On July 15 DEP submitted formal comments to EPA on a Best Available Retrofit Technology (BART) rule designed to reduce regional haze.

The BART rule was proposed by EPA to address air emissions that cause a reduction in visibility in and around national parks and scenic areas. The proposed rule requires sources built between 1962 and 1977 and larger than 250 Megawatts and would potentially require sources to retrofit their facilities with new controls to reduce sulfur dioxide emissions and implement year-round nitrogen oxide controls (seasonal controls are in place now).

DEP objected to the methods used by EPA to allowed states to exempt certain sources from the rule based on their individual contributions to visibility impairment. They supported EPA’s proposal for relatively strong levels of presumptive control for sulfur dioxide emissions. DEP also said it supported a “top-down” approach for performing the BART engineering analysis where the most stringent control technology would be selected unless it cannot be justified on a technical basis.

DEP also pointed to the need to coordinate the BART requirements with the Clean Air Interstate Rule EPA proposed which set separate reductions in sulfur dioxide and nitrogen oxides. DEP recommended the year-round operation of Selective Catalytic Reduction controls and the installation of those controls where they are not yet installed to better control nitrogen oxides.

DEP is also sending letters to the 60 or so sources affected by the regional haze requirements and BART rule in the very near future asking them to confirm they are covered by these rules.

To help coordinate regional solutions to a regional problem, Pennsylvania joined a new interstate group called the Mid-Atlantic/Northeast Visibility Union (MANE-VU) which met on July 24. Eleven states, the District of Columbia, and two Indian Tribes are members. The MANE-VU board adopted interim operating guidelines and received a report on potential control technology for the electric utility industry.

Two other regional organizations, the Northeast States for Coordinated Air Use Management and the Mid-Atlantic Regional Air Management Association will assist MANE_VU with technical analysis of haze issues.

State plans for controlling regional haze are due in 2008, assuming the BART rule is finalized on time.

7/30/2004