Draft Massachusetts Regional Haze State Implementation Plan

BACKGROUND AND OVERVIEW OF THE FEDERAL REGIONAL HAZE REGULATION.1 2 The Basics of Haze

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 establishes a national objective to prevent future impairment of visibility and to address any current visibility issues in mandatory Class I Federal areas caused by man-made air pollution.

The "Class I" designation was given to each of 158 areas in existence as of August 1977 that met the

• all national parks greater than 6000 acres,

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

In 1980, Bradwell Bay in Florida and Rainbow Lake in Wisconsin were designated as federal Class I areas for visibility protection Currently, there are 156 national park and wilderness areas that retain this Class I visibility protection status.

In subsequent years, incremental efforts were made to tackle visibility challenges in Class I areas However, the implemented control measures primarily focused on mitigating "plume blight" from particular pollution sources, leaving regional haze concerns in the Eastern United States largely unaddressed.

In 1990, Congress amended the Clean Air Act (CAA) by adding Section 169B (42 U.S.C 7492), which mandates ongoing research and regular evaluations of visibility improvement efforts A 1993 report from the National Academy of Sciences affirmed that existing scientific knowledge and available control technologies are sufficient for implementing regulatory measures to enhance and safeguard visibility.

Section 169B(f) of the Clean Air Act established the Grand Canyon Visibility Transport Commission (GCVTC) to recommend measures to the U.S Environmental Protection Agency (EPA) aimed at enhancing visibility in the Grand Canyon National Park After four years of extensive research and policy development, the GCVTC submitted its findings to the EPA in June 1996 The insights and data provided in this report, along with additional research conducted by the Commission, played a crucial role in shaping the EPA's regulations for improving visibility in the region.

Figure 1: Locations of Federally Protected Mandatory Class I Areas

History of Federal Regional Haze Rule

The Regional Haze Rule, established under Title 40, Part 51 of the Code of Federal Regulations, outlines federal requirements for states to achieve national visibility goals Adopted on July 1, 1999, and effective from August 30, 1999, this regulation addresses the visibility impacts of pollution sources across extensive geographic areas Consequently, many states, including those without Class I Areas, must engage in haze reduction initiatives The specific obligations for states' Regional Haze State Implementation Plans (SIPs) are detailed in 40 CFR 51.308.

The EPA has designated five Regional Planning Organizations (RPOs) to enhance coordination and collaboration in addressing haze issues, following consultations with states and tribes.

Northeast states, including the District of Columbia, formed the Mid-Atlantic / Northeast Visibility Union (MANE-VU) 3

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 for the D.C District ruled on the challenge to the Best Available Retrofit Technology (BART) provisions, sending the matter back to the EPA However, the court upheld the haze rule's goals regarding natural visibility and the requirement for no degradation.

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

On February 18, 2005, the Appeals Court delivered a ruling that partially vacated and partially upheld the Regional Haze Rule For further details, refer to the case Center for Energy and Economic Development v.

In the case of CEED v EPA, referenced as EPA #03-1222 and decided on February 18, 2005, the court upheld a petition that contested specific elements of the Regional Haze Rule, particularly those related to the optional emissions trading program for certain Western States and Tribes, known as the WRAP Annex Rule.

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

1 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

2 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.

3 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.

Massachusetts has submitted its State Implementation Plan (SIP) to comply with the EPA's Regional Haze Rule, as outlined in 40 CFR 51.308(b) This SIP fulfills the essential requirements of 40 CFR 51.308(d) and incorporates the Best Available Retrofit Technology (BART) standards specified in 40 CFR 51.308(e) Additionally, the SIP addresses regional planning obligations and emphasizes coordination and consultation with state, tribal, and Federal Land Managers (FLMs).

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.

Under 40 CFR 51.308(f), Massachusetts is mandated to revise its Regional Haze State Implementation Plan (SIP) every decade, with the first milestone for reasonable progress set for 2018 The state is dedicated to submitting the necessary revisions to its Regional Haze SIP by the deadline of 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

The Regional Planning Section of this SIP provides a detailed description of MANE-VU and lists its members It addresses a mandatory Class I area outside the state that could be impacted by emissions originating within the state Additionally, Massachusetts is committed to submitting its 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 Figure 2 shows a map of the five RPOs:

The MANE-VU, VISTAS, MRPO, CenRAP, and WRAP organizations play a crucial role in regional air quality planning These Regional Planning Organizations (RPOs), along with the states and tribes they encompass, are mandated to collaborate on the formulation of effective emission management strategies.

Figure 2: US EPA Designated Regional Planning Organizations

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

MANE-VU is overseen by the Ozone Transport Commission (OTC) and implemented in collaboration with the Mid-Atlantic Regional Air Management Association (MARAMA) and the Northeast States for Coordinated Air Quality Management (NESCAUM) The members of MANE-VU are detailed in Table 1, which includes various states, tribes, federal agencies, and professional staff from OTC and MARAMA, all working together to enhance air quality management.

NESCAUM participates in several committees and workgroups formed by MANE-VU, where policy decisions are determined by the MANE-VU Board of Directors, which includes senior representatives from each member state, tribe, or agency.

District of Columbia Rhode Island

Maine St Regis Mohawk Tribe

New Hampshire U.S National Park Service*

New Jersey U.S Fish and Wildlife Service*

Since its establishment on July 24, 2001, MANE-VU has created a robust committee structure to tackle both technical and non-technical aspects of regional haze The Technical Support Committee (TSC) plays a crucial role in evaluating the severity of the regional haze issue, analyzing technical findings, and reporting to the MANE-VU Board It comprises three specialized working groups focused on Emissions Inventory, Modeling, and Monitoring/Data Analysis The TSC serves as an essential platform for discussing technical projects, ensuring timely completion of significant regional haze initiatives, and keeping members updated on all MANE-VU activities.

The Communications Committee is tasked with creating strategies to raise public awareness about the regional haze issue and making recommendations to the MANE-VU Board to support this objective This committee has been instrumental in developing MANE-VU's newsletter and outreach tools aimed at both stakeholders and the general public, focusing on regional concerns related to MANE-VU.

The MANE-VU Board is responsible for making policy decisions, supported by a Policy Advisory Group that offers guidance on key policy issues This group includes representatives from Federal Land Managers, the EPA, state governments, and tribal entities, convening as needed to address relevant concerns.

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 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 A) Based on that work, MANE-

VU determined that the area of influence should encompass all states involved in MANE-VU, along with additional states that contributed at least 2 percent of sulfate ions to MANE-VU Class I areas in 2002 According to MANE-VU, the states listed in Table 2 are responsible for causing or contributing to visibility impairment in several Class I areas, including Acadia National Park, Brigantine Wildlife Refuge, Great Gulf Wilderness Area, Lye Brook Wilderness Area, Moosehorn Wildlife Refuge, Presidential Range-Dry River Wilderness Area, and Roosevelt-Campobello International Park.

Table 2: 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,

Massachusetts Impact on MANE-VU Class I Areas

In the 2002 baseline year, emissions sources in Massachusetts significantly affected visibility in Class I areas within the MANE-VU region Detailed information about the extent of these impacts can be found in Section 7 and the Contribution Assessment in Appendix i A summary of the Class I areas impacted by emissions from Massachusetts is provided in Table 3.

Table 3: Class I Federal Areas Affected by Emissions from Massachusetts

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, the EPA implemented the Clean Air Interstate Rule (CAIR), aimed at significantly reducing SO2 and NOx emissions in the eastern United States through a cap-and-trade system This federal regulation established permanent emission caps for 28 eastern states and the District of Columbia, impacting air quality across the region Although Massachusetts was only a participant during the ozone season, CAIR would have had a substantial influence on the state's future air quality.

According to EPA’s CAIR website, SO2emissions in the affected states would be reduced by more than

70 percent and NOxemissions by more than 60 percent from 2003 levels upon full implementation of CAIR (see http://www.epa.gov/cair/)

Figure 4: Map of CAIR States http://www.epa.gov/cair/

On July 11, 2008, the U.S Court of Appeals for the District of Columbia Circuit ruled that the Clean Air Interstate Rule (CAIR) violated essential provisions of the Clean Air Act, leading to its complete vacatur and a remand to the EPA for the establishment of a new rule aligned with the court's opinion In response to concerns about the regulatory gap created by this decision, the EPA appealed Subsequently, on December 23, 2008, the court stayed the vacatur of CAIR while still requiring the EPA to develop a new rule in accordance with its earlier ruling.

The vacatur of the Clean Air Interstate Rule (CAIR) posed significant challenges for states striving to meet the Regional Haze Rule, particularly in mandatory Class I areas where CAIR was essential for emission reductions aimed at improving visibility While all eastern states utilized CAIR to some extent in their regional haze State Implementation Plans (SIPs), several Southeast states heavily relied on it for compliance Additionally, the invalidation of CAIR raised concerns regarding the credibility of emission inventories and air quality modeling studies conducted by MANE-VU and other Regional Planning Organizations (RPOs) for their members' Regional Haze SIPs.

The CAIR Phase I requirements are still effective, and the regional control programs under CAIR are operational as the EPA works on new replacement regulations following the remand On August 2, 2010, the EPA proposed Federal Implementation Plans aimed at reducing the interstate transport of fine particulate matter.

The "Transport Rule," designed to replace the Clean Air Interstate Rule (CAIR), aims to enforce the Clean Air Act's provisions on cross-state air pollution transport This regulation mandates that 31 states and the District of Columbia enhance air quality by significantly lowering sulfur dioxide (SO2) and nitrogen oxides (NOx) emissions from power plants, which are responsible for ozone and fine particulate pollution in neighboring states The final version of the rule is anticipated to be released in Summer 2011.

Massachusetts expects that future emission controls under the Transport Rule will be as stringent as those anticipated under CAIR, leading to improved emissions and air quality levels The state's long-term strategy for its State Implementation Plan (SIP) serves as a solid foundation for enhancing visibility in MANE-VU’s Class I Areas A mid-point review in 2013 will involve consultations with Class I states to potentially reassess reasonable progress goals By then, the EPA's Transport Rule is expected to be finalized, along with new modeling results, allowing for adjustments to regional haze plans to align with the latest regulations and state measures.

Regional Consultation and the “Ask”

Under 40 CFR Section 51.308(d)(3)(i), Massachusetts is mandated to collaborate with neighboring states and tribes to create unified emission management strategies To fulfill this requirement, the state engaged in consultations with other jurisdictions via the MANE-VU and inter-RPO processes, which provided essential technical information for formulating these coordinated strategies.

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

The Final Interim Principles for Regional Planning by MANE-VU, detailed in Appendix ii, outline key principles utilized by states and tribes during the regional haze consultation and State Implementation Plan (SIP) development processes These principles address critical issues such as regional haze baseline assessments, natural background levels, and the establishment of reasonable progress goals, which are further elaborated in subsequent sections of the SIP.

Figure 5: MANE-VU Principles for Regional Haze Planning

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

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

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

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

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

6) Technical analyses will be transparent, when possible, and will reflect the most up-to-date information and best scientific methods for the decision needed within the resources available

7) The State with the Class I area retains the responsibility to establish reasonable progress goals The RPOs will make reasonable efforts to facilitate the development of a consensus 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)

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

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

The consultation process aims to share information, identify and document issues, explore various options, gather feedback on these options, build consensus where feasible, and support informed decision-making among the Class I States.

11)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.

To effectively address regional haze and achieve reasonable progress goals for 2018, MANE-VU established a set of guiding principles and a consistent technical framework for emission control strategies Following extensive research and analysis, MANE-VU adopted two key documents on June 20, 2007, which serve as the technical foundation for consultations among stakeholders These documents outline fundamental strategies for controlling pollutants that impair visibility in Class I areas across the eastern United States, collectively referred to as the MANE-VU “Ask” (Appendix iii).

• “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.”

In 2007, extensive consultations took place among MANE-VU states, as well as with other states, tribes, and provinces Detailed records of these meetings and calls are available on the MANE-VU website For a comprehensive overview of the consultation process, visit www.otcair.org/manevu/consultations.asp?fview=2.

On March 1, 2007, the MANE-VU members convened for an intra-regional consultation to evaluate the requirements for regional haze plans During the meeting, they discussed preliminary modeling results and the ongoing efforts to prepare the MANE-VU report on reasonable progress factors, as well as the control strategy options currently under consideration.

On June 7, 2007, the MANE-VU Intra-State Consultation convened, where Class I states adopted a statement of principles During this meeting, MANE-VU members engaged in discussions regarding draft statements that outlined reasonable controls both within and outside the organization The meeting was inclusive, welcoming Federal Land Managers and stakeholders to participate in the dialogue.

On June 20, 2007, the MANE-VU Conference Call concluded discussions on reasonable controls both within and outside the MANE-VU framework Participants agreed on a series of statements known as the MANE-VU "Ask," which included specific controls and a request for action from the EPA Federal Land Managers also took part in the call Following approval, all statements, along with the principles adopted on June 7, were made publicly available on the MANE-VU website.

On July 19, 2007, a technical call was held for the MANE-VU Class I States’ Consultation, where the MANE-VU/New Hampshire request was shared with other Regional Planning Organizations (RPOs), RPO staff, and Federal Land Managers This call aimed to offer valuable information and create an opportunity for participants to seek additional details.

Meeting the “Ask” – MANE-VU States

Member states of MANE-VU have expressed their commitment to fulfilling the “Ask” outlined in their SIPs This commitment entails the adoption and implementation of essential emission management strategies tailored to each state's specific needs and circumstances.

• timely implementation of BART requirements; and

The low sulfur fuel oil strategy implemented in the inner zone states—New Jersey, New York, Delaware, and Pennsylvania—aims to significantly reduce sulfur content in various fuel oils By 2012, the sulfur content of distillate oil will be limited to 0.05% (500 ppm), #4 residual oil to 0.25%, and #6 residual oil to between 0.3% and 0.5% Additionally, a further reduction of distillate oil sulfur content to 15 ppm is targeted for 2016.

The outer zone States of the MANE-VU region are implementing a low sulfur fuel oil strategy aimed at significantly reducing sulfur content in various fuel types By 2014, the goal is to lower the sulfur content of distillate oil to 0.05 percent by weight (500 ppm), and by 2018, to achieve a reduction of #4 residual oil to a sulfur content between 0.25 and 0.5 percent by weight.

By 2018, the sulfur content of residual oil must be reduced to no more than 0.5 percent by weight, while the sulfur content of distillate oil should be further lowered to 15 ppm, contingent upon the availability of supply.

A significant reduction of 90 percent or more in sulfur dioxide (SO2) emissions is targeted for the top 100 electric generating units (EGUs) identified by MANE-VU This initiative encompasses a total of 167 stacks that are considered likely to impair visibility in designated Class areas.

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

Ongoing assessments of various control strategies, such as enhancing energy efficiency, utilizing alternative clean fuels, and implementing additional methods to decrease sulfur dioxide (SO2) and nitrogen oxide (NOx) emissions from coal-burning facilities are set for completion by 2018 Additionally, new source performance standards for wood combustion will be established These measures, along with others identified, will undergo evaluation during the consultation process to ensure their feasibility and cost-effectiveness.

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 member state of MANE-VU, Massachusetts adopted the "Ask" during the MANE-VU Board meeting on June 7, 2007 The state plans to fulfill this agreement by implementing Best Available Retrofit Technology (BART) and an alternative approach as outlined in Section 8, while also ensuring reductions in SO2 emissions from targeted Electric Generating Unit (EGU) stacks Massachusetts will pursue a low-sulfur fuel oil strategy and enforce controls on outdoor wood-fired boilers, as detailed in Section 10, along with other reasonable and cost-effective measures as necessary.

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;

The MANE-VU region aims for a significant reduction in sulfur dioxide (SO2) emissions, targeting a 90% or greater decrease from the top 100 electric generating units, which include a total of 167 stacks This initiative is crucial for protecting mandatory Class I Federal areas and requires each state to achieve equivalent SO2 reductions.

Implementing effective controls on non-EGU sources has led to a significant 28 percent decrease in non-EGU SO2 emissions by 2018, compared to the existing projections used in regional haze planning This reduction aligns with the anticipated outcomes of the MANE-VU's low sulfur fuel oil strategy.

In 2018, ongoing assessments will focus on strategies to lower sulfur dioxide (SO2) and nitrogen oxide (NOx) emissions from coal-burning facilities, alongside the establishment of new performance standards for wood combustion These initiatives, along with additional identified measures, aim to enhance environmental protection and air quality.

Massachusetts acknowledges that non-MANE-VU states may opt not to implement the MANE-VU "Ask" due to financial implications, conflicts, and limited benefits for their regions During discussions, some of these states indicated they might not seek emissions reductions beyond the CAIR controls and BART-related measures The EPA's proposed Transport Rule is expected to yield reductions comparable to or exceeding those of CAIR, with hopes that mid-west and southeast RPO states will adopt additional controls Ultimately, the EPA will determine the approvability of all states' State Implementation Plans (SIPs).

Technical Ramifications of Differing Approaches

MANE-VU aimed to create a unified modeling platform for meteorology and emissions among neighboring Regional Planning Organizations (RPOs) Despite their collaborative efforts to establish a consistent emissions inventory, keeping up with each RPO's updates proved challenging Each update improved the emissions inventory's quality, but required all RPOs to incorporate these changes, leading to a cycle of continuous reprocessing and outdated models This lengthy modeling process, often taking over a month, contributed to significant delays in State Implementation Plans (SIPs), ultimately causing many states to miss the critical filing deadline of December 17, 2007.

The Regional Planning Organizations (RPOs) had varying opinions on which version of the EGU dispatching model to utilize, specifically between Integrated Planning Model (IPM) versions 2.1.9 and 3.0 Initially, the EPA approved IPM version 2.1.9 for emissions preparation; however, with the release of IPM version 3.0, which included updated fuel costs, it became the EPA's preferred choice While the Mid-Atlantic RPO (MRPO) adopted IPM version 3.0, the VISTAS organization opted to continue using version 2.1.9 Similarly, MANE-VU also retained IPM version 2.1.9 instead of creating non-comparative datasets for its earlier analyses Consequently, the differing emissions assumptions among the three eastern RPOs influenced the final modeling assumptions.

MANE-VU's final modeling incorporates both the emissions programs for 2018 and additional reasonable controls outlined in the MANE-VU "Ask." In contrast, other Regional Planning Organizations (RPOs) may not have included similar measures, leading to modeling results that do not align with the MANE-VU "Ask" requirements This discrepancy could result in inadequacies in their State Implementation Plans (SIPs), which will require resolution by the EPA.

Federal Land Manager Coordination

Massachusetts will maintain collaboration with Federal Land Managers (FLMs) throughout the creation of future progress reports and plan updates, ensuring effective consultation during the implementation of programs aimed at enhancing visibility in 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 shared earlier drafts of the SIP with Federal Land Managers (FLMs) and the EPA for review and feedback on November 25, 2008, and July 31, 2009 Prior to any public hearing on the SIP, MassDEP offered FLMs a chance for consultation, ensuring at least 60 days for their input The feedback received from FLMs included both general and specific comments, which were carefully considered by the reviewing agencies.

Massachusetts' draft Regional Haze State Implementation Plan (SIP) is comprehensive and well-structured, addressing key uncertainties related to the Clean Air Interstate Rule (CAIR) and modeling discrepancies, particularly regarding the MANE-VU Ask The consultation process highlighted these broad topics for further discussion Specific comments primarily requested additional information to support the initial Best Available Retrofit Technology (BART) analyses In compliance with 40 CFR 51.308(i)(3), the Massachusetts Department of Environmental Protection (MassDEP) has incorporated feedback from Federal Land Managers (FLMs) and the Environmental Protection Agency (EPA) in Appendix IV of the plan.

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:

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

2 Summary of major new source permits issued.

3 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

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

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

6 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)

7 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

Calculation Methodology

The Interagency Monitoring of Protected Visual Environments (IMPROVE) program was established in

From 1985, data has been collected to evaluate visibility conditions, monitor changes, and identify the causes of visibility impairment in Class I Areas This information, provided by the IMPROVE program, was instrumental in calculating baseline and natural visibility conditions for MANE-VU Class I areas.

The IMPROVE monitors listed in 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 4: IMPROVE Monitors for MANE-VU Class I Areas

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

In September 2003, the EPA issued guidance for calculating natural background and baseline visibility conditions, offering a default method and refinements for states to customize estimates for specific Class I areas MANE-VU applied this default method to determine natural visibility for the best and worst 20 percent of visibility days across its Class I areas and explored potential refinements, such as adjusting impairment calculations for carbon and sea salt However, these refinements did not significantly enhance accuracy, leading MANE-VU to adopt the default estimates while acknowledging that future scientific advancements may prompt a reevaluation.

After completing the technical analysis, MANE-VU offered federal agencies and stakeholders the chance to provide feedback The proposed approach was made available on the MANE-VU website on March 17.

In 2004, a stakeholder briefing took place, gathering feedback from various organizations including 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.

The proposal received various supportive comments, while others focused on four key areas: the visibility calculation equation, the statistical method for determining the best and worst 20 percent visibility days, the incorporation of transboundary effects and fires, and the timing for integrating new information MANE-VU reviewed and summarized all comments, subsequently briefing the MANE-VU Board on the feedback and potential response strategies.

The MANE-VU position on natural background conditions was issued in June 2004, and stated that,

To further enhance the default method, refinements to various aspects may be necessary before submitting State Implementation Plans (SIPs) These refinements could include revising the assumed distribution, addressing Rayleigh extinction, incorporating sea salt, and updating assumptions about the chemical composition of the organic fraction However, any changes will depend on the formation of a scientific consensus around a specific approach By incorporating these refinements, the default method can be improved, leading to more accurate SIP submissions.

In 2006, the IMPROVE Steering Committee implemented a revised extinction equation to enhance the default method These scientifically grounded revisions significantly improved the equation's accuracy in reflecting observed visibility at Class I sites.

In 2006, NESCAUM assessed both default and alternative methods for calculating baseline and natural background conditions in MANE-VU Class I areas, as detailed in the MANE-VU document titled "Baseline and Natural Background Visibility Conditions: Considerations and Proposed."

The article discusses the calculation of baseline and natural background visibility conditions in Class I Areas under the MANE-VU initiative It highlights the visibility improvement targets for 2018, indicating that the alternative approach yields similar rates of progress in New England, while slightly higher visibility improvements are necessary in the Mid-Atlantic region compared to the default method As a result of this assessment, MANE-VU recommended the adoption of the alternative reconstructed extinction equation for State Implementation Plans (SIPs) in December 2006 The organization will continue to engage in ongoing research and may update the calculation methodology as scientific knowledge advances.

MANE-VU Baseline and Natural Visibility

The IMPROVE program has determined the top 20 percent and bottom 20 percent of baseline visibility conditions from 2000 to 2004 for each MANE-VU Class I Area, utilizing an EPA-approved alternative method This data is available on the Visibility Information Exchange Web System (VIEWS) and can be accessed at http://vista.cira.colostate.edu/views/ The results, presented in deciviews as mandated by 40 CFR 51.308(d)(2), indicate that a one deciview change in haze is likely noticeable under ideal conditions The summarized five-year average baseline visibility values, natural visibility levels, and the differences between them for each MANE-VU Class I area highlight the extent of visibility impairment due to manmade emissions, which is critical to 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 v.

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

Presidential Range - Dry River Wilderness 4 7.7 22.8 3.7 12.0 3.9 10.8

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

4 Based on 4-year average for 2001-2004 (data collection in 2000 was for summer only).

MONITORING STRATEGY

IMPROVE Program Objectives

The IMPROVE program offers scientific documentation of visual air quality in America's wilderness areas and national parks, serving as a vital resource for land managers, industry planners, scientists, public interest groups, and air quality regulators By utilizing data collected at IMPROVE sites, these stakeholders can effectively understand and safeguard the visual air quality in Class I areas Key objectives of the IMPROVE program focus on preserving and enhancing these critical environmental resources.

• 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

The NESCAUM study, detailed in Appendix i, evaluated the contributions of Northeast and Mid-Atlantic States to visibility degradation in Class I areas, both within and outside the MANE-VU region, utilizing a range of assessment tools and techniques.

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 i.

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

The IMPROVE monitor (ACAD1) is situated at the Acadia National Park headquarters near Bar Harbor, Maine, at an elevation of 157 meters, with coordinates 44.38˚ latitude and -68.26˚ longitude Operated by the National Park Service, this monitor is deemed sufficient by Massachusetts for evaluating visibility progress in the park, indicating that no further monitoring locations or equipment are required at this time.

Figure 6: Map of Acadia National Park Showing

Figure 6: Acadia National Park on Clear and Hazy Days http://www.hazecam.net/class1/acadia.html

Great Gulf Wilderness Area, New Hampshire

The IMPROVE monitor for the Great Gulf Wilderness (GRGU1) is situated at Camp Dodge in the mid-northern region of Greens Grant within the White Mountain National Forest, specifically at an elevation of 454 meters, latitude 44.31˚, and longitude -71.22˚ Located just east and south of Route 16 near the Greens Grant / Martins Location boundary, this monitor also represents the Presidential Range - Dry River Wilderness and is operated by the U.S Forest Service Massachusetts deems the GRGU1 site sufficient for evaluating progress toward visibility goals in the Great Gulf Wilderness, indicating that no additional monitoring sites or equipment are required at this time.

Figure 7: Map of Great Gulf and Presidential Range - Dry River Wilderness Areas Showing

IMPROVE Monitor Location http://www.maine.gov/dep/air/meteorology/images/NHclass1.jpg

Figure 8: Great Gulf Wilderness Area on Clear and Hazy Days http://www.wilderness.net/

Presidential Range - Dry River Wilderness, New Hampshire

The IMPROVE monitor for the Presidential Range - Dry River Wilderness also serves the Great Gulf Wilderness (GRGU1), which is recognized by Massachusetts as suitable for evaluating progress towards visibility objectives in the Presidential Range - Dry River area.

Wilderness, and no additional monitoring sites or equipment are necessary at this time.

Presidential Range - Dry River Wilderness in Autumn http://www.wilderness.net

The IMPROVE monitor for the Lye Brook Wilderness (LYBR1) is positioned on Mount Equinox in Manchester, Vermont, at an elevation of 1,015 meters (latitude 43.15˚, longitude -73.13˚) Although the monitor is not located within the wilderness area, it is situated on a nearby mountain peak to the west of the Lye Brook Wilderness, both at similar elevations The U.S Forest Service is responsible for the operation and maintenance of the monitor.

Massachusetts has determined that the LYBR1 site is sufficient for evaluating progress towards visibility goals at the Lye Brook Wilderness, indicating that no further monitoring sites or equipment are required at this time.

Figure 9: Location of Lye Brook Wilderness Monitor http://www.wilderness.net/index.cfm?fuse=NWPS&sec=stateView&state=NH&map=menhvt

Figure 10: Lye Brook Wilderness Area on Clear and Hazy Days http://www.hazecam.net/class1/lye.html

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, located in New Brunswick, Canada, is monitored and maintained by the U.S Fish & Wildlife Service The MOOS1 site in Massachusetts is deemed sufficient for evaluating visibility progress at the Moosehorn Wilderness, indicating that no further monitoring sites or equipment are required at this time.

Figure 11: 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 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

Massachusetts has determined that the Moosehorn Wilderness (MOOS1) site is sufficient for evaluating progress towards visibility goals at Roosevelt Campobello International Park, indicating that no additional monitoring sites or equipment are required at this time.

Figure 13: Map of Roosevelt/Campobello International Park http://www.maine.gov/dep/air/meteorology/images/rcip.jpg

Figure 14: Roosevelt/Campobello International Park on Clear and Hazy Days source: Chessie Johnson, Roosevelt Campobello International Park Commission

MODELING

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

The MM5 simulations conducted in 2002 utilized a nested grid system, featuring a 36-km continental grid (145 x 102) and a 12-km grid (172 x 172) that covers the eastern United States and parts of Canada, as depicted in Figure 16 In collaboration with the New York State Department of Conservation (NYSDEC), an assessment was performed to evaluate the accuracy of the MM5 predictions against various observational data sources.

• 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

Massachusetts is actively involved in the CAP network and operates an upper air profiler in Stow, which utilizes RADAR return signals from vertically transmitted electromagnetic pulses to deliver hourly wind speed and direction profiles in the lower atmosphere up to approximately 4000 meters This system helps bridge the data gap created by the National Weather Service's upper air measurements, which are conducted only twice a day Additionally, the Stow profiler is equipped with a Radio Acoustic Sounding System (RASS) that provides valuable temperature profiles.

For more information on the MM5 meteorological processing and the modeling domain, please refer to Appendix viii of NYSDEC’s Meteorological Modeling Using the Penn State/NCAR 5th Generation Mesoscale Model and Appendix vi of NESCAUM’s MANE-VU Modeling for Reasonable Progress Goals.

Figure 15: 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 for the CMAQ and REMSAD air quality models were generated using the SMOKE emissions modeling system, which accommodates point, area, mobile (on-road and non-road), and biogenic emissions This system employs flexible processing techniques to effectively apply chemical speciation along with temporal and spatial allocation to the emissions inventories.

SMOKE utilizes the Biogenic Emission Inventory System (BEIS) alongside the EPA’s MOBILE6 model to effectively analyze biogenic and on-road mobile emissions The final processing stage employs vector-matrix multiplication to integrate the different emissions components into a unified model-ready emissions file Processed emissions outputs are illustrated in Figure 16.

Additional information regarding the SMOKE processing used to support air quality simulations can be found in Appendix viii and Appendix ix of the 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 6.

Figure 16: Examples of processed model-ready emissions: a) SO 2 from Point, b) NO 2 from Area, c)

NO 2 from On-road, d) NO 2 from Non-road, e) ISOP from Biogenic, f) SO 2 from all source categories

Model Platforms

Two regional-scale air quality models, CMAQ and REMSAD, were utilized for air quality simulations to support the Regional Haze State Implementation Plan (SIP) The EPA developed CMAQ, which played a crucial role in the primary modeling efforts related to the SIP and was also essential for the 8-hour ozone SIP process Meanwhile, REMSAD was developed by ICF Consulting/Systems.

Applications International, with the support of the EPA, utilized REMSAD for a source apportionment analysis conducted by NESCAUM The air quality simulations integral to the State Implementation Plan (SIP) efforts were carried out within the 12-km eastern modeling domain illustrated in Figure 16.

NESCAUM conducted a performance evaluation of the model for PM2.5 species, aerosol extinction coefficient, and the haze index, detailed in Appendix vi Additionally, NYSDEC analyzed the model's performance by comparing CMAQ model predictions with observed data for ozone, PM2.5, and various chemical species, as presented in Appendix x, CMAQ Model Performance and Assessment, 8-Hr OTC.

The CMAQ air quality simulations were conducted collaboratively by five modeling centers, including NYSDEC, NJDEP in partnership with Rutgers University, VADEQ, UMD, and NESCAUM An annual CMAQ simulation for 2002 was executed by NYSDEC over a 36-km domain, as illustrated in Figure 16, which provided the boundary conditions for a more refined 12-km eastern modeling domain The boundary conditions for the 36-km simulations were sourced from a GEOS-Chem global chemistry transport model run by Harvard University researchers Detailed technical options utilized in the CMAQ simulations are outlined in Appendix xi, focusing on NYSDEC’s Eight-Hour Ozone Modeling.

SMOKE/CMAQ system Further technical details regarding the CMAQ model and its execution are also provided in Appendix vi.

The REMSAD modeling simulations were utilized to meet the haze rule requirement for pollution apportionment, assessing the contribution to visibility improvement by geographic region and source sector Its species tagging capability is crucial for estimating the total contribution from elevated point sources in each state to simulated sulfate concentrations at eastern receptor sites By using the same emission and meteorological inputs as the Integrated SIP (CMAQ) platform, REMSAD simulated the annual average impact of each state's SO2 emissions on the sulfate fraction of PM2.5 across the northeastern United States within a 12-km modeling domain For more details on the REMSAD model and its role in the Regional Haze SIP efforts, refer to Appendix VI.

An additional modeling platform was developed to serve as a screening tool for evaluating control strategies and conducting sensitivity analyses, utilizing the CALGRID model CALGRID is a grid-based photochemical air quality model designed for Windows environments To enhance its utility alongside the SIP-quality CMAQ and REMSAD models, CALGRID was configured to operate with the same input parameters Air quality simulations using CALGRID were conducted on the same 12-km eastern modeling domain employed by CMAQ and REMSAD The performance of CALGRID was assessed in relation to the already evaluated CMAQ and REMSAD models, confirming its adequacy for the intended applications.

Conversion utilities were created to reformat meteorological inputs, boundary conditions, and emissions for the CALGRID modeling platform Pre-merged SMOKE emissions files from modeling centers were reformatted for EMSPROC6, the emissions pre-processor for CALGRID This tool enables users to adjust emissions temporally, geographically, and by category for effective control strategy analysis The pre-merged SMOKE files were categorized into biogenic, point, area, non-road, and on-road emissions, which were then converted for use with EMSPROC6, allowing for a comprehensive analysis of various emissions control strategies For more information on the CALGRID modeling platform, refer to Appendix XII of NHDES’ Modeling Protocol for the OTC CALGRID Screening-Level.

Modeling Platform for the Evaluation of Ozone

CALPUFF is a non-steady-state Lagrangian puff model designed to simulate the dispersion, transport, and chemical transformation of atmospheric pollutants The Vermont Department of Environmental Conservation (VTDEC) and the Maryland Department of the Environment (MDE) developed two parallel CALPUFF modeling platforms The VTDEC platform used meteorological observation data from the National Weather Service (NWS) to operate the CALMET meteorological model, while the MDE platform relied on MM5 meteorological inputs previously utilized for modeling related to ozone and Regional Haze State Implementation Plans (SIPs) These platforms were executed concurrently to assess the contributions of individual states to sulfate levels in Class I areas of the Northeast and Mid-Atlantic regions Detailed information on the CALPUFF modeling effort can be found in Appendix i.

EMISSIONS INVENTORY

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

The Planning: 8-hour Ozone, PM 2.5, and Regional Haze Programs designate 2002 as the baseline emission inventory year for regional haze, with both MANE-VU and Massachusetts adopting this year as a reference point Subsequent emission inventories for 2009 and 2018 were developed based on the 2002 baseline, accounting for projected emissions growth from increased economic activity alongside emissions reductions achieved through the implementation of control measures.

Many states have submitted their 2002 base year State Implementation Plan (SIP) inventories to the EPA as part of their requirements for ozone and particulate matter (PM) programs Notably, Massachusetts submitted its 2002 inventory to the EPA on January 31, 2008.

Emission inventories are dynamic documents that undergo continuous revisions to incorporate improved emission estimates as they emerge Consequently, while both the 2002 “SIP” inventories and the 2002 “modeling” inventories reflect emissions from the same year, they may present slightly varying emission estimates due to their differing timelines and intended purposes.

Accurate baseline and future emissions inventories are essential for the Regional Haze SIP process, as they inform air quality modeling simulations that assess the effectiveness of potential control measures on visibility improvement These inventories also facilitate pollution apportionment, which analyzes the contribution of different geographic regions and emission sectors to visibility impairment To ensure effective use in air quality modeling, the emissions inventories were processed with the SMOKE emissions pre-processor before being input into the CMAQ and REMSAD air quality models.

MANE-VU Regional Baseline Inventory

The 2002 baseline emissions inventory was established using the inventory submissions from state and local agencies to the EPA under the Consolidated Emissions Reporting Rule (CERR) MANE-VU, with the help of contractor E.H Pechan & Associates, coordinated and ensured the quality of this data.

In 2002, inventory data was collected and prepared for integration into the SMOKE emissions model Emissions data from non-MANE-VU regions within the modeling domain were sourced from various Regional Planning Organizations, including VISTAS, MWRPO, and CenRAP, to ensure comprehensive coverage of their respective areas.

The 2002 baseline inventory went through several iterations Work on Version 1 of the 2002 MANE-

The VU inventory project commenced in April 2004, with the final inventory and SMOKE input files completed by January 2005 Version 2, utilized from April to September 2005, incorporated revisions from various MANE-VU state and local agencies regarding point, area, and on-road categories Following this, Version 3 was developed and used from December 2005 to April 2006, which included further enhancements to these categories based on additional state feedback This version also featured the development of a biogenic inventory and a complete overhaul of the non-road inventory, reflecting updates made by the EPA to the NONROAD2005 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 xiii Emissions inventory data files are available on the MARAMA website at www.marama.org/visibility/EI_Projects/index.html.

Following the release of Version 3.0 of the MANE-VU 2002 inventory, Massachusetts updated its area source heating oil emissions inventory due to two key adjustments The sulfur percentage used for emission factors was revised from 1.0% to 0.3%, aligning with the correct value established by Massachusetts regulation 310 CMR 7.05(1) and (2), as the previous methodology incorrectly utilized an EPA default of 1% Additionally, the latest DOE-EIA 2002 fuel use data replaced the outdated figures from 2001 These modifications significantly impacted the 2002 SO2 emissions from area source heating oil combustion, leading to the release of revised 2002 PE and EM tables, which MACTEC incorporated into the 2009, 2012, and 2018 projection inventories.

Massachusetts submitted to EPA in January 2008 its comprehensive 2002 Base Year Emissions

The 2002 Inventory provides a baseline for the 8-Hour Ozone, Carbon Monoxide (CO), and Regional Haze State Implementation Plans (SIPs), estimating emissions for a typical summer day focusing on ozone precursors such as VOCs, NOx, and CO Additionally, CO emissions were estimated for a typical winter day to support the CO SIP The inventory includes annual emissions estimates for VOCs, NOx, CO, SO2, PM2.5, PM10, and NH3, which are essential for establishing a baseline for the Regional Haze SIP.

The complete MA 2002 Base Year Inventory is part of the Massachusetts 8-Hour Ozone Attainment

The Demonstration State Implementation Plan (SIP) can be accessed on the MassDEP website at http://www.mass.gov/dep/air/priorities/sip.htm This document provides a comprehensive narrative detailing the methodology used for developing the emission inventory, along with extensive data files that support the emission estimates.

Massachusetts originally submitted emissions inventory data electronically to the EPA National

The Emissions Inventory (NEI) system underwent revisions following Quality Assurance (QA) procedures, ensuring accurate data submission The point source submittal provided comprehensive facility-level information, including activity data segmented by level and annual emissions of VOCs, NO, CO, SO, PM, and NH Additionally, emissions data for point and area sources were compiled and submitted to the EPA in the mandated NEI format, with specific attention to winter day CO emissions.

In the 2002 Base Year Inventory, Massachusetts estimated typical summer and winter day emissions for both on-road and off-road mobile sources For annual emissions, the state collaborated with MANE-VU contractors to conduct twelve monthly model runs using EPA's MOBILE6.2 for on-road emissions and the NONROAD model for off-road emissions Massachusetts provided essential inputs, including monthly temperature, inspection/maintenance scenarios, daily vehicle miles traveled, vehicle registration data, and roadway speeds by county, to facilitate accurate modeling The annual emissions estimates produced by the MANE-VU contractor were integral to 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 the EPA National Emissions Inventory (NEI) was thoroughly accessed, analyzed, and summarized by MANE-VU contractors and modelers as a crucial step in the quality assurance process and modeling efforts for 8-hour ozone levels.

Emission Processor Selection and Configuration

The SMOKE Processing System is primarily designed for emissions processing rather than serving as a traditional emissions inventory preparation system that simulates emissions estimates from fundamental principles Its main function is to efficiently convert emissions inventory data into the formatted files necessary for photochemical air quality models While it focuses on emissions from stationary sources, SMOKE also generates emissions for on-road mobile and biogenic sources by utilizing the MOBILE6 and BEIS emissions models.

In the MANE-VU region, the New York State Department of Environmental Conservation (NYSDEC) and NESCUAM utilized the SMOKE (Version 2.1) processor to prepare modeling inventories for the CMAQ model For a comprehensive overview of the SMOKE input files, including area, mobile, fire, point, and biogenic emissions, as well as the model's configuration, please refer to Appendix xi.

Inventories for Specific Source Types

There are five emission source classifications in the emissions inventory:

Stationary point sources are significant emitters releasing more than a specified tonnage of pollutants annually, while stationary area sources contribute to emissions collectively despite individual sources being smaller, such as dry cleaners and agricultural activities Non-road mobile sources include equipment like lawn mowers and construction machinery that do not utilize roadways Emissions data for stationary point sources is monitored at the facility level, whereas emissions from other sources are aggregated at the county level, all prepared for modeling in line with EPA guidelines.

Point source emissions refer to emissions from significant individual sources, which typically operate under permits and have their emissions calculated regularly based on specific factors Major point sources, defined as those emitting 50 to 100 tons per year of criteria pollutants, 10 tons per year of a single hazardous air pollutant (HAP), or 25 tons per year of total HAPs, are inventoried annually In Massachusetts, smaller stationary point sources are also assessed, but on a triennial basis Point sources are categorized into Electric Generating Units (EGUs) and other non-EGU industrial sources.

Electric Generating Units

The base year inventory for Electric Generating Units (EGUs) utilized continuous emissions monitoring (CEM) data from 2002, which was reported to the EPA under the Acid Rain program, along with hourly emission data supplied by stakeholders This information offers detailed hourly emissions profiles essential for modeling sulfur dioxide (SO2) emissions.

NOx emissions from significant sources play a crucial role in estimating the emissions of other pollutants, including volatile organic compounds, carbon monoxide, ammonia, and fine particles This estimation is based on the measured emissions of sulfur dioxide (SO2) and nitrogen oxides (NOx).

Future inventories of Electric Generating Unit (EGU) emissions for 2009 and 2018 were created using the Integrated Planning Model (IPM) to project electric demand growth and the transition from older, inefficient, and more polluting power plants to newer, cleaner units The IPM model indicates that while a certain number of older plants will be replaced to accommodate future electricity needs and comply with state-specific NOx and SO2 limits, Massachusetts did not base its 2018 emissions inventory on the closure of any specific power plant when establishing reasonable progress goals.

The results of the IPM model should not be used as a reliable basis for predicting plant closures Consequently, initial modeling was conducted using the unchanged results from the IPM 2.1.9 model Nevertheless, before the Best and Final Modeling outlined in Appendix G, the future year EGU inventories were adjusted.

The IPM predictions were assessed by the MANE-VU permitting and enforcement team, who often deemed the anticipated shutdowns of oil-fired electric generating units (EGUs) in urban areas to be improbable Additional data was gathered from states involved in the VISTAS and MRPO initiatives to validate the model Consequently, adjustments were made to the IPM modeling outputs prior to the Best and Final modeling phase, incorporating insights from staff regarding the actual status of specific plants in the MANE-VU, VISTAS, and MRPO regions When discrepancies arose between the EGU operating status and the IPM predictions, the future emissions inventory was modified to align with the operational expectations of state personnel.

Following consultations within and between RPOs, MANE-VU has committed to implementing specific control measures outlined in the Long-Term Strategy This strategy includes a plan to achieve a 90 percent reduction in emissions from 167 stacks across MANE-VU, MRPO, and VISTAS, as detailed in the Long-Term Strategy section.

Non-EGU Point Sources

The 2002 baseline non-EGU emissions were primarily derived from reports submitted by state and local agencies for the Comprehensive Emissions Reporting Rule (CERR) E.H Pechan & Associates (Pechan), the contractor for MANE-VU, managed the quality assurance of the emissions inventory and prepared the essential files for data input.

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 xiii).

MACTEC Federal Programs, Inc developed projected non-EGU point source emissions for the MANE-VU region under contract with MARAMA Detailed methodologies used in this process are outlined in Appendix XIV, which focuses on the development of emissions projections for the years 2009, 2012, and 2018.

In the MANE-VU region, MACTEC projected future emissions for non-EGU point, area, and nonroad sources using state-supplied growth factor data where available In the absence of such data, they utilized the EPA’s Economic Growth and Analysis System Version 5.0 (EGAS 5.0) to create relevant growth factors for the non-EGU sector Additionally, MACTEC factored in applicable federal and state emissions control programs to estimate the expected emissions reductions under the OTB/OTW and BOTW scenarios.

Stationary area sources consist of numerous individual emitters, each contributing relatively small emissions, but collectively resulting in significant pollution Examples of these sources include dry cleaners, service stations, and heating fuel combustion To estimate area source emissions, an emission factor is multiplied by a relevant indicator of collective activity, such as fuel consumption, household count, or population size.

The area source emissions inventory submissions for the CERR established the foundation for the area source segment of the 2002 baseline inventory In a manner akin to the point source category, Pechan represented the interests of this data collection effort.

MANE-VU developed the area source modeling inventory based on CERR submissions, which was then quality assured by Pechan This inventory was enhanced with additional data, including MANE-VU-sponsored inventories for residential wood combustion and open burning For comprehensive details on the preparation of the MANE-VU 2002 baseline area source modeling emissions inventory, refer to Chapter III of Appendix XIII.

Future area source emissions for the MANE-VU region were projected by MACTEC, employing methodologies detailed in Section 3 of Appendix XIV Utilizing state-supplied data and the EGAS 5.0 growth factor model, MACTEC applied growth factors to the 2002 baseline area source inventory Additionally, the projections incorporated relevant control strategies for future years.

Non-road mobile sources refer to equipment capable of movement without utilizing roadways, including construction machinery, aircraft, railroad locomotives, and lawn and garden tools Emissions from most non-road mobile sources are assessed using the EPA's NONROAD model; however, this model does not account for emissions from aircraft, railroad locomotives, and commercial marine vessels.

The 2002 baseline modeling inventory was developed using state and local CERR submissions as its foundation For comprehensive information regarding the preparation of the 2002 baseline non-road inventory, please refer to Chapter IV of Appendix XIII.

MACTEC projected future non-road mobile source emissions for the MANE-VU region using EPA’s NONROAD2005 emissions model, as detailed in Section 4 of Appendix xiv The model incorporates calendar years as an input, allowing for the calculation of future emissions for non-road vehicles in specified projection years For vehicle types not covered by the NONROAD model, such as aircraft, locomotives, and commercial marine vessels, MACTEC utilized the 2002 baseline inventory alongside EPA's projected inventories for these categories under the Clean Air Interstate Rule (CAIR) to establish emission ratios and combined growth and control factors To align the CAIR projections with the necessary years for ozone, particulate matter, and regional haze analyses (2009, 2012, and 2018), MACTEC employed linear interpolation to generate the required factors.

The on-road emissions source category includes vehicles such as cars, trucks, buses, and motorcycles that operate on public roadways To calculate emissions from these mobile sources, the methodology involves multiplying vehicle-miles-traveled (VMT) data by emission factors derived from the EPA’s MOBILE6 model Unlike other emissions categories, the on-road mobile category necessitates the preparation of SMOKE model inputs instead of emissions data in SMOKE/IDA format For the 2002 baseline inventory, Pechan generated the required VMT and MOBILE6 inputs in SMOKE format.

NESCAUM created projected on-road mobile source inventories for the MANE-VU region to address ozone, particulate matter, and Regional Haze State Implementation Plan (SIP) requirements These inventories were specifically developed for the calendar years 2009, 2012, and beyond, aligning with other emissions source categories.

In 2018, MANE-VU member states were tasked with supplying Vehicle Miles Traveled (VMT) data and MOBILE6 model inputs for relevant calendar years NESCAUM utilized this data to compile and generate the necessary emissions model inputs for SMOKE/MOBILE6 Additional information on the projections for on-road mobile sources is available in Appendix XV.

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

The New York State Department of Environmental Conservation (NYSDEC) utilized the BEIS Version 3.12 within the SMOKE emissions processing model to estimate biogenic emissions of carbon monoxide (CO), nitrous oxide (NO), and volatile organic compounds (VOCs) For comprehensive information on biogenic emissions processing, refer to NYSDEC’s Technical Support Document 1c, which details emission processing for the Revised 2002 OTC Regional and Urban 12 km Base Case Simulations, published on September 19, 2006, as well as Chapter VI (Biogenic Sources) of the Technical Support Document.

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

Tables 6 and 7 provide a summary of emissions inventories for the MANE-VU region, detailing pollutant emissions (in tons per year) from various source categories for the years 2002 and projected for 2018 This data is essential for establishing reasonable progress goals for states with Class I areas and for formulating a long-term strategy to mitigate Massachusetts' contribution to regional haze in these areas.

Table 6: MANE-VU 2002 Emissions Inventory Summary (tons)

VOC NO x CO PM 2.5 PM 10 NH 3 SO 2

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

Table 7: MANE-VU 2018 Emissions Inventory Summary (in tons)

VOC NO x PM 2.5 PM 10 NH 3 SO 2

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 xiv

EGU Point Emissions: VISTAS_PC_1f IPM Run, Appendix xxiii

Summary of Massachusetts 2002 Base and 2018 Projected Emissions and Reductions44 7 UNDERSTANDING THE SOURCES OF VISIBILITY-IMPAIRING POLLUTANTS

Table 8 highlights the emissions inventories for Massachusetts in the base year of 2002 and the projected figures for 2018, including expected reductions It compares the emission summaries and reductions from MANE-VU for the same years, revealing that Massachusetts anticipates a 31 percent reduction in total regional haze pollutants from 2002 to 2018 This figure aligns closely with MANE-VU's overall reduction of 29 percent during the same timeframe, indicating that Massachusetts' emission reduction efforts are on track to fulfill the goals set by MANE-VU.

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

VOC NO x CO SO 2 PM 10 PM 2.5 NH 3 RH TOTAL

8 Massachusetts 2002 Baseline Emission Inventory Available online: http://www.mass.gov/dep/air/priorities/aqdata.htm

MANEVU 2002 WITH BIOGENICS 11 5,562,984 2,704,397 18,260,892 2,321,339 1,616,136 446,367 309,260 31,221,375 MANEVU 2018 WITH BIOGENICS 11 4,673,617 1,241,515 13,728,087 745,576 885,852 369,710 419,718 22,064,075

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/FutureEmissionsInventory.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

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/FutureEmissionsInventory.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 %.

7 UNDERSTANDING THE SOURCES OF VISIBILITY- IMPAIRING POLLUTANTS

This section examines the sources, amounts, and impacts of visibility-reducing pollutants released in the eastern United States and Canada, which play a crucial role in the regional haze affecting MANE-VU’s designated Class I areas.

Visibility-Impairing Pollutants

Fine particle formation, a key contributor to regional haze, is primarily driven by pollutants such as SO2, NOx, VOCs, NH3, PM10, and PM2.5 According to the MANE-VU Contribution Assessment finalized in August 2006, sulfate is identified as the most significant component of haze-forming fine particle pollution and the leading cause of visibility impairment in the Northeast On the 20 percent haziest days at MANE-VU Class I sites, sulfate comprises approximately 50% to 67% of total fine particle mass, resulting in 67% to 75% of visibility extinction Organic carbon ranks as the second largest contributor to haze Consequently, MANE-VU emphasizes that effective emissions management in the Northeast and Mid-Atlantic Regions must prioritize comprehensive regional SO2 control measures.

Visibility extinction quantifies how particles scatter and absorb light, measured in inverse mega-meters (Mm⁻¹) Analysis of baseline data from 2000 to 2004 reveals that sulfate significantly contributes to visibility extinction, as illustrated by the prominent yellow bar in Figure 17.

Figure 17: Contributions to PM 2.5 Extinction at Seven Class I Sites

The MANE-VU Contribution Assessment utilized various modeling techniques, air quality data analysis, and emissions inventory analysis to pinpoint the source categories and states affecting visibility impairment in MANE-VU Class I areas In 2002, it was estimated that emissions from within MANE-VU accounted for approximately 25-30 percent of the sulfate levels in these areas, with contributions from other regions, including Canada and areas beyond the modeling domain, also playing a significant role Table 9 presents the findings from one of the four methods used to evaluate state-by-state contributions to sulfate impacts.

REMSAD model) This table highlights the importance of emissions from outside the MANE-VU region Note that percentage contributions differ between methods

Table 9: Percent of Annual Average Modeled Sulfate Due to Emissions from Listed States 9

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

Moosehorn and Roosevelt Campobello, Maine (%)

Figures 19 and 20 from the Contribution Assessment illustrate a method for ranking states' contributions to sulfate in MANE-VU and adjacent Class I areas, utilizing data from 2002 This straightforward technique assesses the relative impact of emissions from designated point sources on specific receptor sites by calculating the ratio of annual emissions (Q) to the distance between the source and receptor (d).

The Q/d ratio is adjusted by a specific factor to consider the impact of prevailing winds and to convert measurement units, as detailed in the Contribution Assessment.

The Q/d technique results reveal the rankings of northern and southern Class I areas within the MANE-VU region, as illustrated in Figures 19 and 20 Figure 19 highlights the four northern Class I areas: Lye Brook, Great Gulf, Acadia, and Moosehorn, while Figure 20 focuses on Brigantine in the south and its neighboring Class I areas, Dolly Sods and Shenandoah, located in the VISTAS region Massachusetts is positioned tenth in annual average sulfate contributions to Northeast Class I areas and 23rd for Mid-Atlantic Class I areas For further insights into the methods used for identifying contributing states and regions, refer to the Contribution Assessment It is crucial to acknowledge the significant emissions from Canada and various states outside the MANE-VU region.

Figure 18: Ranked state percent sulfate contributions to Northeast Class I receptors based on emissions divided by distance (Q/d) results

Figure 19: Ranked state percent sulfate contributions to Mid-Atlantic Class I receptors based on emissions divided by distance (Q/d) results

O H P A W V N C C is an acronym representing various states including Maryland, Virginia, Kentucky, Georgia, New York, Illinois, Tennessee, Michigan, Alabama, New Jersey, Texas, Florida, Delaware, South Carolina, Missouri, Wisconsin, Massachusetts, Mississippi, Kansas, Minnesota, Oklahoma, Iowa, Louisiana, Connecticut, New Hampshire, Arkansas, Nebraska, Maine, Washington D.C., Rhode Island, and Vermont.

The ranking of emission contributions to visibility impairment in MANE-VU Class I areas is crucial for the consultation process outlined in Section 3 By utilizing results from the REMSAD model, MANE-VU established three key criteria to identify states and regions for effective consultation on regional haze issues.

1 Any state/region that contributed 0.1 àg/m 3 sulfate or greater on the 20 percent worst visibility days in the base year (2002)

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

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

The MANE-VU States determined that consultation would focus on any state or region that contributed at least 2 percent of the total sulfate observed during the 20 percent worst visibility days in 2002.

The seven figures illustrate states and regions that meet specific criteria for seven Class I areas, including Shenandoah and Dolly Sods in the VISTAS region affected by emissions from MANE-VU states The remaining five Class I areas are located within the MANE-VU region Additionally, the IMPROVE monitor at Great Gulf also monitors the Presidential Range - Dry River Wilderness, while the Moosehorn monitor covers Roosevelt Campobello.

International Park Each figure has three components:

The bar graph on the left illustrates the IMPROVE-monitored PM2.5 mass concentration (µg/m³) by constituent species for the baseline years 2000-2004, with the yellow section indicating 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.

The right segment features three maps that illustrate which states fulfill the specified criteria Additionally, the three arrows from the central bar graph highlight the thresholds necessary for state inclusion in these maps.

Connecticut, Rhode Island, Vermont, and the District of Columbia do not contribute 2 percent of sulfate emissions in any of the seven Class I areas Nevertheless, as members of the MANE-VU initiative, these regions are committed to implementing regional control measures to enhance visibility on the most polluted days and to prevent visibility degradation on clearer days.

According to the MANE-VU Contribution Assessment, emissions from Massachusetts negatively impact visibility in several Class I areas, including Acadia National Park, Great Gulf Wilderness, Lye Brook Wilderness, Presidential Range/Dry River Wilderness, and Moosehorn Wilderness.

Roosevelt/Campobello International Park studies show that emissions from Massachusetts contribute less than 0.1 µg/m³ of sulfate and account for only 2% of sulfate levels in the Brigantine, Shenandoah, and Dolly Sods Class I areas.

Figure 20: Modeled 2002 Contributions to Sulfate by State at Brigantine

Figure 21: Modeled 2002 Contributions to Sulfate by State at Lye Brook

Figure 22: Modeled 2002 Contributions to Sulfate by State at Great Gulf and Presidential

Figure 23: Modeled 2002 Contributions to Sulfate by State at Acadia

Figure 24: Modeled 2002 Contributions to Sulfate by State at Moosehorn and Roosevelt

Figure 25: Modeled 2002 Contributions to Sulfate by State at Shenandoah

Figure 26: Modeled 2002 Contributions to Sulfate by State at Dolly Sods

Emissions Sources and Characteristics

The primary pollutants contributing to regional haze in the eastern United States include sulfur oxides (SO), nitrogen oxides (NO), volatile organic compounds (VOCs), ammonia (NH), and particulate matter (PM) This information is derived from the MANE-VU 2002 Baseline Emissions Inventory, Version 2.0, which has since been updated by Version 3.0 released in April 2006 While the emissions inventory also records carbon monoxide (CO), it is excluded from this discussion as it does not play a role in regional haze formation.

The MANE-VU inventory, along with the 1996 EPA National Emissions Trends database (NET) and the 1999 National Emissions Inventory (NEI), provides valuable insights into emissions data This article highlights the trends observed across these three inventories: NET 1996, NEI 1999, and MANE-VU 2002, through detailed text and graphics.

Sulfur dioxide (SO2) is the main precursor pollutant for sulfate particles, which contribute significantly to light extinction in northeastern Class I areas, accounting for over 50% on clear days and up to 80% on hazy days Consequently, targeting SO2 emissions is crucial for mitigating regional haze in the eastern United States The majority of anthropogenic SO2 emissions originate from coal combustion, particularly from coal-burning power plants, which were responsible for two-thirds of total emissions nationwide in 1998 Data from the NEI for the MANE-VU states shows a decline in annual SO2 emissions from 1996 to 2002, largely due to the implementation of the second phase of the EPA Acid Rain Program, which reduced allowable emissions and expanded limits to more power plants.

Figure 27: Trends in Annual Sulfur Dioxide Emissions by State

The EPA's Emission Factor and Inventory Group (EFIG) compiles a comprehensive national database of air emissions, incorporating data from various state and local agencies, tribes, and industries This database tracks emissions from both stationary and mobile sources of criteria air pollutants and hazardous air pollutants (HAPs), providing annual emission estimates across all 50 states, the District of Columbia, Puerto Rico, and the Virgin Islands Emission data is available for individual facilities and county-level sources, covering the years 1985 to 2005 for criteria pollutants and 1996 to 2005 for HAPs The National Emission Inventory (NEI) plays a crucial role in supporting air dispersion modeling, regulatory development, air toxics risk assessments, and monitoring emission trends over time Prior to 1999, the National Emission Trends (NET) database was used to maintain estimates of criteria pollutant emissions.

Since 1999, the National Emissions Inventory (NEI) has been developing criteria and hazardous air pollutant (HAP) emissions data in a more integrated manner, replacing the previous National Toxics Inventory (NTI) and the National Emissions Trends (NET) databases.

11 EPA (2005) http://www.epa.gov/ttn/chief/eiinformation.html and MARAMA (2004) http://www.marama.org/visibility/2002%20NEI/index.html

In 2002, point sources were the leading contributors to SO2 emissions in the MANE-VU states, primarily due to stationary combustion for electricity generation, industrial energy, and heating Additionally, area sources, which include commercial and residential heating as well as smaller industrial facilities, also played a significant role in these emissions.

By contrast, on-road and non-road mobile sources make only a relatively small contribution to overall

SO2 emissions in the region (Appendix xvi).

Figure 28: 2002 Sulfur Dioxide Emissions (SO 2 ) by State

Bar Graph: Percentage Fractions of the Four Source Categories (-o-) Line Graph: Total State Annual Emissions (10 6 tpy)

Volatile organic compounds (VOCs) are significant contributors to ozone formation due to their volatility in the atmosphere While direct emissions of these gases are less concerning for regional haze, the focus shifts to the secondary organic aerosol (SOA) formed through condensation and oxidation processes Consequently, the VOC inventory is primarily relevant because of its organic carbon component, which plays a crucial role in PM2.5 pollution.

Organic carbon (OC) is the second largest contributor to fine particle mass and light extinction at northeastern Class I sites, following sulfate This term includes a diverse array of chemical compounds that can originate from both primary emissions and secondary atmospheric reactions At these sites, OC consists of pollutants from anthropogenic sources and biogenic hydrocarbons from vegetation Efforts to curb manmade organic carbon emissions have primarily focused on reducing summertime ozone levels in urban areas Future initiatives aimed at decreasing OC emissions will likely target fine particles and visibility improvement Massachusetts is committed to finding ways to lessen organic carbon emissions' impact on regional haze, but significant visibility enhancements will depend on reducing sulfate-related visibility issues.

The transport dynamics and source regions of organic carbon (OC) in northeastern Class I areas are more intricate than those for sulfate due to the diverse range of OC species and their varying transport characteristics Additionally, these species can engage in complex chemical reactions in the atmosphere Consequently, the organic carbon's role in visibility impairment at many Eastern Class I sites is influenced by both distant anthropogenic pollution and local sources, as well as biogenic emissions, particularly terpenes from coniferous forests.

The VOC emissions inventory is primarily influenced by mobile and area sources On-road mobile sources, such as gasoline passenger vehicles and diesel-powered heavy-duty vehicles, contribute to exhaust emissions and evaporative emissions from transportation fuels Additionally, area sources, including solvents, architectural coatings, and dry cleaners, along with point sources like industrial facilities and petroleum refineries, also play a significant role in VOC emissions.

Biogenic VOCs are crucial in rural Class I sites, where the oxidation of larger hydrocarbon molecules (seven or more carbon atoms) significantly contributes to light-scattering organic aerosol particles In contrast, smaller reactive hydrocarbons, while impactful on urban smog and ozone levels, have a limited role in organic aerosol formation However, high ozone levels can indirectly affect visibility by enhancing the oxidation of other hydrocarbons, including biogenic emissions Therefore, additional research is essential to assess the organic carbon contribution to regional haze in the Northeast and Mid-Atlantic states and to create more effective emissions inventories for visibility planning.

Figure 29: 2002 Volatile Organic Carbon (VOC) Emissions by State

Bar Graph: Percentage Fractions of the Four Source Categories (-o-) Line Graph: Total State Annual Emissions (10 6 tpy)

NOx emissions significantly impair visibility in the eastern U.S by producing light-scattering nitrate particles While nitrate typically constitutes a smaller portion of fine particle mass and light extinction compared to sulfate and organic carbon at northeastern Class I sites, its impact is more pronounced in urban areas and during winter Furthermore, NOx indirectly affects summertime visibility by contributing to ozone formation, which subsequently leads to the creation of secondary organic aerosols.

Since 1980, NOx emissions in the MANE-VU region at the state level have remained relatively stable, with a slight increase of 2 percent observed nationwide between 1989 and 1998 This rise is primarily attributed to industrial sources and the transportation sector, while power plant combustion sources have achieved modest emissions reductions during the same period Notably, most states within the MANE-VU region have seen a decline in NOx emissions.

Between 1996 and 2002, most states experienced a decline in NOx emissions, with notable exceptions being Massachusetts, Maryland, New York, and Rhode Island, which saw an increase in emissions in 1999 In Massachusetts, the rise in NOx emissions during this period was primarily attributed to higher emissions from off-road and stationary point sources, followed by a decrease in emissions by 2002, bringing levels below those recorded in 1996.

Between 1999 and 2002, significant reductions in emissions were primarily due to regulations in the on-road mobile category, such as Enhanced Inspection and Maintenance (I/M) and California Low Emission Vehicle (CA-LEV) programs Additionally, there were notable decreases in emissions from stationary point sources, particularly power plants, linked to the implementation of NOx Reasonably Available Control Technology (RACT).

13 EPA (2000) National Air Quality and Emission Trends Report, 1998, EPA 454/R-00-003, available online: http://www.epa.gov/oar/aqtrnd98/.

Figure 30: Trends in Annual Nitrogen Oxide (NO x ) Emissions by State

BEST AVAILABLE RETROFIT TECHNOLOGY

BART Overview

The BART program aims to minimize visibility-impairing emissions from large stationary sources that were exempt from specific emission control requirements when the Clean Air Act was amended in 1977 According to Section 169A, states are required to evaluate five statutory factors when establishing BART control requirements for eligible units.

• 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 June 2005, the EPA implemented the final Best Available Retrofit Technology (BART) rule, mandating states to create an inventory of potential sources that may require emission controls.

20 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.

21 “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

22 40 CFR Part 51 Appendix Y: Guidelines for BART Determinations Under the Regional Haze 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 23

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

Under 40 CFR 51.308(e)(2), states have the option to implement emissions trading programs or alternative measures for BART sources that achieve greater reasonable progress than traditional BART implementation If these alternative measures are primarily designed to meet other Federal or State requirements, a simplified approach can be utilized to demonstrate their effectiveness in surpassing BART's progress.

BART-Eligible Sources in Massachusetts

Massachusetts identified its BART-eligible sources by following the methodology outlined in the Guidelines for Best Available Retrofit Technology (BART) Determinations under the Regional Haze Rule, 40 CFR Part 51, Appendix Y A total of seventeen sources were deemed eligible for BART, which includes nine electric generating units (EGUs), four industrial/commercial/institutional (ICI) boilers and chemical processing plants, one municipal waste combustor (MWC), and three petroleum storage facilities.

Table 10: BART-Eligible Facilities in Massachusetts

1190012 Boston Generating - New Boston Unit 1 EGU

1190128 Boston Generating – Mystic Unit 7 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

(TMLP) - Cleary Flood Units 8 and 9 EGU

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

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

420086 Solutia Units 9 and 10 ICI Boilers/Chemical

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 participant in the Mid-Atlantic/Northeast Visibility Union (MANE-VU), which made a significant policy decision in June 2004 This decision mandates that all BART-eligible sources must undergo the BART review process without any exemptions Consequently, every BART-eligible source in Massachusetts is included in this comprehensive review, ensuring strict adherence to visibility improvement measures.

Pollutants Covered by BART

Massachusetts has identified SO2, NOx, and PM as the key visibility-impairing pollutants to target under its BART approach, excluding VOCs and ammonia due to challenges in estimating emissions and modeling The state is actively addressing VOCs through its ozone SIPs, aligning with discussions from the MANE-VU consultation process Consequently, Massachusetts did not pursue further BART considerations for the three petroleum storage facilities listed in Table 10.

Modeling of BART Visibility Impacts

MANE-VU performed modeling analyses on BART-eligible sources utilizing CALPUFF to establish a consistent regional framework for evaluating the potential visibility improvements from the implementation of BART controls (refer to Attachment R).

MANE-VU assessed the visibility effects of BART by utilizing 2002 emissions data for SO2, NOx, and PM10 from all BART-eligible sources in the region, including those in Massachusetts The modeling incorporated data from both the NWS and MM5 meteorological platforms to determine the maximum 24-hour impact of each BART-eligible unit.

The analysis revealed that the Class I area experienced the eighth highest visibility impact over a 24-hour period and in annual averages, primarily influenced by all BART sources These visibility impacts were assessed in comparison to the best 20 percent of days, the worst 20 percent of days, and the annual average natural background conditions Specifically, MANE-VU focused on the maximum visibility impact over a 24-hour timeframe for this evaluation.

20 percent best days In accordance with EPA guidance, which allows the use of either estimates of the

For BART modeling purposes, the MANE-VU initiative chose to utilize the more conservative estimate of the 20 percent best annual average natural background visibility conditions This approach ensures a greater level of protection for the region by accurately calculating the deciview difference contributed by individual sources.

MANE-VU's analysis of BART's potential improvement revealed that 98% of the cumulative visibility impact from eligible sources corresponds to a maximum 24-hour impact of 0.22 dv based on NWS-driven data and 0.29 dv from MM5 data Consequently, MANE-VU determined that an average impact range of 0.2 to 0.3 dv signifies a substantial effect on Class I areas, while sources with impacts below 0.1 dv are generally not expected to require additional BART controls.

Visibility Impacts of Massachusetts BART-Eligible Sources

The CALPUFF modeling results for BART-eligible facilities in Massachusetts, utilizing MM5 and NWS meteorological platforms, are presented in Tables 11 and 12 These findings illustrate the facility-wide impacts on the most affected day, compared to the 20 percent best natural background conditions, excluding VOC sources.

The emissions data was obtained from the MANE-VU 2002 Version 2 (Base A) inventory Subsequently, the MANE-VU 2002 Version 3 (Base B) emissions inventory was created, incorporating various updates from the OTC modeling committee.

Modeling the cumulative impacts of the entire MANE-VU population of units revealed that sources with impacts below the 0.1 dv level were insufficient to necessitate BART controls The analysis showed that the maximum 24-hour impact at any Class I area from all modeled units was minimal.

Table 11: CALPUFF Visibility Modeling Results using MM5 Platform

MM5- Impact on Worst Day Relative to 20 Percent Best Natural

Facility Class I Site Total SO4 NO3 PM10

Dominion - Salem Harbor Moosehorn Wilderness 0.982 0.886 0.151 0.001

General Electric Aircraft - Lynn Acadia 0.239 0.148 0.092 0.000

Table 12: CALPUFF Visibility Modeling Results using NWS Platform

NWS- Impact on Worst Day Relative to 20 Percent Best Natural

Facility Class I Site Total SO4 NO3 PM10

Dominion - Brayton Point Moosehorn Wilderness 7.200 6.206 1.754 0.026

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

New Boston Lye Brook Wilderness 0.028 0.000 0.027 0.001

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.

BART eligibility applies to specific sources within 26 categories that were operational between 1962 and 1977 and currently have the potential to emit over 250 tons per year of visibility-impairing pollutants The EPA allows these sources to establish federally enforceable permit limits to reduce emissions below this threshold, effectively exempting them from BART requirements General Electric – Lynn qualifies for BART consideration due to its potential emissions exceeding 250 tons per year, despite actual emissions being below this limit The facility has sought a permit cap to restrict NOx and SO2 emissions from Unit 3 to under 250 tons per year, while PM10 emissions are already below this threshold MassDEP plans to issue this permit cap, making it federally enforceable and subsequently removing General Electric – Lynn Unit 3 from BART eligibility.

Sources with De Minimis Impacts on Visibility

Under the 2005 Regional Haze Rule, states must evaluate their BART-eligible sources to decide if all should undergo BART determinations or if some can be exempted due to minimal expected impact on visibility in Class I areas MANE-VU has identified certain sources with a negligible potential for visibility improvement (less than 0.1 deciview) that do not warrant additional controls under BART, emphasizing that the cumulative effects of these sources are minimal.

The combined VU sources demonstrate a visibility impact that falls below the EPA's guidance threshold of ≤0.5 dv for determining contributions to visibility impairment Detailed modeling information is available in Appendix R, Section 4.1, with results documented in Appendices R-1 and R-2 Consequently, MANE-VU categorizes these sources as having a "de minimis visibility impact."

Massachusetts has updated its list of sources impacting visibility, now including Trigen – Kneeland, despite its initial modeled impact of 0.146 ddv (0.127 ddv from NO3) using the MM5 modeling platform This decision follows the identification of two significant errors in the 2002 input data used by MANE-VU: only Unit 3 is BART-eligible, yet Units 1-4 were included in the modeling, and the modeled NOx emissions from Unit 3 were inaccurately reported as 396 tons instead of the actual 96 tons With corrected 2002 NOx emissions, Massachusetts anticipates a total visibility impact of less than 0.1 ddv, leading to the classification of Trigen – Kneeland as a source with de minimis impact on visibility.

Table 13: Massachusetts Sources with De Minimis Visibility Impact

1190175 Eastman Gelatin ICI Boilers/Chemical Process

420086 Solutia ICI Boilers/Chemical Process

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

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

All sources mentioned are regulated by MassDEP pollution control requirements that limit sulfur dioxide (SO2) and nitrogen oxides (NOx) emissions Most sources, excluding Cleary Flood and Wheelabrator-Saugus, fall under 310 CMR 7.29, which sets emissions standards for power plants to control NOx, SO2, mercury, and carbon dioxide emissions from the state’s largest electric generating units (EGUs) Additionally, these sources, along with Cleary Flood, must comply with MassDEP's NOx RACT rules and the ozone season MassCAIR control program (310 CMR 7.32) Wheelabrator-Saugus is specifically regulated under 310 CMR 7.08(2) for municipal waste combustors and 310 CMR 7.19(9) for NOx RACT applicable to municipal waste combustors.

Massachusetts is implementing the Regional Haze Rule by developing a BART (Best Available Retrofit Technology) determination for Wheelabrator, while planning to address other BART sources through an alternative approach that aims to enhance progress towards achieving natural visibility conditions.

Table 14: Overview of BART-Eligible EGUs & MWCs

Subject to Presumptive BART? Primary

Natural Gas, Residual Oil Tangentially-fired 1963

EGU Brayton Point 2 yes Coal

EGU Brayton Point 3 yes Coal

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

Natural Gas Dry bottom wall-fired boiler 1976 EGU

Oil Natural Gas Tangentially-fired 1974

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

- 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 is home to one BART-eligible incinerator, the Wheelabrator – Saugus, featuring two mass burn incinerators equipped with water wall boilers, each capable of a heat input of 325 MMBtu/hr These boilers can generate up to 195,000 lbs/hr of steam at a pressure of 650 psi and a temperature of 850º F In 2002, the combined emissions from both incinerator units amounted to 84 tons of SO2 and 721 tons of NOx.

Wheelabrator – Saugus is regulated under MassDEP’s 1995 NOx Reasonably Available Control Technology (RACT) regulation, 310 CMR 7.19(9), and faces stricter NOx emissions limits set by the Municipal Waste Combustor regulation, 310 CMR 7.08(2), established in 1998 and amended in 2001 to align with EPA’s 1995 Emissions Guidelines for large Municipal Waste Combustors These guidelines, mandated by the Clean Air Act, focus on Maximum Achievable Control Technology (MACT) In 2006, the EPA updated its Emissions Guidelines for large Municipal Waste Combustors, reducing PM emission limits while keeping SO2 and NOx guidelines unchanged MassDEP intends to revise 310 CMR 7.08(2) in 2011 to incorporate the updated 2006 Emissions Guidelines.

MassDEP has committed in its 2008 Ozone SIP to conduct additional analysis as to whether existing

NOx controls remain a part of Reasonably Available Control Technology (RACT), with plans to introduce stricter NOx limits in 310 CMR 7.19 during the revisions of 310 CMR 7.08(2) Wheelabrator – Saugus must adhere to any enhanced emissions limits set forth in both 310 CMR 7.08(2) and 310 CMR 7.19.

Wheelabrator utilizes advanced NOx control technologies, including low-NOx burners and Selective Non-Catalytic Reduction (SNCR), to manage emissions effectively The facility operates under a permitted NOx emission limit of 205 ppm, as specified in 310 CMR 7.08(2)(f)3, which is monitored continuously through emissions monitors (CEMs) This regulatory limit aligns with the EPA’s Emissions Guidelines from both 1995 and 2006 However, MassDEP asserts that existing NOx control technologies have the potential to achieve emissions levels even lower than those outlined in the EPA’s MACT standards.

At the request of MassDEP, Wheelabrator conducted furnace gas temperature profiling and SNCR optimization testing to assess the potential for further reducing NOx emissions while minimizing ammonia slip The results indicated that a target of 185 ppm (dry, 7% O2) for NOx emissions could be achieved at current boiler operating loads of approximately 150,000 lbs/hr using the existing SNCR system Following a review of Wheelabrator – Saugus’ current control technologies, MassDEP proposes that a NOx emissions rate target of 185 ppm for each unit qualifies as Best Available Retrofit Technology (BART).

As described in Tables 11 and 12, Wheelabrator – Saugus’ visibility impacts on Class I areas based on

In 2002, emissions were recorded at 0.232 ddv and 0.179 ddv, depending on the modeling platform, which are near MANE-VU's de minimis level of 0.1 ddv and significantly below the EPA's threshold of 0.5 ddv for assessing contributions to visibility impairment Consequently, detailed visibility modeling was not conducted to evaluate the benefits of achieving a lower NOx emission rate; however, MassDEP anticipates a modest improvement in visibility from reduced NOx emissions.

MassDEP considers low-NOx burners and SNCR to be the leading technologies for municipal waste combustors They believe that, through optimization, these technologies can effectively minimize emissions without the need for additional technologies or costs.

NOx emissions limit lower than the current federal MACT limit

MassDEP is set to coordinate permit modifications for Wheelabrator-Saugus to align with the upcoming BART emissions rate and revisions to 310 CMR 7.08(2) and 310 CMR 7.19 In light of potential changes in 2011 that may introduce a presumptive NOx RACT emission limit below 185 ppm, Wheelabrator-Saugus might need to conduct a source-specific RACT analysis Consequently, MassDEP will mandate updates to Wheelabrator's emissions control plan once the regulations are finalized, ensuring the NOx limit becomes federally enforceable This permit modification is required by July 1, 2013.

Wheelabrator utilizes a spray dry absorber (SDA) with lime slurry injection to control SO2 emissions, adhering to a permitted limit of 29 ppm (by volume at 7 percent oxygen dry basis) or a 75 percent reduction from uncontrolled levels, as specified under 310 CMR 7.08(2)(f)2 Compliance is measured based on a 24-hour geometric mean, aligning with MassDEP's regulatory standards, which are consistent with EPA’s Emissions Guidelines from both 1995 and 2006.

CALPUFF modeling indicates that the visibility impacts from 2002 SO2 emissions at Wheelabrator - Saugus are minimal, with effects below 0.1 deciview (ddv) on the worst day at any Class I area The Massachusetts Department of Environmental Protection (MassDEP) has concluded that implementing additional SO2 controls is unnecessary due to the high costs involved, as Wheelabrator already employs control equipment that meets Maximum Achievable Control Technology (MACT) standards The potential visibility improvement is considered negligible, at less than 0.1 ddv.

Each of Wheelabrator’s units are equipped with 10-module fabric filters (baghouses) and are subject to

The 310 CMR 7.08 (2)(f)2 sets a particulate matter (PM) emissions limit of 27 mg/dscm at 7 percent oxygen (dry basis), aligning with the EPA’s 1995 Emissions Guidelines for municipal waste combustors (MWCs) In 2006, the EPA revised the PM emissions guideline to 25 mg/dscm The Massachusetts Department of Environmental Protection (MassDEP) plans to adopt this lower limit in upcoming revisions to 310 CMR 7.08(2) and considers it to represent the Best Available Retrofit Technology (BART) Consequently, Wheelabrator – Saugus will be obligated to meet the new, lower PM emissions standard once finalized.

MassDEP has concluded that a particulate matter (PM) emissions limit below 25 mg/dscm is unnecessary due to the high costs associated with installing additional PM controls Wheelabrator already employs control equipment that meets MACT standards, and the potential improvement in visibility from further reductions would be minimal.

Energy and Non-air Quality Impacts

The proposed BART for Wheelabrator-Saugus presents no significant energy or non-air quality impacts A key environmental advantage of implementing a lower NOx emissions limit is the enhancement of visibility and a reduction in acid deposition across Massachusetts and Northern New England By decreasing ambient NOx concentrations, the plan aims to mitigate acidification in lakes, streams, and soils, prevent material damage to buildings, and curb the eutrophication of both inland and coastal waters.

Massachusetts, as part of MANE-VU, has identified that BART-eligible sources with feasible control options must either reduce emissions before July 1, 2013, or agree to a federally enforceable permit limitation or retirement date before the implementation of this SIP.

Schedule for BART determination and Federal Enforceability

According to 40 CFR 51.308(e)(1)(iv), Best Available Retrofit Technology (BART) controls must be implemented for each relevant source within five years of EPA State Implementation Plan (SIP) approval The Massachusetts Department of Environmental Protection (MassDEP) mandates that Wheelabrator adhere to the reduced nitrogen oxides (NOx) and particulate matter (PM) emissions limits as quickly as possible, with a final compliance deadline set for March 31.

2014 BART determinations are required to be federally enforceable MassDEP will require that

Wheelabrator-Saugus modify its emissions control plans pursuant to 310 CMR 7.08(2) and 310 CMR 7.19 to make the lower BART NOx and PM emissions rates state and federally enforceable.

Alternative to BART

The EPA's Regional Haze Rule allows states to adopt alternative measures, including federal options, instead of meeting individual source BART requirements States can set a BART benchmark to determine the emissions reductions expected from BART and then evaluate the effectiveness of the alternative measures If the reductions from these alternatives exceed the BART benchmark, states can conclude that the alternatives provide greater reasonable progress in improving air quality than traditional BART methods.

The ten BART EGUs located at Brayton Point, Canal Station, Cleary Flood, Mystic Station, and Salem Harbor are subject to the EPA's proposed "Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate Matter and Ozone," commonly referred to as the "Transport Rule." Published on August 2, 2010, this regulation aims to lower emissions of sulfur dioxide (SO2) and nitrogen oxides (NOx) from electric generating units (EGUs) in the eastern United States.

The proposed Transport Rule in the United States will extend its emissions reductions to non-BART EGUs at certain facilities and additional EGUs in Massachusetts According to MassDEP, the emissions reductions achieved through the Transport Rule will surpass those that would be obtained by applying BART solely to BART-eligible EGUs, thereby facilitating greater reasonable progress in emissions management.

The following sections establish a BART benchmark, provide estimated emission reductions that will be achieved by the proposed Transport Rule, and show that

MassDEP recognizes that EPA’s Transport Rule is a proposal and that various aspects of the proposal may change in the final rule, including the level of NOx and

SO2 emissions reductions that Massachusetts EGUs must achieve However,

MassDEP asserts that the emissions budgets proposed by the Transport Rule for Massachusetts are significantly stricter than the BART Benchmark, ensuring greater reductions even if the final budgets are less stringent than those currently suggested The Transport Rule is projected to achieve reductions of 57,961 tons of SO2 and 21,155 tons of NOx beyond what BART can accomplish Once finalized, MassDEP will assess the emissions budgets in comparison to the BART benchmark to confirm that the Transport Rule delivers superior reductions.

Massachusetts has adopted a stringent Best Available Retrofit Technology (BART) standard, aligning with EPA guidelines and the emissions limits recommended by the MANE-VU Workgroup for sulfur dioxide (SO2) and nitrogen oxides (NOx) This approach considers the cost-effective control technologies currently available for electric generating units (EGUs).

The EPA's Guideline for BART Determinations (40 CFR 51, Appendix Y) sets forth presumptive emission limits for sulfur dioxide (SO2) and nitrogen oxides (NOx) specifically for power plants with a capacity of 750 megawatts (MW) or more Notably, four facilities—Brayton, Canal, Mystic, and Salem—exceed this capacity.

750 MW, while Cleary Flood is below 750 MW Seven of the BART-eligible units are oil-fired, while Brayton Point Units 1, 2, and 3 are coal-fired.

The EPA recommends that states limit the sulfur content of fuel oil burned in oil-fired electric generating units (EGUs) at 750 MW power plants to 1 percent or less by weight for effective SO2 control Additionally, for NOx control in power plants exceeding 750 MW capacity that utilize Selective Non-Catalytic Reduction (SNCR) or Selective Catalytic Reduction (SCR) part of the year, the EPA suggests that implementing these controls year-round constitutes Best Available Retrofit Technology (BART).

For each uncontrolled coal-fired EGU greater than 200 MW at a 750 MW power plant, EPA recommends SO2control levels of either 95% or 0.15 lbs/MMBtu For

The EPA advises the year-round implementation of Selective Non-Catalytic Reduction (SNCR) or Selective Catalytic Reduction (SCR) systems to manage NOx emissions For coal-fired electric generating units (EGUs) lacking post-combustion NOx controls, the EPA has established presumptive NOx emission rates that vary based on the design of the boiler and the type of coal utilized.

As part of the regional consultation process, the MANE-VU BART Workgroup established recommended BART emission limits for various types of sources

The NESCAUM Five-Factor Analysis of BART-Eligible Sources, detailed in Appendix R, presents recommended BART emission limits for non-CAIR Electric Generating Units (EGUs) as outlined in Table 15 In Massachusetts, the BART-eligible units fall under the category of non-CAIR, highlighting the importance of these recommendations for local air quality management.

Massachusetts is currently only subject to the CAIR NOx ozone season program However, under the proposed Transport Rule, the state will no longer be included in the ozone season NOx program but will be required to comply with the annual SO2 regulations.

The MANE-VU BART workgroup has suggested that the BART emission limits should align with the EPA's recommended limits for sulfur dioxide (SO2) emissions from coal, while being more stringent than the EPA's recommendations for SO2 from oil and for nitrogen oxides (NOx).

Massachusetts used the MANE-VU recommended emission limits to establish the BART benchmark.

Table 15: MANE-VU BART workgroup recommended BART emission limits for SO 2 and NO x for non-CAIR EGUs

95% control or 0.15 lb/MMBtu (coal) and 0.33 lb/MMBtu (oil) o In NOx SIP call area, extend use of controls to year-round o 0.1 – 0.25 lb/MMBtu, depending on boiler and fuel type

Massachusetts’ SO 2 and NO x Program for Alternative BART

The EPA's proposed Transport Rule is expected to result in significantly higher reductions of SO2 and NOx emissions compared to relying solely on the installation and operation of BART Notably, Tables 16 and 17 provide details on Massachusetts sources, highlighting ten units that are eligible for BART and are also subject to the proposed Transport Rule.

The EPA's proposed Transport Rule aims to reduce interstate emissions of SO2 and NOx across 32 eastern states, ensuring that downwind areas can meet the 1997 and 2006 PM2.5 and ozone NAAQS This initiative focuses on fossil-fuel fired electric generating units (EGUs) with capacities of 25 megawatts or more, implementing Federal Implementation Plans (FIPs) to manage emissions For Massachusetts, the proposed annual limits are set at 7,902 tons of SO2 and 5,960 tons of NOx, with specific allowances for new units The Rule also facilitates intrastate trading and limited interstate trading of emissions allowances.

Analysis of Massachusetts’ Alternative BART Program for SO 2

Table 16 presents the actual annual SO2 emissions for all units under the Transport Rule for the years 2002 and 2009 It also includes the SO2 Transport Rule allocations, which remain unchanged for 2012 and 2014, alongside the BART benchmark potential emission levels These levels were determined by multiplying the recommended BART emission rates, expressed in lb/MMBtu, by the design capacity of each unit measured in MMBtu/hr.

8760 hrs/year as follows: For Brayton Point Units 1-3, the only coal-burning units, the MANE-VU BART workgroup’s recommended BART emission rate of 0.33 lb/MMBtu was used.

Table 16: Sources Addressed in SO 2 Alternative BART

(BART-eligible units are highlighted)

Fore River Station 11 Not Operating 3.65 0.00

Fore River Station 12 Not Operating 2.98 0.00

As shown in Table 17, the SO2 emission reductions that will result from the

Transport Rule in 2012/14 compared to 2002 actual emissions equals 77,765.35 tons (85,429.35 tons minus 7,664 tons), whereas the SO2 reductions that would result from the BART benchmark compared to 2002 actual emissions equals

19,804.41 tons (68,327.80 tons minus 48,523.39 tons) Therefore, the estimated

SO2reductions from the Transport Rule are 57,960.94 tons more than estimated reductions from BART alone

The Transport Rule's emissions reductions outlined in Tables 16 and 17 do not consider intrastate and interstate trading impacts While intrastate trading affects the distribution of emissions reductions among affected electric generating units (EGUs) within a state, it does not influence the overall expected emissions reduction In contrast, interstate trading allows for emissions to exceed the 1-year limit of 1,700 tons and the 3-year limit of 981 tons for SO2, alongside the annual budget of 7,664 tons starting in 2014 and 2016, respectively Nevertheless, the emissions reductions achieved through the Transport Rule significantly surpass the estimated reductions that would result from the Best Available Retrofit Technology (BART) alone.

Table 17: SO 2 Alternate BART Summary (tons)

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

(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.

Conclusion

The EPA's proposed Transport Rule for SO2 and NOx is expected to enhance visibility more effectively than the BART program, as it will result in greater emissions reductions and encompass a broader range of sources than those eligible under BART in Massachusetts Additionally, the geographic coverage of sources included in the Transport Rule aligns with that of the BART-eligible units in the state.

From a regional haze perspective, SO2is the pollutant with the most impact on visibility, and

MassDEP has effectively decreased SO2 and NOx emissions through its regulations, with the proposed Transport Rule set to enhance these reductions further Additionally, the visibility impact from primary PM emissions from Massachusetts' BART-eligible units is minimal, indicating that further controls in this area are unnecessary.

REASONABLE PROGRESS GOALS

According to 40 CFR Section 51.308(d)(1), each Class I area within a State or Tribe is required to establish reasonable progress goals, measured in deciviews, to advance towards achieving natural visibility The EPA provided guidance on this matter on June 7, 2007 These goals should aim to enhance visibility on the most impaired days while ensuring that visibility does not worsen on the least impaired days throughout the State Implementation Plan (SIP) period Additionally, the State or Tribe must evaluate how many years it would take to reach natural visibility conditions if improvements continue at the pace indicated by the established 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

In cases where a State cannot reach an agreement with another State or group of States regarding reasonable progress towards visibility improvement, it is required to outline the actions taken to address the disagreement in its submittal The Administrator will consider this information when evaluating the State's implementation plan to assess whether its visibility improvement goals align with reasonable progress towards achieving natural visibility conditions.

When establishing the reasonable progress goal, the Class I State/Tribe must evaluate four key factors: compliance costs, the time required for compliance, environmental impacts (both energy-related and non-air quality), and the remaining useful life of affected sources Additionally, the State/Tribe needs to demonstrate consideration of the uniform rate of progress and the necessary emission reduction measures for the implementation plan's duration If the proposed rate of progress is slower than the uniform rate, an assessment must be made regarding the number of years needed to achieve natural conditions, assuming visibility improvements continue at the proposed rate.

Massachusetts lacks Class I areas, so it did not establish reasonable progress goals; however, it engaged in consultations with neighboring states, including Maine, New Hampshire, and Vermont, which have Class I areas affected by emissions originating from Massachusetts sources.

Massachusetts agrees with the reasonable progress goals established by these states through the MANE-

VU planning process for their Class I areas.

To establish reasonable progress goals, MANE-VU compared baseline visibility conditions to natural visibility in each Class I area The analysis focused on the 20 percent worst days, determining the uniform rate of progress necessary to achieve natural visibility by 2064 Table 21 details the baseline and natural visibility, along with the required progress rates for MANE-VU Class I areas impacted by emissions from Massachusetts sources Visibility measurements are expressed in deciviews (dv), where a decrease of one deciview indicates a slight improvement in visibility.

Table 21: Uniform Rate of Progress Calculation (all values in deciviews)

Uniform Annual Rate of Improvement

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 29

The reasonable progress goals set for Class I areas are anticipated to yield more significant visibility enhancements compared to the uniform rate of progress outlined in Table 21 A summary of these goals can be found in Tables 22 and 23.

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

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

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

LONG-TERM STRATEGY

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

• 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 has pinpointed effective measures to reduce emissions that impact visibility in Class I areas within the MANE-VU region, aiming for implementation by 2018 or sooner The subsequent section outlines the technical foundation for the long-term strategy, detailing the identification of potential emission reduction approaches.

MANE-VU conducted a comprehensive review of various control measures aimed at reducing emissions that contribute to visibility impairment in Class I areas This initiative began in late 2005 and was part of a broader effort to identify strategies for reducing ozone pollution The proposed regional haze control measures were developed in alignment with the 2018 milestone objectives.

The Commission (OTC) has engaged a contracting firm to analyze options for ozone and regional haze control measures They supplied the contractor with a comprehensive “master list” of around 900 potential control measures, informed by past state implementation plan experiences Additionally, with support from an internal OTC workgroup, the contractor identified relevant regional haze control measures for further evaluation by MANE-VU.

MANE-VU established a preliminary list of control measures to address regional haze, which includes implementing beyond-CAIR sulfate reductions from electric generating units (EGUs), utilizing low-sulfur heating oil for residential and commercial use, and enforcing controls on industrial, commercial, and institutional (ICI) boilers that are coal and oil-fired Additionally, the measures target emissions from lime and cement kilns, residential wood combustion, and outdoor burning activities, including outdoor wood boilers.

The next phase in selecting regional haze control measures involved refining the interim list The CAIR+ Report (Appendix xix) outlines the cost analysis for additional SO2 and NOx controls at electric generating units (EGUs) in the Eastern U.S Additionally, the Reasonable Progress Report (Appendix xx) evaluates control measures for EGUs and other analyzed source categories Further insights are provided in the NESCAUM document titled "Assessment of Control Technology Options for BART-Eligible Sources: Steam Electric Boilers, Industrial Boilers, Cement Plants, and Paper and Pulp Facilities" (Appendix xxi).

The beyond-CAIR EGU strategy remains a priority due to the significant impact of EGU sulfate emissions on visibility in MANE-VU Class I areas Additionally, a low-sulfur oil strategy gained traction following a NESCAUM conference with refiners and fuel-oil suppliers, indicating its feasible implementation by 2014 This strategy unifies control measures for low-sulfur heating oil and oil-fired ICI boilers, addressing both residential and commercial heating needs, as well as oil-fired ICI boiler sources.

In March 2007, during an internal consultation meeting, MANE-VU member states evaluated and refined an interim list of control measures They concluded that the limited presence of coal-fired ICI boilers in the region does not warrant a regional control strategy, suggesting instead that individual states should address this sector Additionally, control of lime and cement kilns, which are also scarce in the MANE-VU area, will likely be managed through each state’s BART determination process While residential wood burning and outdoor wood boilers are still relevant for states concerned about localized visibility impacts, the emissions primarily consist of organic carbon and direct particulate matter Ultimately, outdoor wood burning was deemed more suitable for individual state regulation due to challenges related to enforceability and the effectiveness of existing regulations.

Technical Basis for Strategy Development

According to 40 CFR Section 51.308(d)(3)(iii), states must provide a technical basis for their emission reduction apportionment to meet reasonable progress goals in Class I areas impacted by their emissions Massachusetts utilized technical analyses from MANE-VU to illustrate that its coordinated emission reductions, alongside those from neighboring states, effectively meet the reasonable progress goals in the affected Class I areas.

This SIP outlines the required emission reductions to achieve reasonable progress goals in each Class I area impacted by Massachusetts, with detailed information provided in the subsequent sections and related documents.

• Contributions to Regional Haze in the Northeast and Mid-Atlantic United States (called the

• 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 v)

• MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Control Measure Benefits (Appendix vi)

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

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

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

• Assessment of Control Technology Options for BART-Eligible Sources: Steam Electric

Boilers, Industrial Boilers, Cement Plants and Paper and Pulp Facilities (Appendix xxi)

• The Nature of the Fine Particle and Regional Haze Air Quality Problems in the MANE-VU Region: A Conceptual Description (Appendix xxii)

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

To develop a long-term strategy for reducing regional haze, Massachusetts collaborated with the Ozone Transport Commission and MANE-VU to evaluate various emission reduction strategies targeting multiple sources of SO2 and other pollutants In compliance with 40 CFR 51.308(d)(1), the state considered several key factors in creating its strategy Based on available emissions data and potential impact information, the MANE-VU Reasonable Progress Workgroup identified specific source categories for in-depth analysis to inform the state's efforts to achieve reasonable progress in reducing regional haze.

• Coal and oil-fired electric generating units (EGUs);

• Point and area source industrial, commercial and institutional boilers;

• 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.

1.2.1.46 2018 Emission Reductions Due to Ongoing Air Pollution Controls

According to 40 CFR Section 51.308(d)(3)(v)(A), states must account for emission reductions from ongoing pollution control initiatives In formulating its long-term strategy, Massachusetts evaluated emission control programs enacted from the 2002 baseline to 2018 Many of these programs reflect commitments made by Massachusetts and other states to enforce air pollution control measures for electric generating unit (EGU) point sources, non-EGU point sources, and area sources These control measures align with those previously outlined in existing regulations.

The 2018 emissions inventory was utilized in modeling efforts, highlighting that although the implemented control measures were not specifically aimed at enhancing visibility, they effectively target pollutants that negatively impact visibility in MANE-VU Class I Areas.

The 2018 "beyond on the way" (BOTW) emissions inventory by MANE-VU incorporates both existing emission controls and those anticipated to be implemented by 2009 This inventory builds on the MANE-VU 2002 Version 3.0 and the 2018 on the books/on the way (OTB/OTW) inventory, reflecting expected emission reductions across various RPOs The term "beyond on the way" signifies the inclusion of ozone SIP control measures that are not yet finalized in certain states, as well as potential controls for Regional Haze SIPs still under consideration Due to the uncertainty surrounding the enforceability of these measures, Massachusetts is actively assessing their feasibility for adoption by 2018, with an evaluation to be detailed in its 2013 progress report.

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 vi)

• Development of Emissions Projections for 2009, 2012, and 2018 for Non-EGU Point, Area, and Non-road Sources in the MANE-VU Region (Appendix xiv)

• Documentation of 2018 Emissions from Electric Generating Units in the Eastern U.S for MANE-VU’s Regional Haze Modeling (Appendix xxiii)

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

By 2015, SO2 and NOx emissions in the eastern United States were projected to decrease significantly, with SO2 emissions reduced by over 70% and NOx emissions by more than 60% compared to 2003 levels However, the Clean Air Interstate Rule (CAIR) was vacated by the U.S Court of Appeals on July 11, 2008, leading to a remand to the EPA for a remedy on December 23, 2008 As a result, CAIR remains effective until the EPA finalizes its proposed Transport Rule Future emissions from electric generating units (EGUs) were predicted using the Integrated Planning Model (IPM®) following the implementation of these regulations.

CAIR served as a foundational model for the 30 Class I states in the MANE-VU region to assess their progress towards reasonable progress goals in their Regional Haze State Implementation Plans (SIPs), and this modeling remains applicable in the short term Future modeling by MANE-VU will integrate the specifics of the EPA's Transport Rule once it is finalized.

The report titled "Documentation of 2018 Emissions from Electric Generating Units" (Appendix xxiii) outlines modifications to the output of IPM® aimed at accurately reflecting expected controls These modifications take into account various control measures that were considered during the update process.

Connecticut EGU Regulations: Connecticut adopted the following regulations governing EGU emissions:

Connecticut State Agencies regulations (RCSA) section 22a-174-19a impose a limit on sulfur dioxide (SO2) emissions, capping the rate at 0.33 pounds of SO2 per million British thermal units (MMBtu) for fossil fuel-fired electric generating units (EGUs) exceeding 15 megawatts (MW) that are also classified as Title IV sources This regulation has been in effect since 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:

1 Reg 1144, Control of Stationary Generator Emissions, SO2, PM, VOC and NOx emission control, Statewide, Effective January 2006.

2 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.

3 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:

The IPM® model initially considered the implementation of the EPA's Clean Air Mercury Rule (CAMR), which has since been vacated by the courts However, adjustments to predicted SO2 emissions from electric generating units (EGUs), informed by state-specific regulations and comments on SO2 controls, are expected to significantly influence the air quality modeling analysis for this State Implementation Plan (SIP) MANE-VU asserts that these state-specific adjustments enhance the reliability of the emissions inventory and improve the dependability of the modeling results.

Chapter 145 of the NOx Control Program establishes stringent limits on nitrogen oxide (NOx) emissions for fossil fuel-fired units exceeding 25 MW, constructed prior to 1995 Specifically, it mandates a NOx emission rate of 0.22 lb NOx/MMBtu for units with a heat input capacity between 250 and 750 MMBtu/hr, and a more stringent limit of 0.15 lb NOx/MMBtu for units with a heat input capacity greater than 750 MMBtu/hr This regulation was implemented in 2007 to enhance air quality and reduce environmental impact.

Massachusetts EGU Regulations: Massachusetts adopted 310 CMR 7.29, Emissions Standards for

The regulations affect six major fossil fuel-fired power plants in Massachusetts, specifically Brayton Point (Units 1-4), Mystic (Units 4-7 and 81-94), NRG Somerset (Unit 8), Mount Tom (Unit 1), Canal Station (Units 1 and 2), and Salem Harbor (Units 1-4).

• 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:

1 Chapter Env-A 2900, which caps NOx emissions on all existing fossil steam units to 3,644 tons

In 2007, regulations were established to limit emissions from existing fossil steam units, capping nitrogen oxides (NOx) at 7,289 tons per year and sulfur dioxide (SO2) at 5,425,866 tons per year.

2 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:

1 Repower Bergen Unit #2 to combined cycle by December 31, 2002.

2 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.

Additional Reasonable Strategies

To achieve reasonable progress goals under 40 CFR 51.308(d)(1), Massachusetts and the MANE-VU states identified additional emission control measures to mitigate regional haze as part of a unified strategy The proposed measures were incorporated into the regional strategy adopted by MANE-VU on June 20, 2007, to meet the reasonable progress goals set by Class I states This strategy, outlined in the MANE-VU "Ask," targets coordinated actions in multiple states, including the MANE-VU states, Georgia, Illinois, Indiana, Kentucky, Michigan, North Carolina, Ohio, South Carolina, Tennessee, Virginia, and West Virginia.

The MANE-VU Class I states have decided to incorporate expected emission reductions from Canada into the modeling for establishing reasonable progress goals, alongside proposed emission controls in the U.S This decision was informed by evaluations conducted throughout the consultation process Notably, the modeling considers the shutdown of six coal-burning electric generating units (EGUs) in Canada, which have a total capacity of 6,500 MW, to be replaced by nine natural gas turbine units equipped with selective catalytic reduction (SCR) technology by 2018.

Rationale for Determining Reasonable Controls

According to 40 CFR 51.308(d)(1)(i)(A), states must consider several key factors when establishing reasonable progress goals for each Class I area These factors include compliance costs, the time needed for compliance, the environmental impacts—both energy-related and non-air quality—and the remaining useful life of affected sources The State Implementation Plan (SIP) must provide a demonstration of how these "four statutory factors" were evaluated in setting these goals, as mandated by the Clean Air Act.

MANE-VU's Contribution Assessment revealed that particulate sulfate from SO2 emissions is the primary cause of visibility impairment across all sites and seasons in the base year Although addressing other pollutants like organic carbon and NOx is necessary for meeting national visibility goals, prioritizing SO2 reduction is likely to provide the most immediate benefits Consequently, it is essential to implement additional measures aimed at reducing SO2 emissions to establish reasonable progress towards these goals.

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

33 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.

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 identified the key source categories contributing to visibility degradation in MANE-VU Class I areas A collaborative effort between the Ozone Transport Commission and MANE-VU led to the evaluation of numerous potential control measures, resulting in the identification of several strategies aimed at reducing SO2 emissions for further investigation.

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

The Reasonable Progress Report (Appendix T) provides an analysis of four statutory factors across five major source categories, including Electric Generating Units (EGUs), Industrial, Commercial, and Institutional (ICI) boilers, cement kilns, heating oil, and residential wood combustion Table 24 summarizes the findings of MANE-VU’s Reasonable Progress Report, highlighting the impact of these sources on air quality.

On June 20, 2007, the MANE-VU states reviewed the four-factor analysis from the Reasonable Progress Report and collaborated on the necessary measures They adopted the MANE-VU "Ask" statements, which outline the control measures aimed at enhancing visibility in the region and were incorporated into the modeling for establishing reasonable progress goals.

Table 24: Summary of Results from the Four-Factor Analysis

Primary Regional Haze Pollutant Control Measure(s)

2006 dollars (per ton of pollutant reduction) Compliance

Energy and Non-Air Quality Environmental Impacts Remaining

SO 2 Switch to a low sulfur coal

(generally