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9.0 Reasonable Progress Goals (RPGs)

40 CFR Section 51.308(d)(1) of the EPA's Regional Haze Rule requires each state containing a Class I area to establish, for each Class I area within the state, visibility goals (expressed in deciviews) that provide for reasonable progress toward achieving natural visibility. In addition, the EPA released guidance on June 7, 2007 to use in setting reasonable progress goals. The goals must provide improvement in visibility for the most impaired days, and ensure no degradation in visibility for the least impaired days over the initial SIP period. Each Class I state must also provide an assessment of the number of years it would take to attain natural visibility conditions if improvement continues at the rate represented by the reasonable progress goal (RPG).

This SIP covers the first planning period which ends in 2018.

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

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

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

9.1 Consultation and Agreement with Other States' Goals

The MANE-VU states of New Jersey, New Hampshire, Maine and Vermont sent letters to New York in the spring of 2007 stating that, based on 2002 emissions and modeling results, New York contributed to visibility impairment in Class I areas in those states. While New York has no Class I areas, these MANE-VU Class I states asked for New York State's continued participation in further consultation with these states during the summer of 2007. New York agreed in written responses back to these states. Consistent with the Regional Haze Rule requirements, New York State has consulted, and continues to consult, with states containing Class I areas that are or may be impacted by emission sources within New York State as they established reasonable progress goals for each Class I area within their state. More detail on consultation is provided in Appendix F, Summary of Consultation Meetings and Conferences.

As a result of the consultation process, it was the Department's expectation that each state whose Class I areas are affected by emissions in New York would formally provide a notification by letter of the measures that they expected would be taken by New York to meet the reasonable progress goals for the initial period of the SIP (i.e., 2018) as well as attaining natural haze conditions by 2064. Since the consultation process began with a letter from MANE-VU Class I states advising New York that its emissions caused or contributed to regional haze within each state's Class I areas and requesting participation in the consultation process, it was anticipated that the Department would receive a similar letter from each of these states (New Jersey, New Hampshire, Maine and Vermont) advising that the consultation process had resulted in the recommendation that certain, specific measures would be required in order to meet the reasonable progress goals for each Class I area in these states. Although not all of the Class I states whose visibility is affected by emissions from New York have provided such a letter, the Department received a letter dated May 16, 2008 from the State of New Hampshire summarizing New York State's consultation process via MANE-VU. The information in New Hampshire's consultation letter (Appendix X), is indicative of the measures that must be taken.

Except as provided below, the reasonable progress modeling used by MANE-VU states to establish reasonable progress goals reflect the G2 and Base K 2018 emissions inventories for the VISTAS and Midwest RPO regions, respectively. Based on consultation with those regions, those inventories reflected the measures States in those regions consider to be reasonable to implement by 2018 including CAIR, BART, and other federal and state requirements.

With the implementation of the measures described in Section 9.4, New York will meet the Reasonable Progress Goals and long-term strategy requirements developed for New York's regional haze SIP at MANE-VU's Class I areas. New York commits to satisfying its responsibilities under the Regional Haze Program, the Act, and this SIP.

MANE-VU's Contribution Assessment (Appendix A) indicated that the dominant contributor to visibility impairment is SO2. Control of SO2 emissions, therefore, will yield the greatest near-term benefit. It has been determined that the control measures listed above and the costs of compliance are reasonable, based on available control technologies. New York State is committed to reducing emissions at least equal to those predicted in the model, through the measures described above. These are reasonable measures designed to meet our CAA Section 110(a)(2)(D) obligations.

Except as provided below, the reasonable progress modeling used by MANE-VU states to establish reasonable progress goals reflects the G2 and Base K 2018 emissions inventories for the VISTAS and Midwest RPO regions, respectively. Based on consultation with those regions, those inventories reflect the measures states in those regions consider to be reasonable to implement by 2018 including CAIR, BART, and other federal and state requirements.

Reasonable progress goals are based on an analysis of visibility conditions, including a comparison of baseline conditions to natural visibility conditions, which quantifies the improvement necessary to achieve natural visibility conditions by the year 2064 (Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule, Appendix C). The uniform rate of improvement per year needed to achieve natural background visibility conditions is also shown in Table 9-1 below.

Table 9-1 - Uniform Rate of Progress
Class I Area (2000-2004) 2000-2004
Baseline Visibility (deciviews)
(20% Worst Days)
Natural Visibility
Condition (deciviews) (20% Worst Days)

Deciview
Improvement
Needed by 2018 from 2004

Deciview
Improvement Needed by 2064
Uniform Rate
of Improvement Annually
Acadia National Park, Maine 22.9 12.4 2.4 10.5 0.174
Moosehorn National Wildlife Refuge, Maine 21.7 12.0 2.3 9.7 0.162
Roosevelt/Campobello International Park,
Maine & New Brunswick, Canada
21.7 12.0 2.3 9.7 0.162
Great Gulf Wilderness Area, New Hampshire 22.8 12.0 2.5 10.8 0.180
Presidential Range/Dry River Wilderness Area, New Hampshire 22.8 12.0 2.5 10.8 0.180
Lye Brook Wilderness Area, Vermont 24.5 11.7 3.0 12.8 0.212
Brigantine Wilderness Area, New Jersey 29.0 12.2 3.9 16.8 0.280

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

States containing Class I areas are required to show that visibility improvements will ultimately meet the 2064 goal. States without Class I areas contribute to visibility in these areas as well, and so their emissions must be included in the analysis. The State of New York does not contain any Class I areas.

In determining the reasonable progress goal for each Class I area, 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.1 As explained below, the reasonable progress goals established for the Class I area(s) affected by emissions from New York provide for at least as much visibility improvement by 2018 as would be achieved by the uniform rate of progress shown above.

9.2 Reasonable Progress Goals for Class I Areas

In accordance with the requirements of 40 CFR Section 51.308(d)(1), this Regional Haze SIP addresses the necessary measures that New York State must take to meet the reasonable progress goals for each Class I area located in MANE-VU for the period of the implementation plan. Tables 9-2a and 9-2b below provide a summary of Reasonable Progress Goals located within MANE-VU states in which Class I areas are located.

Table 9-2a - Reasonable Progress Goals
20 Percent Worst Days
Class I Area Baseline Visibility
(deciviews)
(20% worst days
2000-2004)
Reasonable Progress Goals,
20% worst days
(Expected deciview
level by 2018)
Deciview
improvement
expected by
2018
Natural Visibility
Conditions
(20% worst days)
Acadia National Park 22.9 19.4 3.5 12.4
Roosevelt/Campobello International Park 21.7 19.0 2.7 12.0
Moosehorn National Wildlife Refuge 21.7 19.0 2.7 12.0
Presidential Range/Dry River Wilderness Area 22.8 19.1 2.7 12.0
Great Gulf Wilderness Area 22.8 19.1 2. 7 12.0
Lye Brook Wilderness 24.5 20.9 3.6 11.7
Brigantine Wilderness 29.0 25.1 3.9 12.2

Table 9-2b - Reasonable Progress Goals
20 Percent Best Days

Class I Area Baseline Visibility
(deciviews)
(20% Best Days)
Reasonable Progress Goals,
20% best days
(deciviews)
(expected by 2018)
Deciview
improvement
expected
by 2018
Natural Visibility
(20% best days)
(deciviews)
Acadia National Park 8.8 8.3 0.5 4.7
Roosevelt/Campobello International Park 9.2 8.6 0.6 5.0
Moosehorn National Wildlife Refuge 9.2 8.6 0.6 5.0
Presidential Range/Dry River Wilderness Area 7.7 7.2 0.5 3.7
Great Gulf Wilderness Area 7.7 7.2 0.5 3.7
Lye Brook Wilderness 6.4 5.5 0.9 2.8
Brigantine Wilderness 14.3 12.2 2.1 5.5

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.2 Progress toward the 2018 target will be calculated based on 5-year averages calculated in a manner consistent with the EPA's Guidance for Tracking Progress Under the Regional Haze Rule (EPA-454/B-03-004, September 2003) as updated by the alternative method for calculating regional haze recommended by the IMPROVE Steering Committee.

To determine the RPG in deciviews, MANE-VU conducted modeling with certain control measure assumptions. The control measures reflected in these reasonable progress goals are summarized below in Table 9-3. In establishing the reasonable progress goals for 2018, contributing states have the flexibility to submit SIP revisions between now and 2018 as they are able to adopt control measures to implement these goals. This long-term strategy to reduce and prevent regional haze will allow each state up to 10 years to pursue adoption and implementation of reasonable and cost-effective NOx and SO2 control measures as appropriate and necessary.

9.2.1 Consideration of Other Air Quality Requirements

40 CFR Section 51.308 (d)(1)(vi) of EPA's Regional Haze Rule requires that reasonable progress goals represent at least the visibility improvement expected from implementation of other Clean Air Act programs during the applicable planning period.

As documented in the emissions inventory and long term strategy sections of this SIP, the modeling that formed the basis for reasonable progress goals in MANE-VU Class I Areas included an estimate of all of the other programs required by the Clean Air Act. Further information may be found in those sections of this SIP and in the documentation for the MANE-VU modeling.

9.2.2 Rationale for Determining Reasonable Controls

40 CFR 51.308(d)(1)(i)(A) of EPA's Regional Haze Rule requires that, in establishing reasonable progress goals for each Class I area, the state must consider the costs of compliance, the time necessary for compliance, the energy and non-air quality environmental impacts of compliance, and the remaining useful life of any potentially affected sources. The SIP must include a demonstration showing how these factors were taken into consideration in setting the RPGs. These factors are sometimes termed the "four statutory factors," since their consideration is required by the Clean Air Act.

MANE-VU conducted a Contribution Assessment (Appendix A) and developed a conceptual model that showed the dominant contributor to visibility impairment at all MANE-VU Class I areas during all seasons in the base year was particulate sulfate formed from emissions of SO2. While other pollutants, including organic carbon, will need to be addressed in order to achieve the national visibility goals, MANE-VU's contribution assessment suggested that an early emphasis on SO2 would yield the greatest near-term benefit. Therefore, it is reasonable to conclude that the additional measures considered in setting reasonable progress goals require reductions in SO2 emissions.

The MANE-VU Contribution Assessment indicates that emissions from within MANE-VU in 2002 were responsible for approximately 25 percent of the sulfate at MANE-VU Class I Areas. Sources in the Midwest and Southeast regions were responsible for about 15 to 25 percent each. Point sources dominated the inventory of SO2 emissions. Therefore, MANE-VU's long-term strategy includes additional measures to control sources of SO2 both within the MANE-VU region and in other states that were determined to contribute to regional haze at MANE-VU Class I Areas.

The Contribution Assessment documented the source categories most responsible for visibility degradation at MANE-VU Class I Areas. As described in Section 10, Long Term Strategy, there was a collaborative effort between the Ozone Transport Commission and MANE-VU to evaluate a large number of potential control measures. Several measures that would reduce SO2 emissions were identified for further study.

These efforts led to production of the MANE-VU report by MACTEC Federal Programs, Inc., "Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas," Final, July 9, 2007, otherwise known as the Reasonable Progress Report (Appendix J). This report provides an analysis of the four statutory factors for five major source categories: electrical generating units (EGUs); industrial, commercial, and institutional (ICI) boilers; cement and lime kilns; heating oil combustion; and residential wood combustion. Table 9-3 summarizes the results of MANE-VU's four-factor analysis for the source categories considered.

Table 9-3 - Summary of Results from Four-Factor Analysis of Different Source Categories
Source Category Primary Regional Haze Pollutant Control Measure(s) Average Cost in 2006 dollars
(per ton of pollutant reduction)
Compliance Timeframe Energy and
Non-Air Quality Environmental
Impacts
Remaining Useful Life
Electric Generating Units SO2 Switch to a low-sulfur coal (generally <1% sulfur); switch to natural gas (virtually 0% sulfur); coal cleaning; flue gas desulfurization (FGD), including wet, spray-dry, or dry. $775-$1,690 based on IPM® v.2.1.9 *
$170-$5,700 based on available literature
2-3 years following SIP submittal Fuel supply issues, possible permitting issues, reduced electricity production capacity, wastewater issues 50 years or more
Industrial, Commercial, Institutional Boilers SO2 Switch to a low-sulfur coal (generally <1% sulfur); switch to natural gas (virtually 0% sulfur); switch to a lower-sulfur oil; coal cleaning; combustion controls; flue gas desulfurization (FGD), including wet, spray-dry, or dry. $130-$11,000 based on available literature; dependent on size. 2-3 years following SIP submittal Fuel supply issues, potential permitting issues, control device energy requirements, wastewater issues 10-30 years
Cement and Lime Kilns SO2 Fuel switching; flue gas desulfurization (FGD), including wet, spray-dry, or dry; advanced flue gas desulfurization (FGD). $1,900-$73,000 based on available literature; dependent on size. 2-3 years following SIP submittal Control device energy requirements, wastewater issues 10-30 years
Heating Oil SO2 Switch to lower-sulfur fuel (varies by state) $550-$750 based on available literature; high degree of uncertainty with this cost estimate Currently feasible; capacity issues may influence timeframe for implementation of new fuel standards Increased furnace/boiler efficiency, reduced furnace/boiler maintenance requirements 18-25 years
Residential Wood Combustion PM State implementation of NSPS, ban on resale of uncertified devices, installer training certification or inspection program, pellet stoves, EPA Phase II certified RWC devices, retrofit requirement, accelerated changeover requirement or inducement $0-$10,000 based on available literature Several years, depending on mechanism for emission reductions Increased efficiency of combustion device, reduced greenhouse gas emissions 10-15 years

The MANE-VU states reviewed the four-factor analyses presented in the Reasonable Progress Report, consulted with one another about possible control measures, and concluded by adopting the statements known as the MANE-VU "Ask." These statements identify the control measures that would be pursued toward improving visibility in the region. The following discussions focus on the four basic control strategies chosen by MANE-VU and included in the modeling to establish the reasonable progress goals:

  1. Best Available Retrofit Technology (BART),
  2. Low-sulfur fuel oil requirements,
  3. Emission reductions from specific EGUs, and
  4. Additional measures determined to be reasonable.

9.3 Controls Within MANE-VU

In accordance with draft EPA guidance, states must establish baselines from which reasonable progress will be measured. The progress sought is in visibility improvement. However, emission reductions are effectively used as a surrogate for this progress, with visibility improvement assessed over the first five years of the implementation of the haze SIP. If mid-course adjustments are appropriate at that time, the SIP will be revised to provide for any necessary corrections. The baseline year for emissions reductions used by MANE-VU is 2002.

Sulfates have been identified as the major pollutant contributing to visibility impairment in the MANE-VU region, and a number of programs are already in place that include measures to reduce the emission of sulfates and their precursors. Several of these are as follows:

  • NYS Acid Deposition Reduction Program
  • 6 NYCRR Part 225, Fuel Composition and Use
  • The Acid Rain Program
  • 2004 Clean Air Nonroad Diesel Rule
  • 2007 Clean Diesel Trucks and Buses Rule
  • California Low Emission Vehicle Standards
  • Emission standards for other engines (highway and non-highway use)
  • National Clean Diesel Campaign

These are discussed in detail in Section 10 of this document.

As a part of the haze SIP development effort, MANE-VU, through its contractor MACTEC, conducted a contribution assessment to identify the sources that are significant contributors to visibility impairment in the MANE-VU area and looked for additional control reduction opportunities to reduce the level of haze in Class I areas (See Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I Areas, Appendix J).

After beginning the assessment with a more extensive list, the following source categories were selected for further consideration:

  • Coal and oil-fired Electric Generating Units (EGUs);
  • Point and area source industrial, commercial and institutional boilers (ICI boilers);
  • Cement kilns;
  • Lime kilns;
  • The use of heating oil; and
  • Residential wood combustion.

In assessing each of these categories, MACTEC conducted an analysis of economic and environmental impacts of potential control scenarios that could be implemented by MANE-VU states. The purpose of this analysis was to develop information that could be used by the states in producing implementation plans to address regional haze. Each category was evaluated with respect to the four factors described in Section 169A of the Clean Air Act. The factors are:

  1. Cost;
  2. Compliance timeframe;
  3. Energy and non-air quality environmental impacts; and
  4. Remaining useful life for affected sources.

The results of this analysis were used to develop the final list of measures that were recommended by Class I states in MANE-VU as being necessary to meet the reasonable progress goal requirements. These measures focus primarily on the reduction of sulfates and particulate matter as a first step during the initial planning period toward reducing visibility reductions to pre-industrial levels.

9.4 Controls Within MANE-VU Selected by Class I States to Meet Reasonable Progress Goals

The reasonable progress goals shown above in Tables 9-2a and 9-2b represent implementation of the regional strategy adopted by MANE-VU on June 20, 2007 entitled, Statement of the Mid-Atlantic/Northeast Visibility Union (MANE-VU) Concerning a Course of Action Within MANE-VU Toward Assuring Reasonable Progress" (See Appendix K). These actions, consisting of control and other measures intended to reduce the emissions of visibility impairing pollutants and their precursors, are referred to in the SIP as the "Ask." As such, these goals are intended to reflect the pursuit by MANE-VU States, including New York, of a course of action including pursuing the adoption and implementation of the following "emission management" strategies, as appropriate and necessary:

a. Timely implementation of BART requirements, and

b. A 90 percent or greater reduction in sulfur dioxide (SO2) emissions from each of the electric generating unit (EGU) stacks identified by MANE-VU (Appendix P- List of Top 167 Sources, dated June 20, 2007) as reasonably anticipated to cause or contribute to impairment of visibility in each mandatory Class I Federal area in the MANE-VU region. If it is infeasible to achieve that level of reduction from a unit, alternative measures will be pursued in such State; and

c. A low sulfur fuel oil strategy in the inner zone states (New Jersey, New York, Delaware, and Pennsylvania, or portions thereof) to reduce the sulfur content of:

  1. Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later than 2012,
  2. #4 residual oil to 0.25 percent sulfur by weight by no later than 2012,
  3. #6 oil to 0.3 - 0.5 percent sulfur by weight by no later than 2012, and
  4. Further reduce the sulfur content of distillate oil to 15 ppm by 2016; and

d. A low sulfur fuel oil strategy in the outer zone states (the remainder of the MANE-VU region) to reduce the sulfur content of:

  1. Distillate oil to 0.05 percent sulfur by weight (500 ppm) by no later than 2014,
  2. #4 residual oil to 0.25 percent-0.50 percent sulfur by weight by no later than 2018,
  3. #6 oil to no greater than 0.5 percent sulfur by weight by no later than 2018, and
  4. Further reduce the sulfur content of distillate oil to 15 ppm by 2018; and

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

As stated above, this long-term strategy to reduce and prevent regional haze will allow each state up to 10 years to pursue adoption and implementation of reasonable and cost-effective NOx and SO2 control measures as appropriate and necessary. See Section 9.5, below for a description of how these assumptions were modeled in order to estimate the visibility impact of the MANE-VU "Ask."

9.4.1 New York State Measures

Although New York has no Class I areas, the emissions from its sources are contributory to regional haze in several states that contain Class I areas. Through the collaborative effort described above, these Class I states have identified control measures that should be applied in order to meet the Reasonable Progress Goals out until 2018. These measures include the application of Best Available Retrofit Technology (BART) to eligible facilities as expeditiously as practicable, but no later than January 1, 2013, sulfate reductions from specific source sectors defined in the Clean Air Act, a low-sulfur oil strategy for all sectors (commercial, industrial, and residential), an EGU strategy that targets a 90% sulfate reduction from each of the stacks impacting any MANE-VU Class I area, or a reduction equivalent to that amount within each State, as well as continued evaluation of other control measures to reduce SO2 and NOx emissions.

Specifically, New York State anticipates meeting these goals as follows:

a. Timely implementation of BART requirements

New York is in the process of promulgating 6 NYCRR Part 249 which will contain the requirements for the federal BART rule. This rule will provide the state authority necessary to require BART controls for eligible sources, and will require BART-eligible EGUs to apply BART by July 1, 2013. Promulgation of this rule is expected to be completed by May 2010.

After promulgation is completed, BART requirements will be applied in New York to eligible sources in accordance with federal requirements, including the Class I areas' requested control measures.

b. Ninety percent or greater reduction in sulfur dioxide (SO2) emissions from the 167 electric generating unit (EGU) stacks.

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

Table 9-4 below identifies the facilities and units in New York State that are contained in the list of 167 stacks. A complete listing of the 167 sources can be found in Appendix P, List of Top 167 Sources. Emission reductions for SO2 that are presently expected to occur for the New York sources in Table 9-4 by 2018 range from 100% (for those units shutting down) to 0% (at the present time) for the Oswego facility. Based on present expectations, most other units expect SO2 emission reductions in the 80-95% range.

Other measures, will reduce emissions from those facilities even further, including:

  • The reduction of fuel sulfur limits for most types of fuel oil, as discussed below and in Section 10.3,
  • The revisions to 6 NYCRR Part 227 that will require RACT for major sources of PM2.5 (those greater than 100 tpy),
  • Part 231: New Source Review in Nonattainment Areas and Ozone Transport Region (revisions adopted January 15, 2009),
  • MACT under Section 112 of the 1990 CAA Amendments,
  • NOx RACT measures for High Electricity Demand Day Units,
  • Emission reductions resulting from consent orders, and
  • The continued evaluation of other control measures including energy efficiency, alternative clean fuels, and other approaches.

Each of these measures is described in detail in Section 10.3.

Finally, the replacement of equipment at these facilities, such as the construction of a new facility, will result in additional reductions by 2018.

Overall, these measures will reduce emissions significantly, approaching the required 90%. As such, in aggregate, it is expected that the necessary reductions will be achieved to meet this portion of the MANE-VU Class I states' "Ask."

9.4.2 New York State Modeling Reductions

Modeling of emission control strategies for the low sulfur fuel oil strategy outlined above produced the following projections of emissions reductions for 2018:

  • A reduction in sulfur from 500 ppm to 15 ppm results in emissions reductions of 7,444 tons per year (TPY). Reducing sulfur content of #4/#6 oil results in 12,385 TPY fewer emissions. Starting with no sulfur controls as a baseline, then reducing the sulfur to 500 ppm results in a 51,929 TPY reduction. Thus, the total TPY reduced as a result of reduced sulfur in oil reductions is 71,759 TPY.
  • Point source reductions resulting from BART controls are 19,942 TPY.
  • Area source reductions resulting from controls are 51,817 TPY.
  • The total emissions being modeled after controls are applied are 13,955 TPY.
Table 9-4 - Units in New York Included in the List of 167 Stacks Identified by MANE-VU
for Which 90 Percent or Greater Reductions in Sulfur Dioxide (SO2) Emissions are Recommended
Plant Name Type Unit(s) NOx Control SO2 Control
Existing Planned Existing Planned
C R HUNTLEY1 Coal Steam 67,68 LNB SNCR Low Sulfur Coal Low S Coal, Trona Injection and
Baghouse (w/ 63 - 66 80 % control)
with Dunkirk 14,169 ton cap
C R HUNTLEY1 Coal Steam 63 through 66 LNB Shutdown Low Sulfur Coal Shutdown
DANSKAMMER O/G Steam 4 LNB & OFA Nothing additional
planned
None Trona Injection and Baghouse
DUNKIRK1 Coal Steam 3,4 LNB & OFA SNCR Low Sulfur Coal Low S Coal, Trona Injection and Baghouse
(80 % control) with Huntley 14,169 ton cap
GOUDEY Coal Steam 11,12,13 Burners out of service SCR None FGD Scrubber (95 % control)
GREENIDGE Coal Steam 6 SNCR/SCR SNCR/SCR Hybrid Dry scrubber
w/lime injection
FB Dry Scrubber (95 % control)
NORTHPORT O/G Steam 3 OFA System-wide
averaging

New plant to be
constructed

Low S New plant to be constructed
OSWEGO O/G Steam 5 Emission limit Emission limit Fuel S Limit (Oil) Fuel S Limit (Oil)
ROCHESTER 7 Coal Steam 3,4 SNCR Shutdown None Shutdown
ROSETON O/G Steam 1 System-wide averaging Nothing planned Fuel S Limit Trona Injection and Baghouse
(w/ 63 - 66 80 % control)
ROSETON O/G Steam 2 System-wide averaging Nothing planned Fuel S Limit Trona Injection and Baghouse
(w/ 63 - 66 80 % control)

Notes: 1 Consent order requires NOx and SO2 emissions reductions by 2013. Controls not yet determined.

c. Low sulfur fuel oil strategy in New York

A low sulfur fuel oil reduction strategy will be implemented to reduce the sulfur content to specific limits by 2012 and 2016. 6 NYCRR Part 225, which contains the state's fuel sulfur limits, will be revised to incorporate these lower fuel sulfur limits, thus implementing this strategy. The expected schedule for promulgation of these measures is as follows:

Proposal in State Register: July 1, 2011
Package to Environmental Board: October 1, 2011
File Regulation with the Secretary of State: November 14, 2011
Regulation Effective Date: December 31, 2011

This schedule is based on EPA approval of the SIP within a year after it is submitted. If the EPA does not approve the SIP within a year, the schedule is subject to change.

d. Continued evaluation of other measures

The evaluation of other control measures, including energy efficiency, alternative clean fuels, and other measures to reduce SO2 and NOx emissions from all coal-burning facilities by 2018 and new source performance standards for wood combustion, will be continued. This is expected to take place on an ongoing basis, and will be more formally assessed during the five-year reassessment of the effectiveness of the regional haze SIP required under 40 CFR Section 51.308(g). For example, MANE-VU considered how to best deal with residential wood combustion and outdoor wood boilers. Although neither have significant sulfate emissions, both of these source categories are sources of organic carbon and direct particulate matter that also impact visibility. Because of the nature of these sources and the varied rates of use among states, it was recommended that the regulation of woodburning appliances be left to each state rather than being part of a regional strategy. New York State is currently developing a rulemaking and regulatory program to control outdoor wood boilers to address a category of sources that is of concern to many states, especially those in the Northeast.

In addition to the above measures, a number of measures intended to reduce the emissions of VOCs will be implemented as a part of the ozone SIPs that have been submitted to EPA. VOCs are precursors to some of the pollutants that cause regional haze and, as such, this reduction will also have a positive impact on the impairment of visibility in Class I areas as well as others. Although these measures are not part of New York's commitments for the purposes of this SIP, additional VOC control measures are expected to have a positive effect on visibility impairment.

Table 9-5 below lists the New York State On-The-Books (OTB) and On-The-Way (OTW) VOC control measures.

Table 9-5 - New York State OTB/OTW VOC Control Measures in the 8-Hour Ozone SIP
OTB/OTW Control Measures
6 NYCRR Part 228- Adhesives and Sealants -effective 7/2010
6 NYCRR Part 241- Asphalt Formulation -effective 7/2010
6 NYCRR Part 212.10- Asphalt Production -effective 8/2010
6 NYCRR Part 235- Consumer Products -effective 10/15/09
6 NYCRR Part 239- Portable Fuel Containers -effective 7/30/09

9.5 Visibility Impacts of Additional Reasonable Controls

40 CFR Section (d)(1)(i)(A) of the EPA's Clean Air Visibility Rule requires that in establishing reasonable progress goals for each Class I area, each Class I state must consider the costs of compliance, the time necessary for compliance, the energy and non-air quality environmental impacts of compliance, and the remaining useful life of any potentially affected sources, and the SIP must include a demonstration showing how these factors were taken into consideration in setting the goal. These factors are sometimes termed the "four statutory factors," since their consideration is required by the Clean Air Act. The analysis performed by the Class I states impacted by emissions from New York is presented in Appendix N, MANE-VU Basis for Reasonable Controls, of this document for reference.

Preliminary modeling was conducted by NESCAUM on behalf of the MANE-VU Class I states to estimate the impact of various elements of the MANE-VU "Ask" as described above. This modeling is described in NESCAUM's report entitled MANE-VU Modeling for Reasonable Progress Goals: Model Performance Evaluation, Pollution Apportionment, and Control Measure Benefits (February 2008, Appendix R).

NESCAUM also conducted additional revised modeling to assess combined impacts. This modeling is described in NESCAUM's report entitled 2018 Visibility Projections (March 2008, Appendix V). The following information about the effects of specific strategies is taken from those reports.

NESCAUM evaluated the visibility benefits of the potential control strategies that go beyond the "On the Books/On the Way" controls already required by actions to implement other requirements of the Clean Air Act. This section explains assumptions used to model the impact of potential control strategies and describes the combined potential visibility benefits of all the strategies based on CMAQ modeling. As with all modeling, emissions estimates and modeling results for 2018 entail uncertainty, and further evaluation may be conducted as part of the SIP report required in five years under 40 CFR Section 51.308(g). If reasonable progress requirements are not met, New York will submit a revision of its Regional Haze SIP with the necessary corrections as prescribed in the Federal rule.

Appendix N, MANE-VU Basis for Reasonable Controls, of this document discusses the basis for determining that the measures described in the MANE-VU "Ask" are considered to be reasonable.

9.5.1 Model Performance

CMAQ modeling was conducted for 2002 by cooperative modeling efforts from NYSDEC, UMD, NJDEP, Rutgers, VADEP, and NESCAUM and performance for PM2.5 species and visibility was examined. Measurements from IMPROVE and STN networks were paired with model predictions by location and time for evaluation. These comparisons showed that predicted PM2.5 sulfate and measured sulfate were in a good 1:1 linear relationship. Paired organic carbon (OC) concentrations exhibited a weak linear distribution. CMAQ tended to overestimate elemental carbon (EC) and fine soil concentrations. The emission inventory data may be the main cause for the weaker linear relationships between prediction and measurement.

Because sulfate is the dominant PM2.5 species, modeled PM2.5 showed a relatively strong near 1:1 linear relationship. Generally, the northern region of the area modeled displayed stronger correlations than did the southern region. For the MANE-VU region, CMAQ was shown to perform best for PM2.5 sulfate, followed by PM2.5, EC, nitrate, OC, and then fine soil.

Regional haze modeling also required a CMAQ performance evaluation for aerosol extinction coefficient (Bext) and the haze index. Modeled daily aerosol extinction at each IMPROVE site was calculated following the IMPROVE formula with modeled daily PM2.5 species concentration and relative humidity factors from IMPROVE. The approaches used here and throughout the analysis have used natural background visibility estimates and the haze index following EPA Guidance.

A paired comparison between prediction and measurement of daily Bext showed a near 1:1 linear relationship. CMAQ prediction of the Bext agreed well with IMPROVE observation because CMAQ performed well on sulfate, which dominates aerosol extinction. Further, the modeled haze index (HI) was calculated based on modeled Bext. A paired comparison between CMAQ prediction and IMPROVE measurement for 2002 of HI values at seven Class I sites in the eastern U.S.. Acadia and Moosehorn showed the best model performance. The poorest model performance occurred at Lye Brook, which is the closest area to New York State, and Shenandoah. However, since sulfates comprise the largest contribution to visibility impairment, it would be reasonable to expect that modeling results would provide good estimates of the effectiveness of the control strategies proposed in New York's SIP for both 2002 and the 2018 planning year.

A state-specific assessment of the performance of the models that were used is not available and would not be meaningful given the role that transport plays over very long distances. All modeling was done on a regional basis. However, given the good performance of the models as they relate to the impacts of SO2 emissions on haze, which has been shown to be overwhelmingly the most significant, it is possible to infer each states' contributions in a general sense by examining the relative emissions in New York to the total for the region. These emissions appear in Tables 7-1 through 7-6 which present the relative emissions from New York State sources compared to MANE-VU sources in total.

9.6 Modeling Impacts of BART Controls on Former Non-CAIR Sources in MANE-VU

Although many states had not completed BART determinations for non-CAIR BART-eligible sources at the time regional modeling was conducted, NESCAUM did include in the modeling a reasonable estimate of the effect of BART on other (non-CAIR) sources within MANE-VU.

To assess the impacts of the implementation of BART on non-CAIR sources in MANE-VU, NESCAUM estimated reductions for eight BART-eligible facilities. A survey of state staff indicated that these eight units would likely be controlled under BART alone. These states provided potential control technologies and levels of control, which were in turn incorporated into the 2018 emission inventory projections.

Table 9-6 lists the emissions for the BART-eligible sources at eight facilities that were included in modeling used to set reasonable progress goals.

9.7 Controls Outside of MANE-VU Selected to Meet Reasonable Progress Goals

The reasonable progress goals shown above represent implementation of the statement adopted by MANE-VU on June 20, 2007 and entitled, Statement of the Mid-Atlantic/Northeast Visibility Union (MANE-VU) Concerning a Request for a Course of Action by States Outside MANE-VU Toward Assuring Reasonable Progress (See Appendix S).

The states outside MANE-VU to whom this request was addressed were identified in the MANE-VU Contribution Assessment as those states contributing at least 2 percent of the sulfates at MANE-VU Class I areas in 2002. This includes the following states outside MANE-VU: Georgia, Illinois, Indiana, Kentucky, Michigan, North Carolina, Ohio, South Carolina, Tennessee, Virginia, and West Virginia.3

The MANE-VU June 20, 2007 Statement requested that the above-listed states outside MANE-VU pursue the adoption and implementation of the following control strategies, as appropriate and necessary:

a. Timely implementation of BART requirements;

b. A 90 percent or greater reduction in sulfur dioxide (SO2) emissions from each of the electric generating unit (EGU) stacks identified by MANE-VU (See Appendix P, List of Top 167 Sources, dated June 20, 2007) as reasonably anticipated to cause or contribute to impairment of visibility in each mandatory Class I Federal area in the MANE-VU region. If it is infeasible to achieve that level of reduction from a unit, alternative measures will be pursued in such State;

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

d. Continued evaluation of other measures including measures to reduce SO2 and NOx emissions from all coal-burning facilities by 2018 and promulgation of new source performance standards for wood combustion. These measures and other measures identified will be evaluated during the consultation process to determine if they are reasonable.

These measures and other measures identified were evaluated prior to and during the consultation process and the above course of action was determined to be reasonable. Assumptions about the implementation of these measures are represented by the inventory and modeling assumptions described in this section. As stated above, this long-term strategy to reduce and prevent regional haze will allow each state up to 10 years to pursue adoption and implementation of reasonable and cost-effective NOx and SO2 control measures as appropriate and necessary.

In addition to the above controls in the U.S., the MANE-VU Class I states determined that it was reasonable to include anticipated emissions reductions in Canada in the modeling used to set reasonable progress goals. Six coal-burning EGUs in Canada totaling 6500MW are scheduled to be shut down and replaced with nine natural gas turbine units with Selective Catalytic Reduction (SCR) before 2018.

See Section 9.5 for a description of how these emissions controls were modeled in order to estimate the visibility impact of the MANE-VU "Ask."

Table 9-6 - Estimated SO2 Emissions from Non-EGU BART-Eligible Facilities
Located in New York Used in Final Modeling
State Facility Name Unit
Name
SCC Code Plant ID
(from the
MANE-VU
Inventory)
Point ID
(from the
MANE-VU
Inventory)
Facility Type 2002 SO2
Emissions
(tons)
2018 SO2
Emissions
(tons)
NY KODAK PARK DIVISION U00015 10200203 8261400205 U00015 Chemical Manufacturer 23798 14216
NY LAFARGE BUILDING
MATERIALS INC
41000 30500706 4012400001 041000 Portland Cement 14800 4440

9.8 Implementation of MANE-VU's Low Sulfur Fuel Strategy

The MANE-VU states agreed through consultations to pursue a low sulfur fuel strategy within the region. This phased strategy would be implemented in two steps. However, both components of the strategy are to be fully implemented by 2018.

NESCAUM initially analyzed both steps of the program as separate strategies, but it is the combined benefit of implementing the program that is relevant to the question of program benefits in 2018. To estimate the total 2018 emissions reductions from this strategy, 2018 OTB/OTW SO2 emissions were reduced from all MANE-VU non-EGU sources burning #1, #2, #4, #5, or #6 oil. Emissions reductions reflected lowering the sulfur content in fuel from its original level to 0.015 percent for #1 and #2 oil; to 0.25 percent for #4 oil; and to 0.5 percent for #5 and #6 oil.

The first phase of the MANE-VU low sulfur fuel strategy requires the lowering of fuel-sulfur content in distillate (No. 2 oil) from current levels that range between 2,000 and 2,300 ppm down to 500 ppm by weight. It also restricts the sale of heavier blends of residual oil (No. 4 fuel oil and No. 6 bunker fuels) that have sulfur content greater than 0.25 percent sulfur and 0.5 percent sulfur by weight, respectively.

The second phase of the strategy further reduces the fuel-sulfur content of the distillate fraction to 15 ppm sulfur by weight. The two phases of the MANE-VU low sulfur fuel strategy are to be implemented in sequence with slightly different timing for an "inner zone"4 generally corresponding to the I-95 corridor and the remainder of MANE-VU. All states, however, have agreed to pursue reductions that would take place no later than 2018. Based on the fuel sulfur limits within the first phase of the strategy, MANE-VU estimated a decrease of 140,000 tons of SO2 emitted from distillate combustion and a decrease of 40,000 tons of SO2 from residual combustion in MANE-VU.

The second phase of the MANE-VU low sulfur fuel strategy further reduces the sulfur content of distillate from 500 ppm to 15 ppm while keeping the sulfur limits on residual oils to 0.25 percent and 0.5 percent for No. 4 and No. 6 oils, respectively. By lowering the distillate fuel sulfur limit from 500 ppm to 15 ppm, MANE-VU estimates an additional reduction of 27,000 tons of SO2 emissions in MANE-VU from distillate combustion in 2018.

Figure 9-1 shows the full benefit of the MANE-VU fuel strategies being considered relative to the "On The Books/On The Way" baseline. NESCAUM used the concentration changes illustrated in Figure 9-1 to estimate the visibility benefits for this strategy. Because the fuel sulfur program only affects sources within MANE-VU, that region sees the largest PM2.5 reduction and the greatest visibility benefits.

Figure 9-1 - Average Change in 24-hr PM2.5 Due to Low Sulfur Fuel Strategies Relative to OTB/OTW (µg/m3)

Map of east coast illustrating benefit of low sulfur fuel strategies for MANE-VU region.

9.9 Impacts of Reducing Emissions of SO2 from 167 EGU Stacks

SO2 emissions from power plants are the single largest sector contributing to the visibility impairment experienced in the Northeast's Class I areas. The SO2 emissions from power plants continue to dominate the inventory. Sulfate formed through atmospheric processes from SO2 emissions are responsible for over half the mass and approximately 70-80 percent of the extinction on the worst visibility days (NESCAUM's Contribution Assessment and Conceptual Model).

In order to ensure that EGU controls are targeted at those EGUs with the greatest impact on visibility in MANE-VU, a modeling analysis was conducted to determine which sources those were. A list of 167 EGU stacks was developed that includes the 100 largest impacts at each MANE-VU Class I site during 2002. Emissions from the list of 167 EGU stacks can be found in Figure A-2 of Appendix A (Appendix W of this document) of the report entitled, Documentation of 2018 Emissions from Electric Generating Units in the Eastern United States for MANE-VU's Regional Haze Modeling. MANE-VU requested 90 percent control on all units emitting from those stacks by 2018 as part of consultations within MANE-VU and with other RPOs.

Preliminary modeling showed that requiring SO2 emissions from these 167 EGU stacks to be reduced by 90 percent could reduce 24-hour PM2.5 concentrations. NESCAUM modeled 2018 emissions for the 167 EGU stacks in the Northeast, Southeast, and Midwest at levels equal to 10 percent of their 2002 emissions. NESCAUM used CMAQ to model sulfate concentrations in 2018 after implementation of this control program and converted sulfate concentrations to PM2.5 concentrations. Figure 9-2 displays the average change in 24-hr PM2.5.

Figure 9-2 - Preliminary Estimate of Average Change in 24-hr PM2.5 Due to 90 Percent Reduction in SO2 Emissions from 167 EGU Stacks Affecting MANE-VU

Map of eastern US showing average change in 24-hour PM2.5

Figure 9-2 shows that significant reductions of PM2.5 were predicted for the MANE-VU region as well as for portions of the VISTAS and Midwest RPO regions as a result of reducing SO2 emissions by 90 percent from 167 EGU stacks affecting MANE-VU.

While these reductions are potentially large, based on consultations with affected states, it was determined to be unreasonable to expect that the full 90 percent emissions reductions would be achieved by 2018. Therefore, further modeling was conducted to assess a more realistic scenario.

MANE-VU's "Best and Final" modeling is documented in the report 2018 Visibility Projections (NESCAUM, March 2008), Appendix V. This modeling estimated composite visibility benefits of all strategies within and outside MANE-VU rather than the benefits of individual strategies.

9.10 Reducing Non-EGU SO2 Emissions Outside MANE-VU by 28 Percent

In addition to these measures (BART controls within MANE-VU, low sulfur fuel within MANE-VU, and controls on specific EGUs), MANE-VU asked neighboring RPOs to consider further non-EGU emissions reductions comparable to those achieved through MANE-VU's low sulfur fuel strategies, which are expected to achieve a greater than 28 percent reduction in non-EGU SO2 emissions in 2018. After consultation with other states and consideration of comments received, the MANE-VU Class I States decided that MANE-VU's Best and Final modeling would include implementation of these additional emissions reductions.

In order to model the impact of this strategy on visibility at MANE-VU Class I areas, the following reductions were made to emissions in the VISTAS and MRPO regions:

For both Southeast and Midwest States:

  • Coal-Fired ICI Boilers: Emissions were reduced by 60 percent.
  • Oil-Fired ICI boilers: Emissions were reduced by 75 percent.
  • ICI Boilers lacking fuel specification: Emissions were reduced by 50 percent

Additional controls required in the Southeastern States:

  • Emissions from Other Area Oil-Combustion sources were reduced by 75 percent. (Used the same SCCs identified in MANE-VU Oil strategies list.)

9.11 Implementation of Gas-Turbine EGU Controls in Canada

As requested by the MANE-VU Class I States, for the Best and Final Modeling, NESCAUM also removed SO2 emissions from 6500MW of six coal-burning EGUs in Canada that are scheduled to be shut down.5 It is expected that these units will be replaced with nine natural gas turbine units with Selective Catalytic Reduction (SCR) controls. NESCAUM based estimated emission rates for modeled pollutants on a combination of factors, including recommendations from the State of New Hampshire, a NYSERDA study, and AP-42 ratios among pollutants. Emissions were reduced by more than 144,000 tons per year as a result of this measure.

9.12 Results of Best and Final Modeling

In order to estimate the visibility impacts of the measures discussed above, NESCAUM conducted regional modeling using the CMAQ chemical transport model. Documentation of this modeling is contained in the report 2018 Visibility Projections (NESCAUM, March 2008), Appendix V. Based on currently available information and up-to-date modeling tools, this modeling provides an estimate of visibility improvement that could be achieved by 2018 through the reasonable measures described above based on currently available information and up-to-date modeling tools.

Figures 9-3 through 9-7 show the uniform rate of progress for each MANE-VU Class I area as well as the estimated combined visibility benefits of the strategies described in Section 9.5 above. All areas are expected to achieve sufficient visibility improvement by 2018 to meet or exceed the required improvements based on the uniform rate of progress. As a contributing state implementing the emissions measures under the "Ask" of the Class I area states, New York will therefore meet its obligation under this SIP and the Regional Haze Program.

Figure 9-3 - Projected Visibility Improvement at Acadia National Park Based on 2009 and 2018 Best and Final Projections

Projected visibility improvement at Acadia National Park

Figure 9-4 - Projected Visibility Improvement at Brigantine National Wildlife Refuge Based on Best and Final Modeling

Projected visibility improvement at Brigantine National Wildlife Refuge

Figure 9-5 - Projected Visibility Improvement at Great Gulf Wilderness Area Based on Best and Final Modeling6

Projected visibility improvement at Great Gulf Wilderness Area

Figure 9-6 - Projected Visibility Improvement at Lye Brook Wilderness Area Based on Best and Final Modeling

Projected visibility improvement at Lye Brook Wilderness Area

Figure 9-7 - Projected Visibility Improvement at Moosehorn National Wildlife Refuge and Roosevelt/Campobello International Park Based on Best and Final Modeling7

Projected visibility improvement at Moosehorn National Wildlife Refuge and Roosevelt/Campobello International Park

9.13 Comparison to the Clean Air Act

The control measures that are a part of the "Ask" will result in at least as much visibility improvement that is expected from implementation of other CAA requirements during the planning period. See Updated Visibility Statistics for the MANE-VU Region, Appendix D.

9.14 Reporting

Progress will be reported to the EPA every five years in accordance with 40 CFR Section 51.308(g). If reasonable progress requirements are not met, New York will submit a revision of the haze SIP with the necessary corrections.

__________

1 "Baseline and Natural Visibility Conditions, Considerations and Proposed Approach to the Calculation of Baseline and Natural Visibility Conditions at MANE-VU Class I Areas," NESCAUM, December 2006
2 "Baseline and Natural Visibility Conditions, Considerations and Proposed Approach to the Calculation of Baseline and Natural Visibility Conditions at MANE-VU Class I Areas," NESCAUM, December 2006.
3 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.
4 The inner zone includes New Jersey, Delaware, New York City, and potentially portions of eastern Pennsylvania.
5 NESCAUM's 2018 Visibility Projections report cited a November 2006 paper by the Ontario Power Authority, "Ontario's Integrated power System Plan Discussion Paper 7: Integrating the Elements-A Preliminary Plan." See http://www.powerauthority.on.ca/ipsp/Storage/32/2734_DP7_IntegratingTheElements.pdf
6 The estimate for Great Gulf Wilderness Area also serves to provide an estimate for the Presidential Range/Dry River Wilderness Area
7 The estimate for Moosehorn National Wildlife Refuge also serves to provide an estimate for Roosevelt/Campobello International Park.