination and Federal Enforceability

40 CFR 51.308(e)(1)(iv) requires that BART controls must be in operation
for each applicable source no later than five years after EPA SIP
approval and must be federally enforceable. MassDEP has issued an
Emissions Control Plan Final Approval pursuant to 310 CMR 7.08(2) that
requires Wheelabrator to comply with the BART NOx and PM emissions
limits in 2012.  Because 310 CMR 7.08(2) is included in the
federally-approved Massachusetts State Plan for Municipal Waste
Combustors, the  Emission Control Plan Final Approval for Wheelabrator
is federally enforceable.

Alternative to BART for EGUs

EPA’s Regional Haze Rule at 40 CFR 51.308(e)(3) gives states the
authority to implement an alternative measure that achieves greater
reasonable progress towards improving visibility at Class I areas than
source-specific Best Available Retrofit Technology (BART).  A state can
establish a BART benchmark (i.e., emissions reductions that would result
from the application of source-specific BART), and then can compare the
emissions reductions achieved from the alternative measure with the
emissions reductions that would be achieved from the BART benchmark.  If
the reductions from the alternative measure are greater than the BART
benchmark, the state can assume that the alternative measure results in
greater reasonable progress than BART.

MassDEP has adopted an alternative to BART that covers all of the
BART-eligible electric generating units (EGUs) plus all additional coal-
and oil-fired EGUs subject to MassDEP’s regulation 310 CMR 7.29,
Emissions Standards for Power Plants.  This includes the BART-eligible
EGUs (Brayton Point Units 1–4, Canal Station Units 1–2, Mystic Unit
7, Salem Harbor Unit 4, and Cleary Flood Units 8–9), plus additional
units subject to 310 CMR 7.29, which include Salem Harbor Units 1–3,
Mt. Tom Station Unit 1, and Somerset Power Unit 8.  MassDEP’s
alternative to BART includes the following measures:

Existing regulation 310 CMR 7.29, Emissions Standards for Power Plants,
which establishes NOx and SO2 emissions rates (as well as mercury
emission rates and carbon dioxide caps) for certain EGUs.  

The retirement of Somerset Power.

Permit restrictions for Brayton Point, Salem Harbor, and Mt. Tom Station
that limit/retire SO2 and/or NOx emissions. 

Existing regulation 310 CMR 7.19, Reasonably Available Control
Technology (RACT) for Sources of Oxides of Nitrogen NOx, which
establishes NOx emission rates for various sources, including EGUs.

Amended regulation 310 CMR 7.05, Fuels All Districts, which requires
EGUs that burn residual oil to limit the sulfur content to 0.5% by
weight beginning July 1, 2014.

As demonstrated below, MassDEP’s alternative to BART will achieve
greater emission reductions of SO2 and NOx than would be achieved
through the installation and operation of BART alone.  The following
sections establish a BART benchmark, provide estimated emission
reductions that will be achieved by the alternative to BART measures
listed above, and show that reductions from these alternative measures
exceed reductions from the application of BART alone.

BART benchmark

Massachusetts has used a most-stringent-case BART as the BART benchmark,
based on EPA’s Guideline for BART Determinations and the MANE-VU
Workgroup recommended emissions limits for SO2 and NOx, which take into
consideration the currently available cost-effective SO2 and NOx control
technologies for EGUs.

EPA’s Guideline for BART Determinations (40 CFR 51, Appendix Y)
establishes presumptive SO2 emission limits for 750 megawatt (MW) and
larger power plants.  Four facilities (Brayton, Canal, Mystic, and Salem
Harbor) are greater than 750 MW, while Cleary Flood is below 750 MW. 
Seven of the BART-eligible units are primarily oil-fired, while Brayton
Point Units 1, 2, and 3 are primarily coal-fired.

For each oil-fired EGU at a 750 MW or larger power plant, regardless of
size, EPA recommends that, for SO2 control purposes, states evaluate
limiting the sulfur content of the fuel oil burned to 1 percent or less
by weight.  For NOx control purposes at power plants with a generating
capacity in excess of 750 MW currently using SNCR or SCR for part of the
year, EPA suggests that use of such controls year round is BART.

For each uncontrolled coal-fired EGU greater than 200 MW at a 750 MW or
larger power plant, EPA recommends SO2 control levels of either 95% or
0.15 lbs/MMBtu.  For NOx, EPA recommends using selective non-catalytic
reduction (SNCR) or selective catalytic reduction (SCR) year round.  For
coal-fired EGUs operating without post-combustion NOx controls, EPA
provides presumptive NOx emission rates differentiated by boiler design
and type of coal burned.

As part of the regional consultation process, the MANE-VU BART Workgroup
established recommended BART emission limits for various types of
sources (see Appendix R, Five-Factor Analysis of BART-Eligible Sources).
 Table 15 includes the MANE-VU BART Workgroup recommended BART emission
limits for non-CAIR EGUs.  (The BART-eligible units in Massachusetts are
considered non-CAIR EGUs because Massachusetts was not subject to the
CAIR SO2 and NOx annual programs.)  The MANE-VU BART workgroup’s
recommended BART emission limits are the same as EPA’s recommended
limits for SO2 for coal, but are more stringent than the EPA recommended
limits for SO2 for oil and for NOx.  Therefore, Massachusetts used the
MANE-VU recommended emission limits to establish the BART benchmark.

Table   SEQ Table \* ARABIC  15 : MANE-VU BART Workgroup Recommended
BART Emission Limits for SO2 and NOx for non-CAIR EGUs

	SO2	NOx

	95% control or 0.15 lb/MMBtu (coal) and 0.33 lbs/MMBtu (oil)

	o In NOx SIP call area,

extend use of controls to

year-round, and

o 0.1 – 0.25 lbs/MMBtu,

depending on boiler and fuel type





Massachusetts’ Alternative BART Program for SO2

MassDEP’s Alternative to BART for SO2 relies on:

310 CMR 7.29, Emissions Standards for Power Plants, which establishes
SO2 emissions standards for certain EGUs.

Permit restrictions for Mt. Tom Station, Brayton Point, and Salem Harbor
that disallow the use of 310 CMR 7.29 SO2 Early Reduction Credits and
federal Acid Rain Allowances for compliance with 310 CMR 7.29. 

An annual cap of 300 tons of SO2 for Salem Harbor Unit 2, and a shutdown
of Units 3 and 4 beginning June 1, 2014.

The retirement of Somerset Power in 2010.

Amended regulation 310 CMR 7.05, Fuels All Districts, which requires
EGUs that burn residual oil to limit the sulfur content to 0.5% by
weight beginning July 1, 2014.

Each is described below:

310 CMR 7.29, Emissions Standards for Power Plants:  MassDEP’s
existing regulation 310 CMR 7.29 (Appendix DD) establishes a
facility-wide rolling 12-month SO2 emissions rate of 3.0 pounds per
megawatt-hour and a monthly average emissions rate of 6.0 pounds per
megawatt-hour.  This regulation allows the use of 310 CMR 7.29 SO2 Early
Reduction Credits (on a 1 ton credit to 1 ton excess emission basis) and
the use of federal Acid Rain SO2 Allowances (on a 3 ton allowance to 1
ton excess emission basis) for compliance with the 3.0 pounds per
megawatt-hour emissions rate.  310 CMR 7.29 applies to Brayton Point,
Canal Station, Mt. Tom Station, Mystic, Salem Harbor, and Somerset
Power.    

Mt. Tom Station:  On May 15, 2009, MassDEP issued an amended Emission
Control Plan Final Approval (Appendix EE) for Mt. Tom Station that
prohibits the use of 310 CMR 7.29 SO2 Early Reduction Credits and
federal Acid Rain Allowances for compliance with 310 CMR 7.29.

Brayton Point:  On April 12, 2012, MassDEP issued an Amended Emission
Control Plan Final Approval (Appendix GG) that prohibits the use of
Early Reduction Credits and federal Acid Rain Allowances for compliance
with 310 CMR 7.29 after June 1, 2014.      

Salem Harbor:  On March 27, 2012, MassDEP issued a Final Amended
Emission Control Plan (ECP) Approval (Appendix FF) that prohibits the
use of 310 CMR 7.29 SO2 Early Reduction Credits and federal Acid Rain
Allowances for compliance with 310 CMR 7.29, after June 1, 2014.  The
ECP also establishes an annual cap of 300 tons of SO2 for Salem Harbor
Unit 2 and the shutdown of Units 3 and 4 effective June 1, 2014.

Somerset Power Retirement:  Somerset Power ceased operating in 2010, and
on June 22, 2011, MassDEP issued a letter (Appendix HH) that revoked all
air approvals and permits for the facility and deemed all pending permit
applications withdrawn.  

310 CMR 7.05 Fuels All Districts:  MassDEP’s 310 CMR 7.05, Fuels All
Districts (Appendix II) requires EGUs that burn residual oil to limit
the sulfur content to 0.5% by weight beginning July 1, 2014.

Analysis of Alternative BART Program for SO2

Table 16 shows the BART benchmark estimated SO2 emissions for the
BART-eligible units, which were calculated by multiplying the MANE-VU
BART workgroup recommended BART SO2 emission rates in lbs/MMBtu (see
Table 15 above) by each unit’s 2002 heat input in MMBtu.  The BART
benchmark results in a estimated emissions reduction of 50,752 tons of
SO2 from 2002 emissions.

Table   SEQ Table \* ARABIC  16 : BART Benchmark for SO2

BART Eligible Facility	Unit	2002 SO2 Emissions (Tons)	2002 Heat Input
(MMBtu)	MANE-VU Recommended SO2 BART Emission Rate (lbs/MMBtu)	BART
Benchmark Estimated SO2 Emissions (Tons)

Brayton Point 	1	9,254	17,000,579	0.15	1,275

Brayton Point 	2	8,853	15,896,795	0.15	1,192

Brayton Point 	3	19,450	36,339,809	0.15	2,725

Brayton Point	4	2,037	4,787,978	0.33	790

Canal Station 	1	13,066	27,295,648	0.33	4,504

Canal Station 	2	8,948	19,440,919	0.33	3,208

Cleary Flood 	8	39	92,567	0.33	15

Cleary Flood 	9	68	2,123,819	0.33	350

Mystic 	7	3,727	15,172,657	0.33	2,503

Salem Harbor 	4	2,886	6,137,412	0.33	1,013

 Total	 	68,328	 	 	17,576

	SO2 Reduction	50,752



Table 17 shows the Alternative to BART estimated SO2 emissions, which
were calculated by multiplying MassDEP’s 310 CMR 7.05 SO2 emission
rates in lbs/MMBtu by the 2002 heat input in MMBtu, multiplying the 310
CMR 7.29 SO2 rolling 12-month emissions rate in lbs/MWh by the 2002
megawatt-hours electrical generation, and accounting for permit
restrictions in effect at Mt. Tom Station, Brayton Point, and Salem
Harbor, as well as the retirement of Somerset Power.  The Alternative to
BART results in a estimated emissions reduction of 54,986 tons from 2002
emissions, which is 4,234 tons more than the estimated emissions
reductions from the BART benchmark.  

Table   SEQ Table \* ARABIC  17 :  Alternative to BART for SO2

Facility	Unit	2002 SO2 Emissions (Tons)	2002 Heat Input (MMbtu) or
Generation (MWh)	Alternative BART Emission Rate (lbs/MMBtu or lbs/MWh)
Alternative BART Estimated SO2 Emissions (Tons)

Brayton Point 	1	9,254	1,951,839	3.0	2,928

Brayton Point 	2	8,853	1,855,515	3.0	2,783

Brayton Point 	3	19,450	4,294,957	3.0	6,442

Brayton Point 	4	2,037	4,787,978	0.56	1,341

Canal Station	1	13,066	27,295,648	0.56	7,643

Canal Station 	2	8,948	19,440,919	0.56	5,443

Cleary Flood 	8	39	92,567	0.56	25

Cleary Flood 	9	68	2,123,819	0.56	595

Mount Tom 	1	5,282	1,047,524	3.0	1,571

Mystic 	7	3,727	15,172,657	0.56	4,248

Salem Harbor 	1	3,425	631,606	3.0	947

Salem Harbor 	2	2,821	527,939	Cap	300

Salem Harbor 	3	4,999	974,990	Retired	0

Salem Harbor 	4	2,886	6,137,412	Retired	0

Somerset 	8	4,399	8,910,087	Retired	0

 Total	 	89,254	 	 	34,268

	SO2 Reduction	54,986



40 CFR 51.308(e)(3) provides a process for determining whether an
alternative measure makes greater reasonable progress than would be
achieved through the installation and operation of BART.  If the
geographic distribution of emissions reductions is similar between an
alternative measure and BART, the comparison of the two measures may be
made on the basis of emissions alone.  The alternative measure may be
deemed to make greater reasonable progress than BART if it results in
greater emissions reductions than requiring sources subject to BART to
install, operate and maintain BART.  In this case, the Alternative to
BART achieves greater emissions reductions than BART and the geographic
distribution of emissions reductions is nearly identical since all of
the units subject to BART are included in the Alternative to BART.

Massachusetts’ Alternative BART Program for NOx

MassDEP’s Alternative to BART for NOx relies on:

310 CMR 7.29, Emissions Standards for Power Plants, which establishes
NOx emissions rates for certain EGUs.

An annual cap of 276 tons of NOx for Salem Harbor Unit 1 and an annual
cap of 50 tons of NOx for Unit 2, and a shutdown of Units 3 and 4
beginning June 1, 2014.

The retirement of Somerset Power in 2010.

310 CMR 7.19, Reasonably Available Control Technology (RACT) for Sources
of Oxides of Nitrogen NOx, which establishes NOx emissions standards for
various sources, including EGUs.

Each is described below:

310 CMR 7.29, Emissions Standards for Power Plants: MassDEP’s existing
regulation 310 CMR 7.29 establishes a rolling 12-month average NOx
emission rate of 1.5 lbs/MWh and a monthly average emission rate of 3
lbs/MWh.  310 CMR 7.29 applies to Brayton Point, Canal Station, Mt. Tom
Station, Mystic, Salem Harbor, and Somerset Power.    

Salem Harbor:  On March 27, 2012, MassDEP issued a Final Amended
Emission Control Plan (ECP) Approval (Appendix FF) that requires an
annual cap of 276 tons of NOx for Salem Harbor Unit 1 and an annual cap
of 50 tons of NOx for Unit 2, and a shutdown of Units 3 and 4 beginning
June 1, 2014.  

Somerset Power Retirement:  Somerset Power ceased operating in 2010, and
on June 22, 2011, MassDEP issued a letter (Appendix HH) that revoked all
air approvals and permits for the facility and deemed all pending permit
applications withdrawn.  

310 CMR 7.19, Reasonably Available Control Technology (RACT) for Sources
of Oxides of Nitrogen NOx:  MassDEP’s existing regulation 310 CMR 7.19
establishes NOx emissions rates for various stationary sources,
including EGUs.  Under 310 CMR 7.19, Cleary Flood Units 8 and 9 are
subject to a NOx emission rate of 0.28 lbs/MMBtu.  Mystic Unit 7 is
subject to a NOx emission rate of 0.25 lbs/MMBtu.  Mystic also is
subject to 310 CMR 7.29 on a facility-wide basis; however, Mystic Unit 7
could exceed the 310 CMR 7.29 NOx rate of 1.5 lbs/MWh while the facility
as a whole complies with the rate because the other units at Mystic are
natural gas-fired with low NOx emissions, and therefore the 310 CMR 7.19
unit-specific NOx rate of 0.25 lbs/MMBtu is the controlling factor for
Unit 7.

Analysis of Alternative BART Program for NOx

Table 18 shows the BART benchmark estimated NOx emissions for the
BART-eligible units, which were calculated by multiplying the lowest
MANE-VU BART workgroup recommended BART emission rate of 0.1 lb/MMBtu
(from Table 15 above) by the 2002 heat input in MMBtu.  The BART
benchmark results in estimated emissions reductions of 12,820 tons of
NOx from 2002 emissions.

Table   SEQ Table \* ARABIC  18 : BART Benchmark for NOx

BART-Eligible Facility	Unit	2002 NOx Emissions (Tons)	2002 Heat Input
(MMBtu)	MANE-VU Recommended BART NOx Emission Rate (lbs/MMBtu)	BART
Benchmark Estimated NOx Emissions (Tons)

Brayton Point 	1	2,513	17,000,579	0.10	850

Brayton Point 	2	2,270	15,896,795	0.10	795

Brayton Point 	3	7,335	36,339,809	0.10	1,817

Brayton Point	4	552	4,787,978	0.10	239

Canal Station 	1	3,339	27,295,648	0.10	1,365

Canal Station 	2	2,260	19,440,919	0.10	972

Cleary Flood 	8	12	92,567	0.10	5

Cleary Flood 	9	161	2,123,819	0.10	106

Mystic 	7	805	15,172,657	0.10	759

Salem Harbor 	4	787	6,137,412	0.10	307

 Total	 	20,034	 	 	7,214

	NOx Reduction	12,820



Table 19 shows the Alternative to BART estimated NOx emissions, which
were calculated by multiplying MassDEP’s 310 CMR 7.29 NOx emission
rate in lbs/megawatt hour (MWh) and 310 CMR 7.19 NOx emission rate in
lbs/MMbtu by the 2002 electricity generation in MWh and 2002 heat input
in MMBtu, respectively, and accounting for permit restrictions in effect
at Salem Harbor and the retirement of Somerset Power.  The Alternative
to BART results in estimated emission reductions of 13,117 tons from
2002 emissions. The estimated NOx reductions from the Alternative to
BART are 297 tons more than estimated reductions from BART alone.

Table   SEQ Table \* ARABIC  19 :  Alternative to BART for NOx

Facility	Unit	2002 NOx Emission (Tons)	2002 Heat Input (MMBtu) or
Generation (MWh)	Alternative BART Emission Rate (lbs/MMBtu or lbs/MWh)
Alternative BART Estimated NOx Emissions (Tons)

Brayton Point 	1	2,513	1,951,839	1.5	1,464

Brayton Point 	2	2,270	1,855,515	1.5	1,392

Brayton Point 	3	7,335	4,294,957	1.5	3,221

Brayton Point 	4	552	401,305	1.5	301

Canal Station	1	3,339	2,945,578	1.5	2,209

Canal Station 	2	2,260	1,910,079	1.5	1,433

Cleary Flood 	8	12	92,567	0.28	13

Cleary Flood 	9	161	2,123,819	0.28	297

Mount Tom 	1	1,969	1,047,524	1.5	786

Mystic 	7	805	15,172,657	0.25	1,897

Salem Harbor 	1	920	631,606	Cap	276

Salem Harbor 	2	755	527,939	Cap	50

Salem Harbor 	3	1,331	974,990	Retired	0

Salem Harbor 	4	787	508,342	Retired	0

Somerset 	8	1,445	8,910,087	Retired	0

 	 	26,455	 	 	13,338

	NOx Reduction	13,117



As with SO2, the Alternative to BART achieves greater NOx emission
reductions than BART and the geographic distribution of NOx emissions
reductions is nearly identical since all of the units subject to BART
are included in the Alternative to BART.

BART for PM10 Emissions

MassDEP has made source-by-source BART determinations for PM10 emissions
from its BART EGUs.  An overview of 2002 and 2009 PM10 emissions and PM
controls at the EGU BART sources is contained in Table 20. 
Collectively, these facilities emitted 1,531 tons of PM10 in 2002 that
diminished visibility in New England Class I areas by 0.032-0.037
deciviews (ddv).  Through installation of controls, these facilities
have significantly reduced PM emissions, so that in 2009 these
facilities emitted a total of 109 tons of PM10.

CALPUFF modeling of 2002 PM emissions at these facilities shows an
impact that was well below 0.1 ddv on the worst day at affected Class I
areas, for each unit and cumulatively, which is the level MANE-VU has
identified that the degree of visibility improvement is so small (<0.1
ddv) that no reasonable weighting could justify additional controls
under BART.  The visibility impact would be even lower today based on
the emissions reductions achieved since 2002 as shown in Table 20. 
MassDEP considered MANE-VU’s evaluation of PM control options; 
however, MassDEP has determined that no additional controls are
warranted for primary PM10 because controls have been added to all but
one of the facilities, and the additional cost of further control is not
justified since there would be no significant visibility improvement. 

Table   SEQ Table \* ARABIC  20 : Massachusetts PM10 BART Sources,
Emissions and Controls

I.D.	Source	Unit	PM10 ddv	2002 PM10 Emissions (tpy)	2009 PM10 Emissions
(tpy)	PM Controls	PM Emission Limits lbs/MMBtu as of 2009

1200061	Brayton Point	1	0.031, 0.026	386	39	Fabric Filter Baghouse	0.08

1200061	Brayton Point	2



Fabric Filter Baghouse	0.08

1200061	Brayton Point	3



Fabric Filter Baghouse (Planned)	0.08

1200061	Brayton Point	4	0.000, 0.000	6	0	ESP	0.03

1200054	Canal Station	1	0.000, 0.000	672	60	ESP	0.02

1200054	Canal Station	2



ESP	0.02

1190128	Mystic Station	7	0.002, 0.003	131	4	ESP	0.05

1190194	Salem Harbor	4	0.001, 0.001	316	0	ESP	0.04

1200067	Cleary Flood	8	0.003, 0.002	20	6	 None	0.12

1200067	Cleary Flood	9



 None

 	0.12

Reasonably Attributable Visibility Impairment

40 CFR 51.302(c) provides for general plan requirements in cases where
the affected Federal

Land Manager has notified the state that Reasonably Attributable
Visibility Impairment

(RAVI) exists in a Class I Area in the state.  Based on the modeling
conducted by MANE-VU

and consultations with Federal Land Managers, there are no RAVI sources
in Massachusetts or the other MANE-VU states.

Reasonable Progress Goals 

For each Class I area within a State/Tribe, 40 CFR Section 51.308(d)(1)
requires the State/Tribe to establish reasonable progress goals
(expressed in deciviews) that provide for reasonable progress towards
achieving natural visibility.  EPA released guidance on June 7, 2007 to
use in setting reasonable progress goals.  The goals must provide
improvement in visibility for the most impaired days and ensure no
degradation in visibility for the least impaired days over the SIP
period.  The State/Tribe also must provide an assessment of the number
of years it would take to attain natural visibility conditions if
improvement continues at the rate represented by the reasonable progress
goals. 

Under 40 CFR Section 51.308(d)(1)(iv), consultation is required in
developing reasonable progress goals. The rule states:  

In developing each reasonable progress goal, the State must consult with
those States which may reasonably be anticipated to cause or contribute
to visibility impairment in the mandatory Class I Federal area. In any
situation in which the State cannot agree with another such State or
group of States that a goal provides for reasonable progress, the State
must describe in its submittal the actions taken to resolve the
disagreement. In reviewing the State's implementation plan submittal,
the Administrator will take this information into account in determining
whether the State's goal for visibility improvement provides for
reasonable progress towards natural visibility conditions.

In developing the reasonable progress goal, the Class I State/Tribe also
must consider four factors (cost of compliance, time needed for
compliance, energy and non-air quality environmental impacts, and
remaining useful life of any affected source).  The State/Tribe also
must show that it considered the uniform rate of progress and the
emission reduction measures needed to achieve reasonable progress for
the period covered by the implementation plan, and if the state proposes
a rate of progress slower than the uniform rate of progress, assess the
number of years it would take to attain natural conditions if visibility
improvement continues at the rate proposed. 

Because Massachusetts does not contain any Class I areas, it did not
determine reasonable progress goals but did consult with states it
impacts.  Massachusetts consulted with Maine, New Hampshire, and
Vermont, which have Class I areas impacted by emissions from sources
within Massachusetts.  Massachusetts agrees with the reasonable progress
goals established by these states through the MANE-VU planning process
for their Class I areas.

As a benchmark to aid in developing reasonable progress goals, MANE-VU
compared baseline visibility conditions to natural visibility conditions
at each MANE-VU Class I area.  The difference between baseline and
natural visibility conditions for the 20 percent worst days was used to
determine the uniform rate of progress that would be needed during each
implementation period in order to attain natural visibility conditions
by 2064.  Table 21 presents baseline visibility, natural visibility, and
required uniform rate of progress for the MANE-VU Class I areas affected
by emissions from sources within Massachusetts.  Visibility values are
expressed in deciviews (dv), where each single-unit deciview decrease
would represent a barely perceptible improvement in visibility.

Table   SEQ Table \* ARABIC  21 : 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

Note: Both natural conditions and baseline visibility for the 5-year
period from 2000 through 2004 were calculated in conformance with an
alternative method recommended by the IMPROVE Steering Committee.

The reasonable progress goals established for each of the Class I areas
are expected to provide greater visibility improvements than the uniform
rate of progress shown in Table 21.  A summary of the reasonable
progress goals are shown in Tables 22 and 23. 

Table   SEQ Table \* ARABIC  22 : Reasonable Progress Goals - 20% Worst
Days (all values in deciviews)

Visibility Condition	2000-2004 Baseline Visibility	2018 Reasonable
Progress Goal	Visibility Improvement by 2018	Natural Visibility

Acadia National Park	22.9	19.4	3.5	12.4

Moosehorn Wilderness Area/ Roosevelt Campobello International Park 	

21.7	

19.0	

2.7	

12.0

Great Gulf Wilderness	22.8	19.1	3.7	12.0

Presidential Range – Dry River Wilderness	22.8	19.1	3.7	12.0

Lye Brook Wilderness	24.4	20.9	3.5	11.7



Table   SEQ Table \* ARABIC  23 : Reasonable Progress Goals - 20% Best
Days (all values in deciviews)

Visibility Condition	2000-2004 Baseline Visibility	2018 Reasonable
Progress Goal	Visibility Improvement by 2018	Natural Visibility

Acadia National Park	8.8	8.3	0.5	4.7

Moosehorn Wilderness Area/ Roosevelt Campobello International Park 	

9.2	

8.6	

0.6	

5.0

Great Gulf Wilderness	7.7	7.2	0.5	3.7

Presidential Range – Dry River Wilderness	7.7	7.2	0.5	3.7

Lye Brook Wilderness	6.4	5.5	0.9	2.8

  

Long-Term Strategy

40 CFR Section 51.308(d)(3) requires Massachusetts to submit a long-term
strategy that addresses regional haze visibility impairment for each
mandatory Class I Federal area within and outside the state that may be
affected by emissions from within the state.  The long-term strategy
must include enforceable emissions limitations, compliance schedules,
and other measures necessary to achieve the reasonable progress goals
established by states where the Class I areas are located.  Consultation
between states affecting and/or containing Class I areas must be
performed to develop coordinated emission management strategies.  The
state must demonstrate that it has included all measures necessary to
obtain its share of the emission reductions needed to meet the progress
goal for the area.  If the state has participated in a regional planning
process, the state must include measures needed to achieve its
obligations agreed upon through that process.  

This section describes the long-term strategy that Massachusetts will
pursue to address visibility impairment for each of the following Class
I areas that are affected by emissions from within Massachusetts: Acadia
National Park, Great Gulf Wilderness, Lye Brook Wilderness, Presidential
Range/Dry River Wilderness, Moosehorn Wilderness, and
Roosevelt/Campobello International Park.  

The long-term strategy includes enforceable emissions limitations,
compliance schedules, and other measures necessary to achieve the
reasonable progress goals established for the Class I areas.  To the
extent that it is practicable, Massachusetts commits to adopting these
measures before submitting a report on reasonable progress to EPA in
2013.  Additional measures may be reasonable to adopt at a later date
after further consideration and review.

Overview of the Long-Term Strategy Development Process

As a participant in MANE-VU, Massachusetts supported a regional approach
towards deciding which control measures to pursue for regional haze
based on technical analyses documented in the following reports:

Contributions to Regional Haze in the Northeast and Mid-Atlantic United
States (called the Contribution Assessment, Appendix   REF _Ref191968764
\r \h  \* MERGEFORMAT  A ), 

Five-Factor Analysis of BART-Eligible Sources: Survey of Options for
Conducting BART Determinations (Appendix R),

Comparison of CAIR and CAIR Plus Proposal using the Integrated Planning
Model® (called the CAIR+ Report, Appendix S),

Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I
Areas (called the Reasonable Progress Report, Appendix T), and

Assessment of Control Technology Options for BART-Eligible Sources:
Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and
Pulp Facilities (Appendix U). 

The regional strategy development process identified reasonable measures
that would reduce emissions contributing to visibility impairment at
Class I areas affected by emissions from within the MANE-VU region by
2018 or earlier.  The technical basis for the long-term strategy is
discussed in the following section, which describes the process of
identifying potential emission reduction strategies.

MANE-VU reviewed a wide range of potential control measures to reduce
emissions from sources contributing to visibility impairment in affected
Class I areas.  The process by which MANE-VU arrived at a set of
proposed regional haze control measures to pursue for the 2018 milestone
started in late 2005 in conjunction with efforts to identify measures to
reduce ozone pollution.  The Ozone Transport Commission (OTC) selected a
contracting firm to assist with the analysis of ozone and regional haze
control measure options.  OTC provided the contractor with a “master
list” of some 900 potential control measures, based on experience and
previous state implementation plan work.  With the help of an internal
OTC control measure workgroup, the contractor also identified available
regional haze control measures for MANE-VU’s further consideration.

MANE-VU then developed an interim list of control measures, which for
regional haze included: beyond-CAIR sulfate reductions from EGUs,
low-sulfur heating oil (residential and commercial), and controls on ICI
boilers (both coal and oil-fired), lime and cement kilns, residential
wood combustion, and outdoor burning (including outdoor wood boilers).

The next step in the regional haze control measure selection process was
to further refine the interim list.  The CAIR+ Report (Appendix   REF
_Ref197852454 \r \h  S ) documents the analysis of the cost of
additional SO2 and NOx controls at EGUs in the Eastern U.S.  The
Reasonable Progress Report (Appendix   REF _Ref197852975 \r \h  T )
documents the assessment of control measures for EGUs and the other
source categories selected for analysis.  Further analysis is provided
in the NESCAUM document entitled, “Assessment of Control Technology
Options for BART-Eligible Sources: Steam Electric Boilers, Industrial
Boilers, Cement Plants and Paper and Pulp Facilities” (Appendix   REF
_Ref197852974 \r \h  \* MERGEFORMAT  0 ). 

The beyond-CAIR EGU strategy continued to stay on the list since EGU
sulfate emissions have, by far, the largest impact on visibility in the
MANE-VU Class I areas.  Likewise, a low-sulfur oil strategy gained
support after a NESCAUM-initiated conference with refiners and fuel-oil
suppliers concluded that such a strategy could realistically be
implemented in the 2014 timeframe.  The low-sulfur heating oil and the
oil-fired ICI boiler sector control measures merged into an overall
low-sulfur oil strategy for distillate and residual oils for both the
residential and commercial heating and oil-fired ICI boiler source
sectors.

During MANE-VU’s internal consultation meeting in March 2007, member
states reviewed the interim list of control measures to make further
refinements.  States determined, for example, that there are too few
coal-fired ICI boilers in the MANE-VU states to be considered a
“regional” control strategy, but could be a sector pursued by
individual states.  They also determined that control of lime and cement
kilns, of which there are few in the MANE-VU region, would likely be
handled in each state’s BART determination process.  Residential wood
burning and outdoor wood boilers remained a strategy for those states
where localized visibility impacts may be of concern even though
emissions from these sources are primarily organic carbon and direct
particulate matter.  Finally, outdoor wood burning also was determined
to be better left as a sector to be examined and controlled further by
individual states, due to issues of enforceability and penetration of
existing state regulations.

Technical Basis for Strategy Development 

40 CFR Section 51.308(d)(3)(iii) requires states to document the
technical basis for the state’s apportionment of emission reductions
necessary to meet reasonable progress goals in each Class I area
affected by the state’s emissions.  Massachusetts relied on technical
analyses developed by MANE-VU to demonstrate that its emission
reductions, when coordinated with those of other states, are sufficient
to achieve reasonable progress goals in Class I areas affected by
Massachusetts.

The emission reductions necessary to meet reasonable progress goals in
each Class I area affected by Massachusetts are summarized in the
following sections of this SIP and are described in the following
documents:

Contributions to Regional Haze in the Northeast and Mid-Atlantic United
States (called the Contribution Assessment, Appendix   REF _Ref191968764
\r \h  \* MERGEFORMAT  A )

Baseline and Natural Background Visibility Conditions—Considerations
and Proposed Approach to the Calculation of Baseline and Natural
Background Visibility Conditions at MANE-VU Class I Areas (Appendix  
REF _Ref191968946 \r \h  \* MERGEFORMAT  E )

MANE-VU Modeling for Reasonable Progress Goals: Model Performance
Evaluation, Pollution Apportionment, and Control Measure Benefits
(Appendix   REF _Ref201032634 \r \h  \* MERGEFORMAT  F )

2018 Visibility Projections (Appendix   REF _Ref201032635 \r \h  \*
MERGEFORMAT  G )

Five-Factor Analysis of BART-Eligible Sources: Survey of Options for
Conducting BART Determinations (Appendix   REF _Ref201033142 \r \h  \*
MERGEFORMAT  R )  

Comparison of CAIR and CAIR Plus Proposal using the Integrated Planning
Model® (called the CAIR+ Report, Appendix   REF _Ref197852454 \r  \*
MERGEFORMAT  S )

Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I
Areas (called the Reasonable Progress Report) (Appendix   REF
_Ref197852975 \r  \* MERGEFORMAT  T )

Assessment of Control Technology Options for BART-Eligible Sources:
Steam Electric Boilers, Industrial Boilers, Cement Plants and Paper and
Pulp Facilities (Appendix   REF _Ref197852974 \r  \* MERGEFORMAT  0 )

The Nature of the Fine Particle and Regional Haze Air Quality Problems
in the MANE-VU Region:  A Conceptual Description (Appendix   REF
_Ref197834028 \r \h  \* MERGEFORMAT  V )

In addition, Massachusetts relied on analyses conducted by neighboring
RPOs, including the following documents, which are available upon
request but are not incorporated into this SIP:

VISTAS Reasonable Progress Analysis Plan by VISTAS, dated September 18,
2006

Reasonable Progress for Class I Areas in the Northern Midwest-Factor
Analysis, by EC/R, dated July 18, 2007

Massachusetts worked with other members of the Ozone Transport
Commission and MANE-VU, as described in Section 2, to consider a wide
variety of potential emission reduction strategies covering a wide range
of sources of SO2 and other pollutants contributing to regional haze. 
40 CFR 51.308(d)(1) requires states to consider several factors in
developing their long-term strategies.  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 industrial, commercial and institutional boilers;

Cement kilns;

Lime kilns;

The use of low-sulfur heating oil; and

Residential wood combustion and open burning.

These efforts led to the selection of the emission reduction strategies
presented in this SIP.

2018 Emission Reductions Due to Ongoing Air Pollution Controls

40 CFR Section 51.308(d)(3)(v)(A) requires states to consider emission
reductions from ongoing pollution control programs.  In developing its
long-term strategy, Massachusetts considered emission control programs
being implemented between the 2002 baseline period and 2018, as
discussed below.  Many of the emission reduction programs represent
commitments already made by Massachusetts and other states to implement
air pollution control measures for EGU point sources, non-EGU point
sources, and area sources, respectively.  These control measures are the
same measures that were included in the 2018 emissions inventory and
used in the modeling.  While these control measures were not designed
expressly for the purpose of improving visibility, the pollutants they
control include those that contribute to visibility impairment in
MANE-VU Class I Areas.

MANE-VU’s 2018 “beyond on the way” (BOTW) emissions inventory
accounts for emission controls that are already in place, as well as
those that are not yet finalized but are likely to achieve additional
reductions by 2009.  The BOTW inventory was developed based on the
MANE-VU 2002 Version 3.0 inventory and the MANE-VU 2018 on the books/on
the way (OTB/OTW) inventory.  Inventories used for other RPOs also
reflect anticipated emissions controls that will be in place by 2018. 
The inventory is termed “beyond on the way” because it includes
control measures that were developed for ozone SIPs that are not yet on
the books in some states.  For some states, it also included controls
that were under consideration for Regional Haze SIPs that have not yet
been adopted.  Given the uncertainty inherent in the BOTW emissions
inventory due to lack of enforceability, Massachusetts is continuing to
evaluate these measures to determine whether they are reasonable to
adopt and implement by 2018 and expects to make that determination in
the progress report it will submit in 2013.

More information may be found in the following documents:

MANE-VU Modeling for Reasonable Progress Goals: Model Performance
Evaluation, Pollution Apportionment, and Control Measure Benefits
(Appendix   REF _Ref201032634 \r \h  \* MERGEFORMAT  F )

2018 Visibility Projections (Appendix   REF _Ref201032635 \r \h  \*
MERGEFORMAT  G )

Development of Emissions Projections for 2009, 2012, and 2018 for
Non-EGU Point, Area, and Non-road Sources in the MANE-VU Region
(Appendix   REF _Ref191969187 \r \h  \* MERGEFORMAT  N )

Documentation of 2018 Emissions from Electric Generating Units in the
Eastern U.S. for MANE-VU’s Regional Haze Modeling (Appendix   REF
_Ref197835294 \r  \* MERGEFORMAT  W )

EGU Emissions Controls Expected by 2018 

The following EGU emission reduction programs were included in the
modeling used to develop the reasonable progress goals and as the basis
for the long-term strategy:  

Clean Air Interstate Rule (CAIR). The CAIR program was intended to
permanently cap emissions of SO2 and NOx in the eastern United States by
2015 and reduce SO2 emissions in the CAIR region by more than 70 percent
and NOx emissions by more than 60 percent from 2003 levels.  However,
CAIR was vacated by the U.S. Court of Appeals on July 11, 2008.  A
subsequent remand to EPA for remedy occurred on December 23, 2008.  CAIR
remained in place through 2011.    On August 8, 2011, EPA promulgated
the Cross State Air Pollution Rule, effective beginning January 1, 2012.
The IPM® model was used to predict future emissions from EGUs after
implementation of CAIR.  All MANE-VU Class I states used CAIR as a basis
for modeling progress towards the reasonable progress goals in their
Regional Haze SIPs.  For the short-term, this modeling is still valid. 
MANE-VU will incorporate the details of EPA’s CSAPR into future
modeling. 

Modifications to the output of IPM® made to better represent
anticipated controls are described in the report Documentation of 2018
Emissions from Electric Generating Units (Appendix   REF _Ref197835294
\r  \* MERGEFORMAT  W ). Controls considered in making these
modifications include the following:

Connecticut EGU Regulations: Connecticut adopted the following
regulations governing EGU emissions:

      

Regulations of Connecticut State Agencies (RCSA) section 22a-174- 19a,
limiting the SO2 emission rate to 0.33 lb SO2/MMBtu for fossil
fuel-fired EGUs greater than 15 MW that also are Title IV sources.
(Implementation status - 2007)

RCSA section 22a-174-22, limiting the non-ozone seasonal NOx emission
rate to 0.15 lb NOx/MMBtu for fossil fuel-fired EGUs greater than 15 MW.
(Implementation status - 2007)

Connecticut General Statutes section 22a-199, limiting the mercury (Hg)
emission rate to 0.0000006 lb Hg/MMBtu for all coal-fired EGUs, or
alternatively coal-fired EGUs can meet a 90% Hg emission reduction.
(Implementation status - 2008)

Delaware EGU Regulations:  Delaware adopted the following regulations
governing EGU emissions:

Reg. 1144, Control of Stationary Generator Emissions, SO2, PM, VOC and
NOx emission control, Statewide, Effective January 2006.

Reg. 1146, EGUs, Electric Generating Unit (EGU) Multi-Pollutant
Regulation, SO2 and NOx emission control, Statewide, Effective December
2007. SO2 reductions will be more than regulation specifies.

Regulation No. 1148, Control of Stationary Combustion Turbine Electric
Generating Unit Emissions, SO2, NOx, and PM2.5 emission control,
Statewide, Effective January 2007. 

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

SO2 2002 levels of 32,630 tons to 8,137 tons in 2018 (75 percent
decrease) 

NOx 2002 levels of 8,735 tons to 3,740 tons in 2018 (57 percent
decrease)

Delaware Consent Decree:  Valero Refinery Delaware City, DE (formerly
Motiva, Valero Enterprises). 2002 SO2 levels of 29,747 tons will
decrease to 608 tons in 2018 (98 percent decrease). NOx 2002 levels of
1,022 tons will decrease to 102 tons in 2018 (90 percent decrease).

Maine EGU Regulations:  Maine adopted the following regulations
governing EGU emissions:

	Chapter 145 NOx Control Program, which limits the NOx emission rate to
0.22 lb NOx/MMBtu for fossil fuel-fired units greater than 25 MW built
before 1995 with a heat input capacity between 250 and 750 MMBtu/hr and
also limits the NOx emission rate to 0.15 lb NOx/MMBtu for fossil
fuel-fired units greater than 25 MW built before 1995 with a heat input
capacity greater than 750 MMBtu/hr. (Implementation - 2007)

Massachusetts EGU Regulations:  Massachusetts adopted 310 CMR 7.29,
Emissions Standards for Power Plants, in 2001, which:

Applies to six of the largest fossil fuel-fired power plants in
Massachusetts, including Brayton Point (Units 1, 2, 3, 4), Mystic (Units
4, 5, 6, 7, 81, 82, 93, and 94), NRG Somerset (Units 8), Mount Tom (Unit
1), Canal Station (Units 1 and 2), and Salem Harbor (Units 1, 2, 3, and
4).

Limits SO2 emissions to 6.0 lbs/MWh each month and 3.0 lbs/MWh as a
rolling average incorporating allowances and early reduction credits.

 Limits NOx emissions to 3.0 lbs/MWh each month and 1.5 lbs/MWh as a
rolling average.

Limits mercury (Hg) emissions to 85% Hg reduction or 0.0075 lbs Hg/GWh
in 2008 and 90% Hg reduction or 0.0025 lbs Hg/GWh in 2012.

Limits CO2 emissions to 1,800 lbs CO2/MWh.

These regulations will achieve an approximately 50 percent reduction in
NOx emissions and 50 - 75 percent reduction in SO2 emissions.

New Hampshire EGU Regulations: New Hampshire adopted the following
regulations governing EGU emissions:

Chapter Env-A 2900, which caps NOx emissions on all existing fossil
steam units to 3,644 tons NOx per year, SO2 emissions on all existing
fossil steam units to 7,289 tons SO2 per year, and CO2 emissions on all
existing fossil steam units to 5,425,866 tons CO2 per year.
(Implementation - 2007)

Chapter Env-A 3200, which limits NOx emissions on all fossil fuel-fired
EGUs greater than 15 MW to 0.15 lb NOx/MMBtu. (Implementation - 2007)

New Jersey New Source Review Settlement Agreements:  The New Jersey
settlement agreement with PSEG required the following actions:

Repower Bergen Unit #2 to combined cycle by December 31, 2002.

For Hudson Unit #2, install Dry FGD or approved alternative technology
by Dec. 31, 2006 to control SO2 emissions and operate the control
technology at all times the unit operates to limit SO2 emissions to 0.15
lb SO2/MMBtu; install SCR or approved alternative technology by May 1,
2007 to control NOx emissions and operate the control technology
year-round to limit NOx emissions to 0.1 lb NOx/MMBtu; and install a
baghouse or approved alternative technology by May 1, 2007 to control PM
emissions and limit PM emissions to 0.015 lb PM/MMBtu.  The settlement
also requires coal with a monthly average sulfur content no greater than
2% at units operating an FGD.

For Mercer Unit #1: install Dry FGD or approved alternative technology
by Dec. 31, 2010 to control SO2 emissions and operate the control
technology at all times the unit operates to limit SO2 emissions to 0.15
lb SO2/MMBtu and install SCR or approved alternative technology by 2005
to control NOx emissions and operate the control technology ozone season
only in 2005 and year-round by May 1, 2006 to limit NOx emissions to
0.13 lb NOx/MMBtu.  The settlement also requires coal with a monthly
average sulfur content no greater than 2% at units operating an FGD.

For Mercer Unit #2: install Dry FGD or approved alternative technology
by Dec. 31, 2012 to control SO2 emissions and operate the control
technology at all times the unit operates to limit SO2 emissions to 0.15
lb SO2/MMBtu and install SCR or approved alternative technology by 2004
to control NOx emissions and operate the control technology ozone season
only in 2004 and year-round by May 1, 2006 to limit NOx emissions to
0.13 lb NOx/MMBtu.  The settlement also requires coal with a monthly
average sulfur content no greater than 2% at units operating an FGD.

New York EGU Regulations: New York adopted the following regulations
governing EGU emissions:

Part 237, which limits NOx emissions from all fossil fuel-fired EGUs
greater than 25 MW to a non-ozone season cap of 39,908 tons in 2007 and
annual SO2 emissions from all fossil fuel-fired EGUs greater than 25 MW
to an annual cap of 197,046 tons SO2/year starting in 2007 and an annual
cap of 131,364 tons SO2/year starting in 2008.  

North Carolina Clean Smokestacks Act: Under the act, enacted in 2002,
coal-fired power plants (EGUs) in North Carolina must achieve a 77
percent cut in NOx emissions by 2009 and a 73 percent cut in SO2
emissions by 2013.  This legislation establishes annual caps on both SO2
and NOx emissions for the two primary utility companies in North
Carolina, Duke Energy and Progress Energy.  These reductions must be
made in North Carolina, and allowances are not saleable. 

Consent Agreements in the VISTAS region:  The impacts of the following
consent agreements in the VISTAS states were reflected in the emissions
inventory used for those states:

Santee Cooper: A 2004 consent agreement calls for Santee Cooper in South
Carolina to install and commence operation of continuous emission
control equipment for PM/SO2/NOx emissions; comply with system-wide
annual PM/SO2/NOx emissions limits; agree not to buy, sell or trade
SO2/NOx allowances allocated to Santee Cooper System as a result of said
agreement; and to comply with emission unit limits of said agreement.

TECO: Under a settlement agreement, by 2008, Tampa Electric in the state
of Florida will install permanent emissions control equipment to meet
stringent pollution limits; implement a series of interim
pollution-reduction measures to reduce emissions while the permanent
controls are designed and installed; and retire pollution emission
allowances that Tampa Electric or others could use, or sell to others,
to emit additional NOx, SO2 and PM.

VEPCO: Virginia Electric and Power Co. agreed to spend $1.2 billion
between by 2013 to eliminate 237,000 tons of SO2 and NOx emissions each
year from eight coal-fired electricity-generating plants in Virginia and
West Virginia.

Gulf Power 7: A 2002 agreement calls for Gulf Power to upgrade its
operation to cut NOx emission rates by 61 percent at its Crist 7
generating plant by 2007 with major reductions beginning in early 2005. 
The Crist plant is a significant source of nitrogen oxide emissions in
the Pensacola Florida area.

Non-EGU Point Source Controls Expected by 2018 

Control factors were applied to the 2018 MANE-VU inventory to represent
the following national, regional, and state control measures:

NOx SIP Call Phase I (NOx Budget Trading Program)

NOx SIP Call Phase II 

NOx RACT in 1-hour Ozone SIPs

NOx OTC 2001 Model Rule for ICI Boilers

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

Combustion Turbine and RICE MACT 

Industrial Boiler/Process Heater MACT 

EPA’s Refinery Enforcement Initiative

In addition, states provided specific control measure information about
specific sources or regulatory programs in their state.  MANE-VU used
the state-specific data to the extent it was available.

 

For other regions, MANE-VU used inventories developed by the RPOs for
those regions, including VISTAS Base G2, MRPO’s Base K, and CenRAP’s
emissions inventory.  (Emissions for CenRAP states in the MANE-VU
modeling domain were taken from the VISTAS Base G2 inventory.)  Non-EGU
source controls incorporated into the modeling include the following
consent agreements reflected in the VISTAS inventory:

Dupont: A 2007 agreement calls for E. I. Dupont Nemours & Company’s
James River plant to install dual absorption pollution control equipment
by September 1, 2009, resulting in emission reductions of approximately
1,000 tons SO2 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 with a wet scrubber
the SO2 emissions of the #8 Power Boiler.  This control device should
result in reductions of over 3,500 tons of SO2 in 2018.

Area Source Controls Expected by 2018 

For area sources within MANE-VU, Massachusetts relied on MANE-VU’s
Version 3.0 Emissions Inventory for 2002.  In general, the 2018
inventory for area sources was developed by MANE-VU applying growth and
control factors to the 2002 Version 3.0 inventory.  Area source control
factors were developed for the following national and regional control
measures:

OTC VOC Model Rules (Consumer products, architectural and industrial
maintenance coatings, portable fuel containers, mobile equipment repair
and refinishing, and solvent cleaning)

Federal On-board Vapor Recovery 

New Jersey Post-2002 Area Source Controls 

Residential Woodstove NSPS

The following additional control measures were included in the 2018
analysis to reduce VOC emissions for the following area source
categories for some states (as identified below):  

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

VOC measures: adhesives and sealants (all MANE-VU states except VT);

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

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

portable fuel containers (all MANE-VU states except VT).  

As noted above, the inventory information used for other regions was
obtained from those regions’ RPOs.

Onroad Mobile Source Controls Expected by 2018 

For the onroad mobile source emission inventory, Massachusetts relied on
MANE-VU’s Version 3.0 emissions inventory that included the following
emission control measures in MANE-VU states: 

Heavy Duty Diesel (2007) Engine Standard:  EPA set a PM emissions
standard for new heavy-duty engines of 0.01 grams per
brake-horsepower-hour (g/bhp-hr), to take full effect for diesel engines
in the 2007 model year.  This rule also includes standards for NOx and
non-methane hydrocarbons (NMHC) of 0.20 g/bhp-hr and 0.14 g/bhp-hr,
respectively.  These NOx and NMHC standards will be phased in together
between 2007 and 2010 for diesel engines.  Sulfur in diesel fuel must be
lowered to enable modern pollution-control technology to be effective on
these trucks and buses.  EPA will require a 97 percent reduction in the
sulfur content of highway diesel fuel from its current level of 500
parts per million (low-sulfur diesel, or LSD) to 15 parts per million
(ultra-low sulfur diesel, or ULSD).

Tier 2 Motor Vehicle Standards:  Tier 2 is a fleet averaging program,
modeled after the California LEV II standards.  Manufacturers can
produce vehicles with emissions ranging from relatively dirty to zero,
but the mix of vehicles a manufacturer sells each year must have average
NOx emissions below a specified value.  Tier 2 standards became
effective in the 2005 model year and are included in the assumptions
used for calculating mobile source emissions inventories used for 2018.

Large Spark Ignition and Recreational Vehicle Rule:  EPA has adopted new
standards for

emissions of NOx, hydrocarbons (HC), and carbon monoxide (CO) from
several groups of previously unregulated nonroad engines.  Included in
these are large industrial spark-ignition engines and recreational
vehicles.  Nonroad spark-ignition engines are those powered by gasoline,
liquid propane, or compressed natural gas rated over 19 kilowatts (kW)
(25 horsepower).  These engines are used in commercial and industrial
applications, including forklifts, electric generators, airport baggage
transport vehicles, and a variety of farm and construction applications.
 Nonroad recreational vehicles include snowmobiles, off-highway
motorcycles, and all terrain vehicles.  These rules were initially
effective in 2004 and were assumed to be fully phased-in by 2012.

Nonroad Sources Controls Expected by 2018 

Massachusetts used Version 3.0 of the MANE-VU 2002 Emissions Inventory. 
Since the NONROAD Model used to develop the nonroad source emissions did
not include aircraft, commercial marine, and locomotives, MANE-VU’s
contractor, MACTEC, developed the inventory for these categories. 
Nonroad mobile source emissions for the 2018 emission inventory were
calculated with EPA’s NONROAD2005 emissions model as incorporated in
the NMIM2005 (National Mobile Inventory Model) database.  The NONROAD
model accounts for the emissions benefits associated with Federal
non-road equipment emissions control measures such as the following:

 “Control of Air Pollution; Determination of Significance for Nonroad
Sources and Emissions Standards for New Nonroad Compression Ignition
Engines At or Above 37 Kilowatts,” 59 FR 31306, June 17, 1994.

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

“Control of Emissions From Nonroad Large Spark-Ignition Engines and
Recreational Engines (Marine and Land-Based); Final Rule,” 67 FR
68241, November 8, 2002.

“Control of Emissions of Air Pollution From Nonroad Diesel Engines and
Fuel; Final Rule,” April, 2004. This rule sets standards that will
reduce emissions by more than 90 percent from nonroad diesel equipment
and reduce sulfur levels by 99 percent from current levels in nonroad
diesel fuel starting in 2007.  This step will apply to most nonroad
diesel fuel in 2010 and to fuel used in locomotives and marine vessels
in 2012. 

As noted above, the inventory information used for other regions was
obtained from those regions’ RPOs.

Additional Controls Analyzed as Part of Ozone SIPs

Additional control measures were considered by several states as part of
ozone planning.  These control measures were included in the inventory
used for regional haze modeling analysis.  The states may or may not
have committed to adopting these measures in the ozone SIP.  For
specific states, the measures included in this analysis reduce emissions
for the following pollutants and non-EGU point source categories due to
strategies developed for purposes of reducing ozone in the Ozone
Transport Region (OTR):

NOx measures: 

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

Cement kilns in ME, MD, NY, PA 

Glass and fiberglass furnaces in MD, MA, NJ, NY, PA 

VOC measure: adhesives and sealants application (all MANE-VU states
except NJ and VT) 

These measures were included in the “Beyond on the Way” inventory
for the states identified.

The following additional control measures were included in the 2018
analysis to reduce VOC emissions for the following area source
categories for some states (as identified below):

NOx measures (natural gas, No. 2 fuel oil, No. 4 and 6 fuel oil, and
coal) (Only CT, NJ, and NY)

VOC measures: adhesives and sealants (except VT) 

emulsified and cutback asphalt paving (except ME and VT) 

consumer products (except VT) 

portable fuel containers (except VT)  

Additional Reasonable Strategies

In developing reasonable progress goals as required by 40 CFR
51.308(d)(1), Massachusetts and the MANE-VU states identified specific
emission control measures - beyond those which individual states or RPOs
have already made commitments to implement - that would be reasonable to
undertake as part of a concerted strategy to mitigate regional haze. 
The proposed additional control measures were incorporated into the
regional strategy adopted by MANE-VU on June 20, 2007, to meet the
reasonable progress goals established by the Class I states.  The basic
elements of this strategy are described in the MANE-VU “Ask” (see
below).  States targeted for coordinated actions toward achieving these
goals include all of the MANE-VU states plus Georgia, Illinois, Indiana,
Kentucky, Michigan, North Carolina, Ohio, South Carolina, Tennessee,
Virginia and West Virginia.

In addition to proposed emission controls in the U.S., the MANE-VU Class
I states determined that it was reasonable to include anticipated
emission reductions in Canada in the modeling used to set reasonable
progress goals.  This determination was based on evaluations conducted
before and during the consultation process.  Specifically, the modeling
accounts for six coal-burning EGUs in Canada having a combined output of
6,500 MW that are scheduled to be shut down and replaced by nine natural
gas turbine units with selective catalytic reduction (SCR) by 2018.

Rationale for Determining Reasonable Controls

40 CFR 51.308(d)(1)(i)(A) requires that, in establishing reasonable
progress goals for each Class I area, the State must consider the costs
of compliance, the time necessary for compliance, the energy and non-air
quality environmental impacts of compliance, and the remaining useful
life of any potentially affected sources.  The SIP must include a
demonstration showing how these factors were taken into consideration in
setting the reasonable progress goals.  These factors are sometimes
termed the “four statutory factors,” since their consideration is
required by the Clean Air Act.

Focus on SO2:   MANE-VU conducted a Contribution Assessment (Appendix A)
and developed a conceptual model that indicated particulate sulfate
formed from emissions of SO2 was the dominant contributor to visibility
impairment at all sites and during all seasons in the base year.  While
other pollutants, including organic carbon and NOx, will need to be
addressed in order to achieve the national visibility goals, MANE-VU’s
contribution assessment suggested that an early emphasis on SO2 will
yield the greatest near-term benefit.  Therefore, it is reasonable to
conclude that the additional measures considered in establishing
reasonable progress goals require reductions in SO2 emissions. 

Contributing Sources:  The MANE-VU Contribution Assessment indicates
that emissions in 2002 from within the MANE-VU region were responsible
for about 25 to 30 percent of the sulfate at MANE-VU Class I areas. 
Sources in the Midwest and Southeast regions were responsible for about
15 to 25 percent each, respectively.  Point sources dominated the
inventory of SO2 emissions.  Therefore, the MANE-VU’s long-term
strategy includes additional measures to control sources of SO2 both
within the MANE-VU region and in other states that were determined to
contribute to regional haze at MANE-VU Class I areas. 

The Contribution Assessment documented the source categories most
responsible for visibility degradation at MANE-VU Class I areas.  As
described earlier, there was a collaborative effort between the Ozone
Transport Commission and MANE-VU to evaluate a large number of potential
control measures.  Several measures that would reduce SO2 emissions were
identified for further study. 

These efforts led MANE-VU to prepare the report entitled, “Assessment
of Reasonable Progress for Regional Haze in MANE-VU Class I Areas”
MACTEC, July 9, 2007 otherwise known as the Reasonable Progress Report
(Appendix T), which documented an analysis of the four statutory factors
for five major source categories.  Table 24 summarizes the results of
MANE-VU’s Reasonable Progress Report, which considered EGUs, ICI
boilers, cement kilns, heating oil and residential wood combustion.

The MANE-VU states reviewed the four-factor analysis presented in the
Reasonable Progress Report, consulted with each other about the
measures, and concluded by adopting the statements known as the MANE-VU
“Ask” on June 20, 2007.  These statements identify the control
measures that would be pursued toward improving visibility in the region
and that were included in the modeling used to establish reasonable
progress goals.

Table   SEQ Table \* ARABIC  24 : Summary of Results from the
Four-Factor Analysis

Source Category	Primary Regional Haze Pollutant	Control Measure(s)
Average Cost in 2006 dollars (per ton of pollutant reduction)	Compliance
Timeframe	Energy and Non-Air Quality Environmental Impacts	Remaining
Useful Life

Electric Generating Units 	SO2	Switch to a low sulfur coal (generally
<1% sulfur), switch to natural gas (virtually 0% sulfur), coal cleaning,


Flue Gas Desulfurization (FGD): Wet, Spray Dry, or Dry.	IPM®* v.2.1.9
predicts $775-$1,690. $170-$5,700 based on available literature

*Integrated Planning Model®	2-3 years following SIP submittal	Fuel
supply issues, potential permitting issues, reduction in electricity
production capacity, wastewater issues	50 years or more

Industrial, Commercial, Institutional Boilers	SO2	Switch to a low sulfur
coal (generally <1% sulfur), switch to natural gas (virtually 0%
sulfur), switch to a lower sulfur oil, coal cleaning, combustion
control, Flue Gas Desulfurization (FGD): Wet, Spray Dry, or Dry.
$130-$11,000 based on available literature. Depends on size.	2-3 years
following SIP submittal	Fuel supply issues, potential permitting issues,
control device energy requirements, wastewater issues	10-30 years

Cement and Lime Kilns	SO2	Fuel switching, Dry Flue Gas Desulfurization:
Spray Dryer Absorption (FGD), Wet Flue Gas Desulfurization (FGD),
Advanced Flue Gas Desulfurization (FGD).	$1,900-$73,000 based on
available literature. Depends on size.	2-3 years following SIP submittal
Control device energy requirements, wastewater issues	10-30 years

Heating Oil	SO2	Lower the sulfur content in the fuel. Depends on the
state.	$550-$750 based on available literature.  There is a high
uncertainty associated with this cost estimate.	Currently feasible.
Capacity issues may influence timeframe for implementation of new fuel
standards	Increases in furnace/boiler efficiency, decreased
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, accelerated
changeover inducement.	$0-$10,000 based on available literature	Several
years -dependent on mechanism for emission reduction 	Reduce greenhouse
gas emissions, increase efficiency of combustion device	10-15 years

	

MANE-VU Statement of June 20, 2007

The reasonable progress goals adopted by the MANE-VU Class I states
represent implementation of the regional course of action set forth by
MANE-VU on June 20, 2007 entitled “Statement of the
Mid-Atlantic/Northeast Visibility union (MANE-VU) Concerning a Course of
Action within MANE-VU toward Assuring Reasonable Progress.” As such,
these reasonable progress goals are intended to reflect the pursuit by
MANE-VU states of a course of action including pursuing the adoption and
implementation of the following “emission management” strategies, as
appropriate and necessary:

Timely implementation of BART requirements; and

A low sulfur fuel oil strategy in the inner zone states (New Jersey, New
York, Delaware, and Pennsylvania, or portions thereof) to reduce the
sulfur content of: 

Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later
than 2012,

#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, and

Further reduce the sulfur content of distillate oil to 15 ppm by 2016;
and

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

Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later
than 2014,

#4 residual oil to 0.25 percent-0.50 percent sulfur by weight by no
later than 2018,

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

Further reduce the sulfur content of distillate oil to 15 ppm by 2018
depending on supply and availability; and

A 90 percent or greater reduction in SO2 emissions from each of the 167
EGU stacks identified by MANE-VU as reasonably anticipated to cause or
contribute to impairment of visibility in each mandatory Class I Federal
area in the MANE-VU region.  If it is infeasible to achieve that level
of reduction from a unit, alternative measures will be pursued in such
State; and

Continued evaluation of other control measures including energy
efficiency, alternative clean fuels, and other measures to reduce SO2
and NOx emissions from all coal-burning facilities by 2018 and new
source performance standards for wood combustion.  

This long-term strategy to reduce and prevent regional haze will lead
each state to pursue adoption and implementation of reasonable and
cost-effective NOx and SO2 control measures as appropriate and
necessary.  While some measures that states pursue may not represent
enforceable commitments immediately, they may become enforceable in the
future as new laws are passed, rules are written, and facility permits
are issued.  Massachusetts will provide an update on the implementation
of the strategies listed in the “Ask” in the 2013 mid-term review.

This suite of additional control measures are those that the MANE-VU
states have agreed to pursue for the purpose of mitigating regional
haze.  The corollary is that the MANE-VU Class I states (Maine, New
Hampshire, Vermont, and New Jersey) asked states outside of the MANE-VU
region that contribute to visibility impairment inside the region to
pursue similar measures.  The control measures that non-MANE-VU states
choose to pursue may be directed 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.  

Best Available Retrofit Technology

Implementation of the BART provisions of the Regional Haze Rule [40 CFR
51.308(e)] is one of the reasonable strategies included in this SIP. 
BART controls in Massachusetts are described in Section 8 of this SIP.  

Additional emission reductions will occur at many other BART-eligible
facilities within MANE-VU as a result of controls achieved by other
programs that serve as BART but are not  specifically identified as such
(e.g., RACT control measures).  While not specifically identified as
being attributable to BART, these additional emission reductions were
fully accounted for in the 2018 CMAQ modeling.

Additional visibility benefits are likely to result from installation of
new emission controls at BART-eligible facilities located in neighboring
RPOs.  However, the MANE-VU modeling

did not account for BART controls in other RPOs and, consequently, did
not include visibility

improvements at MANE-VU Class I Areas that would be likely to accrue
from such measures.

Low-Sulfur Fuel Oil Strategy

The important assumption underlying MANE-VU’s low-sulfur fuel oil
strategy is based on the production and use of home heating and fuel
oils that contain 50% less sulfur for the heavier grades (#4 and #6
residual), and a minimum of 75% and a maximum of 99.25% less sulfur in
#2 fuel oil (also known as home heating oil, distillate, or diesel fuel)
at an acceptably small increase in price to the end user.  As much as
three-fourths of the total sulfur reductions achieved by this strategy
come from using the low-sulfur #2 distillate for space heating in the
residential and commercial sectors.  The costs of these emission
reductions are estimated at $550 to $750 per ton, as documented in the
MANE-VU Reasonable Progress Report.  In some seasons and some locations,
low-sulfur diesel is actually cheaper than regular diesel fuel. 
NESCAUM’s report, “Low Sulfur Heating Oil in the Northeast States:
An Overview of Benefits, Costs, and Implementation Issues,” December
2005 (Appendix Y) notes that the incremental cost of low-sulfur (500
ppm) highway diesel fuel has averaged 1.5 cents per gallon more than the
cost of heating oil over the past decade.  However, any increased cost
would be more than offset by the avoided maintenance costs resulting
from the reduced rate of equipment fouling when using low-sulfur oil.  

A recent study developed for the National Oilheat Research Alliance
(NORA) uses data from the U.S. Energy Information Administration to
evaluate the potential for suppliers to bring 15 ppm sulfur content
heating oil into widespread use in the Northeast by 2018.  While the
study acknowledges that additional refining capacity is needed to meet
the increased demand in 2018 and beyond, it concludes that, given
appropriate advance notice, the refining industry can supply the
necessary fuels with minimal market disruptions and price impacts.  In
the short-term, excess production capacity of ultra-low sulfur diesel
(ULSD) exists in the region.  In the longer term, the transition to ULSD
in the transportation sector, combined with clear signals from
regulatory agencies that similar requirements will be widespread for
heating oil in the coming years, will support a move toward greater
availability of 15 ppm sulfur content heating oil.  

The study projects a wholesale price differential between ULSD and
higher sulfur heating oil of 1-3 cents per gallon, suggesting that the
incremental cost of providing 15 ppm sulfur content heating oil will not
be significant compared to normal price fluctuations.  The study also
notes that the incremental cost to consumers will be more than offset by
cost savings associated with lower maintenance costs and higher fuel
efficiency.  For example, a typical consumer who uses 800 gallons of
fuel per year would spend an additional $24 per year if per-gallon fuel
costs increased by $0.03.  However, the same consumer could expect to
save approximately $50 per year in avoided maintenance costs (cleaner
fuel reduces the frequency with which equipment must be serviced) and
another $50 in avoided fuel costs from higher efficiency.  This is
because existing equipment generally operates more efficiently with
lower sulfur fuels, so less fuel is required to produce the same amount
of heat; even larger efficiency gains are possible using newer furnaces
specifically designed to use lower sulfur fuels.

 in the Northeast, lower sulfur No. 6 residual oil (≤ 1%) ranged from
8.9 to 12.9 cents per gallon more than higher sulfur No. 6 residual oil
(> 1%).  The additional expense would be at least partially offset by
reduced maintenance costs with the use of lower sulfur oil.  Low sulfur
oil is cleaner burning and emits less particulate matter than higher
sulfur oil; this reduces the rate of fouling of heating units
substantially and permits longer time intervals between cleanings.  The
decreased deposits also would enable a more efficient transfer of heat,
thereby reducing fuel use. Thus, there are potential costs savings for
switching to lower sulfur residual oil.  Reducing the sulfur content of
residual fuel is a cost-effective SO2 reduction strategy; a simple
calculation using a price differential of $0.089 – $0.129 suggests
that a 78% reduction in SO2 emissions (by converting from 2.2 percent to
0.5 percent sulfur residual oil) is achievable at an approximate cost of
$800 - $1,100 per ton of SO2 removed.  This cost per ton removal
compares favorably to the costs of other pollution controls typically
required by environmental agencies and is well within the range
considered to be cost-effective for SO2 reductions.

While the costs of the low-sulfur oil strategy will vary depending on
market conditions, they are reasonable when compared to the costs of
controlling other sectors.  Importantly, a January 2008 Public Health
Benefits study prepared by NESCAUM shows that the low-sulfur fuel
strategy will result in billions of dollars in public health benefits
for the region (see Appendix AA).  Controlling the fuel-sulfur content
to 500 ppm leads to health benefits of almost 3.4 billion dollars in
MANE-VU and controlling the fuel-sulfur content to 15 ppm could lead to
an additional 431 million dollars in benefits, bringing the total
benefits to 3.7 billion dollars.

The MANE-VU states agreed through consultations to pursue a low-sulfur
fuel oil strategy within the region.  The MANE-VU low-sulfur fuel
strategy will be implemented in two phases; however, both components of
the strategy are to be fully implemented by 2018.  The first phase of
the MANE-VU low-sulfur fuel strategy requires the lowering of fuel
sulfur content in distillate (#1 and #2 oil) from current levels that
range between 2,000 and 2,300 ppm down to 500 ppm.  The second phase of
the strategy further reduces the fuel-sulfur content of the distillate
fraction to 15 ppm sulfur.  It also requires the lowering of sulfur
content in residual oil to 0.5 percent sulfur by weight.

The two phases of the MANE-VU low-sulfur fuel strategy are to be
implemented in sequence with slightly different timing for an “inner
zone” and the remainder of MANE-VU.  All MANE-VU states have agreed
that a low-sulfur oil strategy is reasonable to pursue by 2018 as
appropriate and necessary. 

Based on the fuel sulfur limits within the first phase of the strategy,
MANE-VU estimated a decrease of 140,000 tons of SO2 emitted from
distillate combustion and a decrease of 40,000 tons of SO2 from residual
combustion in MANE-VU.  In the second phase in which distillate fuel
sulfur limits are lowered from 500 ppm to 15 ppm, MANE-VU estimated an
additional reduction of 27,000 tons of SO2 emissions in MANE-VU in 2018.


Figure 40 shows the combined impact of both phases of the MANE-VU
low-sulfur fuel strategy relative to the On The Books/On The Way
baseline.  NESCAUM used the concentration changes illustrated in Figure
40 to estimate the visibility benefits for this strategy.  Because the
fuel sulfur program only affects sources within MANE-VU, that region
sees the largest PM2.5 reduction and the greatest visibility benefits.

In July 2012, Massachusetts adopted amendments to 310 CMR 7.05: Fuels
All Districts to implement the MANE-VU Strategy (Appendix II).



Figure   SEQ Figure \* ARABIC  40 : Average Change in 24-hr PM2.5 Due to
Low Sulfur Fuel Strategies Relative to OTB/OTW (g/m3)

Targeted EGU Strategy

SO2 emissions from power plants (electric generating units or EGUs) are
the single largest sector contributing to the visibility impairment
experienced in the Northeast’s Class I areas.  The SO2 emissions from
power plants continue to dominate the inventory.  Sulfate formed through
atmospheric processes from SO2 emissions are responsible for over half
the mass and approximately 70-80 percent of the light extinction on the
worst visibility days (Contribution Assessment, Appendix   REF
_Ref191968764 \r \h  \* MERGEFORMAT  A ).  

In order to properly target controls on EGUs, modeling was conducted to
identify those EGUs with the greatest impact on visibility in MANE-VU. 
A list was developed that includes the 100 largest impacts at each
MANE-VU Class I site during 2002.  These emissions were from 167 EGU
stacks and are illustrated below (a complete list can be found in
Appendix   REF _Ref197835294 \r \h  \* MERGEFORMAT  W ; see Appendix A).
 Some of the stacks identified as important were outside the states
identified as contributing at least 2 percent of the sulfate at MANE-VU
Class I areas and were dropped from the list.  Massachusetts sources
identified in the list include Brayton Point, Canal Station, Mount Tom,
Salem Harbor, and Somerset Station.  Given the magnitude of their
potential impact, controlling emissions from these stacks is important
to improving visibility at MANE-VU Class I areas. 

MANE-VU’s agreed to regional approach for the EGU sector is to pursue
a 90 percent reduction in SO2 emissions (from 2002 emissions) from these
167 targeted stacks by 2018 as appropriate and necessary.  MANE-VU
concluded that pursuing this level of sulfur reduction is both
reasonable and cost-effective.  Even though current wet scrubber
technology can achieve sulfur reductions greater than 95 percent,
historically a 90 percent sulfur reduction level includes lower average
reductions from dry scrubbing technology.  The cost for SO2 emissions
reductions will vary by unit, and the MANE-VU Reasonable Progress report
(Appendix T) summarizes the various control methods and costs available,
ranging from $170 to $5,700 per ton, depending on site-specific factors
such as the size and type of unit, combustion technology, and type of
fuel used.

  

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

To evaluate the impact of reducing emissions from the 167 EGU stacks,
NESCAUM used CMAQ to model sulfate concentrations in 2018 after
implementation of this control program.  2018 SO2 emissions for these
stacks were modeled at levels equal to 10 percent of their 2002 SO2
emissions; sulfate concentrations were then converted to PM2.5
concentrations.  This preliminary modeling showed that requiring SO2
emissions from the 167 EGU stacks to be reduced by 90 percent from 2002
emission levels could reduce 24-hour PM2.5 concentrations.  Figure 43
shows the reduction in fine particle pollution in the Eastern U.S. that
would result from implementing the targeted EGU SO2 strategy.
Improvements in PM2.5 concentrations would occur throughout the MANE-VU
region as well as for portions of the VISTAS and Midwest RPO regions,
especially the Ohio River Valley.

Figure   SEQ Figure \* ARABIC  42 : Average Change in 24-hr PM2.5 due to
90 Percent Reduction in SO2 Emissions from 167 EGU Stacks Affecting
MANE-VU

Although the reductions are potentially large, MANE-VU determined, after
consultation with affected states, that it was unreasonable to expect
that the full 90-percent reduction in SO2 emissions would be achieved by
2018.  Therefore, additional modeling was conducted to assess the more
realistic scenario in which emissions would be controlled by the
individual facilities and/or states to levels already projected to take
place by that date.  At some facilities, the actual emission reductions
are anticipated to be greater or less than the 90 percent benchmark. 
For details, see Appendix   REF _Ref197835294 \r \h  W  “Documentation
of 2018 Emissions from Electric Generating Units in the Eastern United
States for MANE-VU’s Regional Haze Modeling.”

Massachusetts has five sources (Table 25) with a total of 10 EGUs on the
167 Stacks list, including Brayton Point (Units 1-3), Canal Station
(Units 1-2), Mt. Tom Station (Unit 1), Salem Harbor (Units 1, 3, 4), and
Somerset Power (Unit 8).  Each of these facilities is subject to
MassDEP’s 310 CMR 7.29, which limits SO2 emissions facility-wide.  

Several of the Massachusetts EGUs already have installed SO2 controls or
are planning additional SO2 controls to help them meet 310 CMR 7.29
limits.  Brayton Point has installed spray dryer absorbers on Units 1
and 2 and plans to operate a dry scrubber on Unit 3 in 2013; Mt. Tom
Station has installed a dry scrubber.  Salem Harbor is currently using
lower sulfur coal and oil to meet its 310 CMR 7.29 limits (Unit 4 is
subject to MassDEP’s amended 310 CMR 7.05 sulfur in fuels regulation)
and plans to shut down all units by June 2014.  Somerset Power shut down
in 2010.  Canal Station is using lower sulfur oil to comply with 310 CMR
7.29, and is subject to MassDEP’s amended 310 CMR 7.05 sulfur in fuels
regulation.

Table 25 shows that SO2 emissions were reduced by 72% from 2002 to 2011
at the targeted units.  Additional reductions will occur in the 2012-14
timeframe as the Salem Harbor units retire and the Brayton Point Unit 3
scrubber becomes operational.   

MassDEP believes that there will be further emissions reductions at the
targeted units as a result of EPA’s recently issued Mercury and Air
Toxics Standards (MATS) rule. MATS gives coal units with scrubbers a
compliance option to meet an SO2 emissions rate of 0.2 lbs/MMBtu as an
alternative to a hydrogen chloride emissions rate, which is more
stringent than MassDEP’s 310 CMR 7.29 annual SO2 emissions rate (3.0
lbs/MWh, which is roughly equivalent to 0.3 lbs/MMBtu).  Brayton Point
and Mt. Tom Station may choose this option for their coal units, thereby
further reducing their permitted SO2 emissions.  

To be subject to MATS in a given year, an EGU must fire coal or oil for
more than 10 percent of the average annual heat input during the 3
previous consecutive calendar years, or for more than 15 percent of the
annual heat input during any one of the 3 previous calendar years.  This
provision provides an incentive to Canal Unit 2, which can burn oil or
natural gas, to limit the amount of oil it burns so that it is not
subject to MATS, which would result in future SO2 emissions continuing
to be lower than permitted emissions.  MATS also establishes work
practices (versus emissions rates) for oil-fired units with an annual
capacity factor of less than 8% of its maximum heat input.  Canal
Station Unit 1’s utilization was 1% in 2011, and thus has an incentive
to remain below 8%, which would result in future SO2 emissions
continuing to be lower than its permitted emissions.  Even without MATS,
oil-fired combustion at Canal Units 1 and 2 is expected to be low well
into the future because of the high cost of oil relative to natural gas.
 This cost differential is why Canal’s utilization currently is very
low.

In addition, EPA’s 1-hour SO2 National Ambient Air Quality Standards
(NAAQS) may require MassDEP to establish new SO2 emission rates that are
more stringent than 310 CMR 7.29 for Brayton Point, Mt. Tom Station, and
Canal Station, as well as to establish emission rates for other large
emitters of SO2.  MassDEP will be working with facilities to determine
whether their potential emissions could result in exceedances of the
1-hour SO2 NAAQS, and to develop permit conditions where necessary to
limit SO2 emissions in order to meet the NAAQS.

Taking into account 310 CMR 7.29 SO2 emission rates, permit restrictions
and retirements, and MassDEP’s amended 310 CMR 7.05 sulfur in fuels
regulation, MassDEP conservatively projects SO2 emissions in 2018 would
represent at least a 67% reduction in SO2 emissions compared to 2002
emissions (see Table 25).  However, taking into account EPA’s MATS,
including the SO2 compliance option and incentives for low utilization
of oil-fired units, MassDEP believes there is a likelihood that SO2
emissions in 2018 will be up to 87% lower than 2002 emissions (see Table
25).  Therefore, MassDEP believes that existing regulatory programs will
lead to SO2 emission reductions that fulfill the MANE-VU Targeted EGU
Strategy for Massachusetts.  MassDEP will review emissions and
individual facility MATS compliance strategies in a mid-course planning
review in 2013, and if emissions reductions are not projected to be
close to 90%, MassDEP will assess whether other equivalent SO2 reduction
strategies may be necessary.  

Table   SEQ Table \* ARABIC  25 : Massachusetts Targeted EGUs

Facility	Unit	2002 SO2 Emissions	2011 SO2 Emissions	2018 Projected SO2
Emissions (Conservative)	2018 Projected SO2 Emissions (Likely)	2018
Projected SO2 Emissions (90% Target) 

Brayton Point 	1	9,254	               4,298 	2,928	                  
1,700 	                      925 

Brayton Point 	2	8,853	               3,535 	2,783	                  
1,590 	                      885 

Brayton Point 	3	19,450	             10,769 	6,442	                  
3,634 	                  1,945 

Canal Station	1	13,066	                   99 	7,643	                  
1,069 	                  1,307 

Canal Station 	2	8,948	                     29 	5,443	                  
1,479 	                      895 

Mt Tom 	1	5,282	                   129 	1,571	                   1,033 	
                     528 

Salem Harbor 	1	3,425	               893 	0	0	                      343 

Salem Harbor 	3	4,999	               2,344 	0	0	                     
500 

Salem Harbor 	4	2,886	                     69 	0	0	                     
289 

Somerset 	8	4,399	0	0	0	                      440 

Total	 	80,562	             22,165 	                      26,811 	     
          10,505 	                  8,057 

Reduction

	59,396	53,751	70,057	72,505

Percent Reduction

	72%	67%	87%	90%



It should be noted that even the conservative projection of a 67%
reduction in SO2 emissions from the targeted EGUs is more than enough to
meet the level of SO2 emissions projected from Massachusetts EGUs that
was used in the MANE-VU 2018 regional modeling, as documented in
NESCAUM’s 2018 Visibility Projections (Appendix G).  Emission results
from the 2018 Inter-Regional Planning Organization CAIR Case Integrated
Planning Model v. 2.1.9 estimated 17,486 tons of SO2 emissions for
Massachusetts (See Appendix W, Table 1).  However, MANE-VU planners
recognized that CAIR allows emissions trading, and that reductions at
one unit could offset increases at another unit within the CAIR region. 
Because most states do not restrict trading, MANE-VU decided that
projected emissions should be increased to represent the implementation
of the strategy for the 167 stacks within the limits of the CAIR
program, and therefore increased the projected emissions from states
subject to the CAIR cap and trade program.  For Massachusetts, this
modification resulted in projected SO2 emissions of 45,941 tons for
Massachusetts (see Appendix W, Table 9), effectively doubling
Massachusetts’ SO2 emissions inventory for EGUs.  As shown in Table
25, MassDEP’s conservative 67% reduction projection for targeted EGUs
results in 2018 emissions of 26,811 tons of SO2, well below the 45,941
tons of SO2 that is needed to meet the modeled 2018 reasonable progress
goals for the Class I areas Massachusetts affects.  

Other State EGU Programs Assumed in 2018 EGU Modeling 

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

Maryland Healthy Air Act: Maryland adopted the following requirements
governing EGU emissions:

For NOx:

Phase I (2009): Sets unit-specific annual caps (totaling 20,216 tons)
and ozone season caps (totaling 8,900 tons).

Phase II (2012): Sets unit-specific annual caps (totaling 16,667 tons)
and ozone season caps (totaling 7,337 tons).

For SO2:

Phase I (2010): Sets unit-specific annual caps (totaling 48,818 tons).

Phase II (2013): Sets unit-specific annual caps (totaling 37,235 tons).

For mercury:

Phase I (2010): 12-month rolling average of a minimum of 80% removal
efficiency.

Phase II (2013): 12-month rolling average of a minimum of 90% removal
efficiency.

The specific EGUs covered are: Brandon Shores (Units 1 and 2), C.P.Crane
(Units 1 and 2), Chalk Point (Units 1, and 2), Dickerson (Units 1, 2,
and 3), H.A. Wagner (Units 2 and 3) Morgantown (Units 1 and 2) and R.
Paul Smith (Units 3 and 4).  No out-of-state trading, no inter-company
trading, and no banking from year to year is permitted. 

New Hampshire EGU Regulations: New Hampshire adopted the following
regulations governing EGU emissions: Chapter Env-A 2900 requires the
installation of scrubbers on Merrimack Station (Units 1 and 2) by July
1, 2013 to control SO2 and mercury emissions with state-level SO2
credits for over- or early- compliance.

New Jersey Hg MACT Rule: All coal-fired EGUs must have a mercury removal
efficiency of 90%.

Consent Agreements in the VISTAS region:  The impacts of the additional
following consent agreements in the VISTAS states were reflected in the
emissions inventory used for those states:

EKPC: A July 2, 2007 consent agreement between EPA and East Kentucky
Power Cooperative requires the utility to reduce its emissions of SO2 by
54,000 tons per year and its emissions of NOx by 8,000 tons per year by
installing and operating selective catalytic reduction (SCR) technology,
low-NOx burners, and PM and mercury Continuous Emissions Monitors at the
utility’s Spurlock, Dale and Cooper Plants.  According to EPA, total
emissions from the plants will decrease between 50 and 75 percent from
2005 levels.  As with all federal consent decrees, EKPC is precluded
from using reductions required under other programs, such as CAIR, to
meet the reduction requirements of the consent decree.  EKPC is expected
to spend $654 million to install pollution controls.

AEP: American Electric Power agreed to spend $4.6 billion dollars to
eliminate 72,000 tons of NOx emissions each year by 2016 and 174,000
tons of SO2 emissions each year by 2018 from sixteen plants located in
Indiana, Kentucky, Ohio, Virginia, and West Virginia.

Source Retirement and Replacement Schedules  

40 CFR Section 51.308(d)(3)(v)(D) requires Massachusetts to consider
source retirement and replacement schedules in developing reasonable
progress goals.  Source retirement and replacement were considered in
developing the 2018 emissions inventory described in Appendix   REF
_Ref191969187 \r  \* MERGEFORMAT  N , Appendix B-5.  

Measures to Mitigate the Impacts of Construction Activities

40 CFR Section 51.308(d)(3)(v)(B) requires States to consider measures
to mitigate the impacts of construction activities.  A description of
MANE-VU’s consideration of measures to mitigate the impacts of
construction can be found in the MANE-VU document entitled, Technical
Support Document on Measures to Mitigate the Visibility Impacts of
Construction Activities in the MANE-VU Region (Appendix X).  The
following statements summarize the main points of this technical support
document:

Although a temporary source, fugitive dust and diesel emissions from
construction activities can affect local air quality.

While construction activities are responsible for a relatively large
fraction of direct PM2.5 and PM10 emissions in the region, the
contribution of construction activities to reduced visibility is much
smaller because dust settles out of the air relatively close to the
sources.

Ambient air quality data shows that soil dust makes up only a minor
fraction of the PM2.5 measured in MANE-VU Class I areas.  Furthermore,
the impacts of diesel emissions in these rural areas are a small part of
the total PM2.5.

The use of measures such as clean fuels, retrofit technology, best
available technology, specialized permits, and truck staging areas (to
limit the adverse impacts of idling) can help decrease the effects of
diesel emissions on local air quality.

MANE-VU states have rules in place to mitigate potential impacts of
construction activities on visibility in Class I areas.

MassDEP requires contractors working on certain state-financed projects
to install retrofit pollution controls in their construction equipment
engines.  In addition, Massachusetts regulation 310 CMR 7.09 regulates
dust from construction and demolition activities. 7.09(3) states, “No
person responsible for an area where construction or demolition has
taken place shall cause, suffer, allow, or permit particulate emissions
therefrom to cause or contribute to a condition of air pollution…” 
Furthermore, the construction or demolition of large buildings requires
a written notification to MassDEP ten working days prior to operations. 
Due to the lower visibility impact of particulate matter from
Massachusetts at Class I areas (relative to SO2 and NOx emissions),
MassDEP concludes that its regulations are currently sufficient to
mitigate the impacts of construction activities.

Agricultural and Forestry Smoke Management

40 CFR Section 51.308(d)(3)(v)(E) requires States to consider smoke
management techniques for the purposes of agricultural and forestry
management.  A description of MANE-VU’s analysis of smoke management
in the context of Regional Haze SIPs can be found in the MANE-VU Smoke
Management TSD entitled, “Technical Support Document on Agricultural
and Forestry Smoke Management in the MANE-VU Region” (Appendix Q).

This technical support document concluded that Smoke Management Programs
(SMPs) are only required when smoke impacts from fires managed for
resource benefits contribute significantly to regional haze. 
Massachusetts does not currently have a smoke management program.  The
results of the emissions inventory indicate that emissions from
agricultural, managed, and prescribed burning are very minor source
categories (totaling 1.34% of PM2.5 emissions in the MANE-VU region). 
Source apportionment results show that wood smoke is a moderate
contributor to visibility impairment at some Class I areas in the
MANE-VU region; however, smoke is not an especially important
contributor to MANE-VU Class I areas on either the 20% best or 20% worst
visibility days.  Most of the wood smoke is attributable to residential
wood combustion and it is unlikely that fires for agricultural or
forestry management cause large impacts on visibility in any of the
Class I areas in the MANE-VU region.  On rare occasions, smoke from
major fires degrades the air quality and visibility in the MANE-VU area.
However, these fires are generally unwanted wildfires that are not
subject to SMPs. 

MassDEP’s air regulations include 310 CMR 7.00, which bans open
burning entirely in 22 urban municipalities and prohibits the use of
open burning to clear commercial or institutional land for
non-agricultural purposes.  Burning for “activities associated with
the normal pursuit of agriculture” and the open burning of brush and
debris between January 14 and April 30, “except during periods of
adverse meteorological conditions,” are currently allowed.  Prescribed
burning also is allowed under 310 CMR 7.07(3)(f) upon specific
permission from MassDEP.  Massachusetts considers these efforts to be
sufficient to protect visibility in the Class I areas affected by
emissions from Massachusetts sources, including agricultural and
forestry smoke.

Regulation of Outdoor Hydronic Heaters

On December 26, 2008, MassDEP finalized new regulations, 310 CMR
7.26(50) through (54), to control emissions from outdoor hydronic
heaters (OHHs, also known as outdoor wood-fired boilers or OWBs), which
are included in Appendix CC as part of this SIP.  The regulations are
based in part on a NESCAUM model rule developed in January 2007 and have
requirements for manufacturers, sellers, and owners of OHHs. 
Manufacturers must meet stringent performance standards in order to sell
OHHs in Massachusetts.  The Phase I emission standard is 0.44 lb/MMBtu
for units sold after October 1, 2008, and the Phase II emission standard
is 0.32 lb/MMBtu for units sold after March 31, 2010.  Owners of current
and new OHHs are subject to regulations regarding the operation of their
OHHs. Massachusetts concludes that adoption of these proposed
regulations will reduce future smoke and particulate emissions from
OHHs.

Estimated Impacts of Long-Term Strategy on Visibility

Preliminary modeling was conducted to estimate the impact of various
elements of the MANE-VU “Ask.”  This modeling is described in
NESCAUM’s report entitled MANE-VU Modeling for Reasonable Progress
Goals (Appendix   REF _Ref201032634 \r \h  \* MERGEFORMAT  F ).  NESCAUM
also conducted additional revised modeling to assess combined impacts. 
This modeling is described in NESCAUM’s report entitled 2018
Visibility Projections (Appendix   REF _Ref201032635 \r \h  \*
MERGEFORMAT  G ).  The following information about the effects of
specific strategies is taken from those reports.  As with all modeling,
emissions estimates and modeling results for 2018 entail uncertainty,
and further evaluation may be conducted as part of the progress report
required in five years under 40 CFR Section 51.308(g).

Additional Measures Included in Best and Final Modeling

In addition to the measures described in Section 10.5 (BART controls
within MANE-VU, low-sulfur fuel within MANE-VU, and controls on specific
EGUs), MANE-VU asked neighboring RPOs to consider further non-EGU
emissions reductions comparable to those achieved through MANE-VU’s
low-sulfur fuel strategies.  Prior modeling indicated that the MANE-VU
low-sulfur fuel strategy is expected to achieve a greater than 28
percent reduction in non-EGU SO2 emissions in 2018.  After consultation
with other states and consideration of comments received, the MANE-VU
Class I states decided that the Best and Final modeling would include
implementation of measures to match MANE-VU’s 28 percent reduction in
non-EGU SO2 emissions in the VISTAS and MRPO regions.  In order to model
the impact of this strategy on visibility at MANE-VU Class I areas,
additional emissions reductions in the VISTAS and MRPO states were
assumed to occur, resulting in a modeled 28 percent reduction in non-EGU
SO2 emissions in those regions.  These reductions include:

For both Southeast and Midwest States:

	Coal-Fired ICI Boilers: emissions were reduced by 60 percent

	Oil-Fired ICI boilers: emissions were reduced by 75 percent

	ICI Boilers lacking fuel specification: emissions were reduced by 50
percent

Additional controls only in the Southeast States:

	Emissions from Other Area Oil-Combustion sources were reduced by 75
percent (Used the same SCCs identified in MANE-VU Oil strategies list.)

In addition, NESCAUM removed SO2 emissions from 6500 MW of six
coal-burning EGUs in Canada that are scheduled to be shut down for the
Best and Final Modeling.  It is expected that these units will be
replaced with nine natural gas turbine units with selective catalytic
reduction controls.  NESCAUM based estimated emission rates for modeled
pollutants on a combination of factors, including recommendations from
the State of New Hampshire, a NYSERDA study, and AP-42 ratios among
pollutants.  Emissions were reduced by more than 144,000 tons per year
as a result of this measure.

Visibility Impacts of Additional Reasonable Controls from Best and Final
Modeling

40 CFR Section 51.308(d)(3)(v)(G) requires states to address the net
effect on visibility resulting from changes projected in point, area and
mobile source emissions by 2018.  The starting point for indicating
progress achieved by measures included in this SIP and other
MANE-VU-member SIPs is the 2000-2004 baseline visibility at affected
Class I areas.  To calculate the baseline visibility for affected Class
I areas, using 2000-2004 IMPROVE monitoring data, the deciview value for
the 20 percent best days in each year were averaged together, producing
a single average deciview value for the best days.  Similarly, the
deciview values for the 20 percent worst days in each year were averaged
together,  producing a single average deciview value for the worst days.

Initial modeling (Appendix   REF _Ref201032634 \r \h  \* MERGEFORMAT  F
) was then performed to identify reasonable progress goals.  Results of
this modeling showed that sulfate aerosol – the dominant contributor
to visibility impairment in the Northeast’s Class I areas on the 20
percent worst visibility days – has significant contributions from
states in all three of the eastern RPOs.  These emissions are projected
to continue in future years.  An assessment of potential control
measures identified a number of promising strategies, including the
adoption of a low-sulfur fuel oil strategy, the implementation of BART
requirements, and additional controls on select EGUs, as well as a 28
percent reduction in non-EGU SO2 emissions in VISTAS and MRPO states. 
These strategies were predicted to yield significant visibility benefits
beyond the uniform rate of progress and, in fact, significantly beyond
the projected visibility conditions that would result from “on the
books/on the way” air quality protection programs.

NESCAUM conducted modeling for MANE-VU to document the impacts of the
long-term strategy on visibility at affected Class I areas.  This
“Best and Final” modeling is documented in the report 2018
Visibility Projections (Appendix G), and estimates the composite
visibility benefits of all strategies within and outside MANE-VU. 
Emissions inventory adjustments were made for this modeling in order to
better represent the likely outcome of efforts to pursue the BART,
low-sulfur oil, and EGU control measures included in the MANE-VU June
20, 2007 statements.

 

Figure 43 to Figure 46 illustrate the predicted visibility improvement
by 2018 resulting from the implementation of the MANE-VU regional
long-term strategy (the short green line above the year 2018).  This
improvement is compared to the Uniform Rate of Progress for affected
Class I areas (shown as the diagonal purple line).  No degradation is
represented by the dashed line, blue dots at the upper left indicate the
20 percent worst observed visibility days, and the pink line at bottom
left indicate the 20 percent best observed visibility days.  All MANE-VU
sites are projected to meet or exceed the uniform rate of progress for
2018.  In addition, no site anticipates increases in best-day visibility
relative to the baseline.

Figure   SEQ Figure \* ARABIC  43 : Projected Visibility Improvement at
Acadia National Park Based on 2018 Visibility Projections

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

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

Figure   SEQ Figure \* ARABIC  46 : Projected Visibility Improvement at
Moosehorn Wilderness Area Based on 2018 Visibility Modeling 

Massachusetts’ Share of Emissions Reduction

40 CFR Section 51.308(d)(3)(ii) requires states to demonstrate that its
implementation plan includes all measures necessary to obtain its share
of emission reductions needed to meet reasonable progress goals.  The
control measures included in this SIP represent the contribution of
Massachusetts towards achieving the reasonable progress goals of Class I
states by 2018.  

  REF _Ref196790899 \h  Table 8  in Section 6.8 shows that
Massachusetts’ overall projected reduction of total regional haze
pollutants between 2002 and 2018 is 31 percent.  This is closely
comparable to MANE-VU’s overall reduction of 29 percent for the same
period.  In addition, MANE-VU modeling demonstrates that
Massachusetts’ long-term strategy, when coordinated with other
states’ strategies as defined by the MANE-VU statement, is sufficient
to meet the reasonable progress goals of Class I states.  Thus,
Massachusetts is contributing its share of emissions reductions needed
to meet reasonable progress goals.

The MANE-VU statement of June 20, 2007 provided that each state will
have up to 10 years to pursue adoption and implementation of reasonable
NOx and SO2 control measures as appropriate and necessary.  This SIP is
consistent with that statement.

Emission Limitations and Compliance Schedules

40 CFR 51.308(d)(3)(v)(C) requires Massachusetts to consider emission
limitations and compliance schedules to achieve reasonable progress
goals.  Emission limitations and compliance schedules are already in
place for the Massachusetts programs outlined in Subsection 10.4. 
MassDEP’s amended 310 CMR 7.05: Fuels All Districts establishes
emissions limitations and compliance schedules for the low sulfur fuel
oil strategy consistent with the MANE-VU Ask.   MassDEP has established
emissions limitations for Wheelabrator – Saugus that require
implementation of BART in 2012.  MassDEP has adopted an alternative to
BART that ensures emissions reductions by July 1, 2014, and a Targeted
EGU Strategy.  All emissions limitations will be in place by 2018 in
order to achieve the reasonable progress goals.  MassDEP will provide a
status update on emissions limitations and compliance schedules in the
2013 regional haze SIP progress report. 

Enforceability of Emission Limitations and Control Measures

40 CFR 51.308(d)(3)(v)(F) requires Massachusetts to consider the
enforceability of emissions limitations and control measures.  Emissions
reductions due to ongoing air pollution controls described in Section
10.4 are or will be enforceable by 2018.  For the additional reasonable
strategies identified above, MassDEP has promulgated regulations, 310
CMR 7.26(50) through (54) to control emissions from outdoor hydronic
heaters, and amended 310 CMR 7.05 to reduce the sulfur content of fuel
oil, and includes these regulations in this SIP.  MassDEP has issued an
Emissions Control Plan for Wheelabrator – Saugus reflecting BART, and
has issued Emissions Control Plans for Salem Harbor, Brayton Point, and
Mt. Tom that support MassDEP’s Alternative to BART.  All of the
Emissions Control Plans are submitted as part of this SIP.

Prevention of Significant Deterioration

The Prevention of Significant Deterioration (PSD) program applies to all
new major stationary sources (or existing major stationary sources
making a major modification) located in an area that is in attainment or
is unclassified for a pollutant with a NAAQS.  A major source is an
emissions source that has the potential to emit more than 100 tons per
year of a regulated pollutant in a listed category or 250 tons per year
in any other category.  One of the intentions of the PSD program is to
protect air quality in national parks, wilderness areas, and other areas
of special natural, scenic, or historic value.  The PSD permitting
process requires a technical air quality analysis and additional
analyses to assess the potential impacts on soils, vegetation and
visibility at Class I areas. 

MassDEP accepted delegation of the federal PSD program in 1982.  In
2003, consistent with its delegation agreement, MassDEP returned the
program to EPA and EPA Region I assumed the responsibility for issuing
PSD permits for Massachusetts facilities.  In April 2011, MassDEP took
back delegation of the PSD program, and is developing state regulatory
adoption of the PSD program for inclusion in the federally enforceable
Massachusetts State Implementation Plan.  

In addition, MassDEP has retained its state new source review program,
which permits new and modified sources of emissions under 310 CMR 7.02
– Plan Approval and Emission Limitations.  This regulation requires
Best Available Control Technology (BACT) for all pollutant emissions and
a determination that the new or modified source will not cause or
contribute to a violation of a NAAQS.

Depending upon the specific pollutant, the new or modified source also
may be subject to non-attainment review under 310 CMR 7.00 Appendix A
– Emissions Offsets and Non-Attainment Review, which requires Lowest
Achievable Emissions Rate (LAER).  

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

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

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

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

 Along with the NYSDEC, NJDEP/Rutgers, VADEQ, and UMD.  

 Along with the VTDEP and MDEQ.

 Tables 6-8 are based upon the 2002 MANE-VU Regional Baseline Inventory,
version 3.  See Appendix M for details.

 Massachusetts 2002 Baseline Emission Inventory. Available online:
http://www.mass.gov/dep/air/priorities/aqdata.htm

 Excludes CO, which is not a regional haze pollutant.

 Percentages based on 2002 annual average sulfate impact estimated with
REMSAD model as described in MANE-VU Contribution Assessment Chapter 4
and summarized on page 8-2 of the Contribution Assessment (Appendix  
REF _Ref191968764 \r  \* MERGEFORMAT  A ).

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

 EPA (2005)   HYPERLINK
"http://www.epa.gov/ttn/chief/eiinformation.html" 
http://www.epa.gov/ttn/chief/eiinformation.html  and MARAMA (2004)  
HYPERLINK "http://www.marama.org/visibility/2002%20NEI/index.html" 
http://www.marama.org/visibility/2002%20NEI/index.html   

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

 EPA. (2000) National Air Quality and Emission Trends Report, 1998, EPA
454/R-00-003, available online:   HYPERLINK
"http://www.epa.gov/oar/aqtrnd98/"  http://www.epa.gov/oar/aqtrnd98/ .

 EPA 454/R-00-002. (2000) National Air Pollutant Trends, 1900 – 1998.
Available online:   HYPERLINK
"http://www.epa.gov/ttn/chief/trends/trends98/trends98.pdf" 
http://www.epa.gov/ttn/chief/trends/trends98/trends98.pdf .

 Ansari, A. S., and Pandis, S.N. (1998) “Response of inorganic PM to
precursor concentrations,” Environ Sci Technol, 32: 2706-2714.

 SO2 reacts in the atmosphere to form sulfuric acid (H2SO4).  Ammonia
can partially or fully neutralize this strong acid to form ammonium
bisulfate or ammonium sulfate.  If planners focus future control
strategies on ammonia and do not achieve corresponding SO2 reductions,
fine particles formed in the atmosphere will be substantially more
acidic than those presently observed.

 Davidson, C., Strader, R., Pandis, S., and Robinson, A. Preliminary
Proposal to MARAMA and NESCAUM:  Development of an Ammonia Emissions
Inventory for the Mid-Atlantic States and New England. Carnegie Mellon
University, Pittsburgh, PA. January, 1999.

 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.

 The NEI 1999 V.3 NH3 emissions were developed by EPA for a limited
amount of livestock. ( HYPERLINK
ftp://ftp.epa.gov/EmisInventory/finalnei99ver3/criteria/documentation/ar
ea/area_99nei_finalv3_0204.pdf 
ftp://ftp.epa.gov/EmisInventory/finalnei99ver3/criteria/documentation/ar
ea/area_99nei_finalv3_0204.pdf ) 

In contrast, the MANE-VU 2002 V.3 NH3 emissions were developed by the
Carnegie Mellon University (CMU) Ammonia Model that is more
comprehensive than EPA's 1999 method. 

 A full list of the 26 source categories can be found in 40 CFR Part 51
Appendix Y: Guidelines for BART Determinations Under the Regional Haze
Rule.

 “Source” can refer to an emission unit or to a facility and is used
in the Clean Air Act and in EPA’s Guidance on Regional Haze. 

 40 CFR Part 51 Appendix Y: Guidelines for BART Determinations Under the
Regional Haze Rule.

 On August 8, 2011, EPA promulgated the Cross-State Air Pollution Rule
(CSAPR) to replace CAIR.

 Emissions information was gathered from the MANE-VU 2002 Version 2
(Base A) emissions inventory.  Since then, the MANE-VU 2002 Version 3
(Base B) emissions inventory has been developed which includes several
changes made by the OTC modeling committee.

 As an additional demonstration that sources whose impacts were below
the 0.1 dv level were too small to warrant BART controls, the entire
MANE-VU population of these units was modeled together to examine their
cumulative impacts at each Class I site.  The results of this modeling
demonstrated that the maximum 24-hour impact at any Class I area of all
modeled sources with individual impacts below 0.1 dv was only a 0.35 dv
change relative to the estimated best days natural conditions at Acadia
National Park.  This value is well below the 0.5 dv impact recommended
by EPA for exemption modeling and used by most other RPOs.

 MassDEP is developing a replacement to MassCAIR that will continue to
limit ozone season NOx emissions when MassCAIR is replaced by EPA’s
Cross-State Air Pollution Rule.

 No data was reported for PM emissions.

 EPA recalculated and changed the emissions limits for some of the
pollutants in the Emissions Guidelines in a direct final rule in 1997.

 Salem Harbor Units 1 and 2 were removed from service as of December 31,
2011, which means that these units can no longer generate electricity
for the power grid.  These units are not restricted from operating for
other purposes; therefore, MassDEP established permit restrictions in
order for emission reductions at these units to be counted in the
Alternative to BART. 

 For further discussion of CALPUFF modeling, see Sections 8.6 and 8.7 of
the Regional Haze SIP. 

 As described in Appendix R (Five-Factor Analysis of BART-Eligible
Sources) and Appendix U (Assessment of Control Technology Options for
BART-Eligible Sources). 

 Values for MM5 and NWS meteorological modeling platforms; see Tables 12
and 13.

 “Baseline and Natural Visibility Conditions, Considerations and
Proposed Approach to the Calculation of Baseline and

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

 Although the IPM® model runs also anticipated the implementation of
EPA’s Clean Air Mercury Rule (CAMR), that rule has since been vacated
by the courts.  However, it is anticipated the adjustments to the
predicted SO2 emissions from EGUs used in the air quality modeling,
which were based on state-specific comments on the amount of SO2
controls that will actually be installed due to state-specific
regulations and EPA’s CAIR rule, will have more of an impact on the
air quality modeling analysis conducted for this SIP than the vacatur of
the CAMR rule.  MANE-VU believes the adjustments based on
state-specific comments improved the reliability of the inventory and
made the modeling results more dependable.

 The inventory was prepared before the MACT for Industrial Boilers and
Process Heaters was vacated.  Control efficiency was assumed to be at 4
percent for SO2 and 40 percent for PM.

 Note that New Jersey indicated that the reductions from the adhesives
and sealants application control measure should only apply to area
sources—no reductions for point sources (SCC 4-02-0007-xx) were
included due to inventory double counting issues, not due to rule change
issues.  

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

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http://www.nora-oilheat.org/site20/uploads/lowsstudy.pdf ).

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

  HYPERLINK
"http://www.gpo.gov/fdsys/pkg/FR-2012-02-16/pdf/2012-806.pdf"
www.gpo.gov/fdsys/pkg/FR-2012-02-16/pdf/2012-806.pdf 

 The 67% projection is less than the 72% reduction already achieved in
2011 because it assumes the same unit utilization as in the 2002
baseline year, whereas the reduction achieved in 2011 is due in part to
low utilization of several units, including Canal Units 1 and 2 and Mt.
Tom Station.    

 Note that this SO2 emissions reduction is less than the SO2 emissions
reduction under the Alternative to BART (Table 17 in Section 8.10)
because fewer units are included in the Targeted EGU Strategy. 

 Two additional EGUs beyond the “167 Stack” Targeted EGUs were
projected to have 2018 SO2 emissions, totaling 3,588 tons, which would
bring the total 2018 emissions to 30,399 tons, which is still well below
the 45,941 tons used in the 2018 modeling.

 NESCAUM’s 2018 Visibility Projections report cited a November 2006
paper by the Ontario Power Authority, “Ontario’s Integrated power
System Plan Discussion Paper 7:  Integrating the Elements—A
Preliminary Plan. See   HYPERLINK
"http://www.powerauthority.on.ca/ipsp/Storage/32/2734_DP7_IntegratingThe
Elements.pdf" 
http://www.powerauthority.on.ca/ipsp/Storage/32/2734_DP7_IntegratingTheE
lements.pdf 

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

 The estimate for Moosehorn Wilderness Area also serves to provide an
estimate for Roosevelt/Campobello International Park.

Page   PAGE  xi 





This information is available in alternate format. Call Michelle
Waters-Ekanem, Diversity Director, at 617-292-5751. TDD# 1-866-539-7622
or 1-617-574-6868

MassDEP Website: www.mass.gov/dep

Printed on Recycled Paper



Page   PAGE  10 

DRAFT   DATE \@ "MMMM d, yyyy"  August 9, 2012 

This information is available in alternate format. Call Michelle
Waters-Ekanem, Diversity Director, at 617-292-5751. TDD# 1-866-539-7622
or 1-617-574-6868

MassDEP Website: www.mass.gov/dep

Printed on Recycled Paper



Figure   SEQ Figure \* ARABIC  6 : Map of Acadia National Park Showing

Location of IMPROVE Monitor

IMPROVE MONITOR SITE

MA

MA

  HYPERLINK "http://www.maine.gov/dep/air/meteorology/images/Acadia.jpg"
 http://www.maine.gov/dep/air/meteorology/images/Acadia.jpg 

IMPROVE MONITOR SITE

