State Implementation Plan Revision to Meet the 

Ozone Infrastructure SIP Requirements of the 

Clean Air Act Section 110(a)(2). 

Clark County, Nevada

February 2013

Clark County Department of Air Quality

4701 W Russell Road, Suite 200

Las Vegas, NV 89118
State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Ozone

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INTENTIONALLY LEFT BLANK
State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Ozone

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ACRONYMS AND ABBREVIATIONS

Acronyms

AERR Air Emissions Reporting Requirements

AQR Clark County Air Quality Regulations

BCC Clark County Board of County Commissioners

CAA Clean Air Act

CFR Code of Federal Regulations

DAQ Clark County Department of Air Quality

EPA U.S. Environmental Protection Agency

FR Federal Register

GHG Green House Gasses

I-SIP Infrastructure State Implementation Plan

NAAQS National Ambient Air Quality Standards

NAC Nevada Administrative Code

NDEP Nevada Division of Environmental Protection

NESHAP National Emission Standards for Hazardous Air Pollutants

NRS Nevada Revised Statutes

NSPS New Source Performance Standards

NSR New Source Review

SNRPC Southern Nevada Regional Planning Coalition

PSD Prevention of Significant Deterioration

QA Quality Assurance

QC Quality Control

SIP State Implementation Plan 

TAC Technical Advisory Committee

RTC Regional Transportation Commission

USC United States Code

Abbreviations

O3 Ozone

ppb Parts per billion

μg/m3 Micrograms per cubic meter
State Implementation Plan Revision to Meet the Infrastructure SIP Requirements for Ozone

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Introduction and Background

Sections 110(a)(1) and (2) of the federal Clean Air Act (CAA), 42 U.S.C. § 7410(a)(1) and (2) hereafter 

referred to as the “Infrastructure” State Implementation Plan (I-SIP) requirements, requires states and 

delegated local agencies to submit an implementation plan to the U. S. Environmental Protection Agency 

(EPA) demonstrating their ability and authority to implement, maintain, and enforce each National Ambient 

Air Quality Standard (NAAQS). 

Section 110(a)(1) addresses the submittal requirements for I-SIPs which are due to EPA not later than 3 years 

after promulgation of a new or revised NAAQS. An I-SIP needs to be submitted regardless of whether or not 

a jurisdiction has any nonattainment areas. 

This SIP revision submittal addresses Clark County’s authority to implement, maintain and enforce the 2008 

Ozone NAAQS within the County’s jurisdiction.

Section 110(a)(2) lists the required elements that cover the I-SIP. These elements include: enforceable 

emission limitations, air quality modeling, enforcement programs, ambient air monitoring programs, and 

confirmation of adequate personnel, resources and legal authorities. The following elements are addressed 

in this I-SIP: 

• Enforceable Emission Limitations and Other Control Measures (110(a)(2)(A)) 

• Air Quality Monitoring, Compilation, Data Analysis, and Reporting (110(a)(2)(B)) 

• Enforcement and Stationary Source Permitting (110(a)(2)(C)) 

• Resources, Conflict of Interest, and Emergency Backstop (110(a)(2)(E)) 

• Stationary Source Emissions Monitoring and Reporting (110(a)(2)(F)) 

• Emergency Powers and Contingency Plans (110(a)(2)(G)) 

• Revision For Revised Air Quality Standards or New Attainment Methods (110(a)(2)(H)) 

• Consultation and Public Notification (110(a)(2)(J)) 

• Air Quality Modeling and Reporting (110(a)(2)(K)) 

• Major Stationary Source Permitting Fees (110(a)(2)(L)) 

• Consultation with Local Entities (110(a)(2)(M)) 

In accordance with the EPA guidance memo1 dated October 17, 2011, two elements identified in Section 

110(a)(2) are not governed by the 3-year submission deadline of Section 110(a)(1). The elements pertain to 

part D, in Title I of the CAA, which addresses plan requirements for nonattainment areas. Therefore, the 

following Section 110(a)(2) elements are considered by EPA to be outside the scope of infrastructure SIP 

actions: 

(1) Section 110(a)(2)(C) to the extent it refers to permit programs (known as "nonattainment new source 

review") under part D; and

(2) Section 110(a)(2)(I) in its entirety.

 1 Guidance on Infrastructure State Implementation Plan (SIP) Elements Required Under Section 110(a)(1) and 110(a)(2) for the 2008 Lead (Pb) 

National Ambient Air Quality Standards (NAAQS), October 17, 2011
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Section 110(a)(2)(D) is exempt from the I-SIP due to the recent Cross-State Air Pollution Rule (CSAPR)

2

 2 Memorandum from Gina McCarthy, November 19, 2012

decision. EPA does not intend to make findings that states failed to address the good neighbor obligation in 

Element D.
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CAA 110(a)(2)(A)-(M) Requirements for the Clark County Infrastructure State Implementation Plan for O3

Element

(A)

Emission limits and other control measures:

Requires State Implementation Plans (SIP) to include enforceable emission limits and other control measures, means, 

or techniques, and schedules for compliance.

The Clark County Board of County Commissioners (BCC), in accordance with NRS Chapter 445B, has adopted the Clark County 

Air Quality Regulations (AQR) and has delegated enforcement authority to the Department of Air Quality (DAQ). Emission sources 

within Clark County are required to comply with all existing rules and regulations through federally enforceable state implementation 

plan regulations3.

Clark County has a SIP Approved PSD program and most of the AQRs are SIP approved. Several AQR updates have been adopted 

by the BCC and submitted to EPA for incorporation in the SIP (submittal dates in parentheses). A complete index of all AQRs (SIP 

approved and local-only) is included in Attachment B. 

The following is a list of rules that have been revised and submitted for incorporation into the SIP:

• Section 0 - Definitions (revised as part of the Section 12.1 rulemaking and the Section 12.2 et al rulemaking);

• Section 12.0 - Applicability, General Requirements, Transition Procedures (adopted 11-09, submitted 02-10);

• Section 12.1 - Permit Requirements for Minor Sources (adopted 11-09, submitted 02-10);

• Section 12.2 - Permit Requirements for Major Sources in Attainment Areas (PSD) (adopted 05-10, submitted 8-10);

• Section 12.3 - Permit Requirements for Major Sources in Nonattainment Areas (adopted 05-10, submitted 8-10); 

• Section 12.4 - Authority to Construct Application and Permit Requirements for Part 70 Sources (adopted 05-10, submitted 8-

10); 

• Section 12.11 - General Permits for Minor Stationary Sources (adopted 11-09, submitted 02-10);

• Section 25 - Affirmative Defense For Excess Emissions Due to Malfunctions, etc. (adopted 05-10, submitted 08-10).

In addition, the emissions limitations in the following SIP-approved rules in the Clark County portion of the Nevada SIP reduce 

ozone by limiting ozone precursors, including chlorine and VOC:

• Section 33 – Chlorine in Chemical Processes;

• Section 50 – Storage of Petroleum Products;

 3 Although not a SIP rule, DAQ administers the Part 70 (Title V) permit requirements through the implementation of Section 12.5 – Part 70 Operating Permit Requirements.
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• Section 51 – Petroleum Product Loading into Tank Trucks and Trailers.

Several AQRs such as Section 12.9 – Annual Emissions Inventory Requirement, and Section 12.10 – Continuous Monitoring 

Requirements for Stationary Sources, are local-only rules.

Section 0 and Section 12.2 were revised in November, 2010 specifically for the purpose of meeting the Greenhouse Gas (GHG) 

Tailoring Rule requirements, submitted as a SIP revision on January 4, 2011. 

Section 9 - Civil Penalties and Section 10 - Compliance Schedules are part of the DAQ enforcement programs.

Clark County also enforces Hazardous Air Pollutants (Section 13) rules and New Source Performance Standards (Section 14).

Clark County will continue to implement the permitting and enforcement programs and enforce control measures with respect to the 

requirements in the CAA.
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Element

(B)

Ambient air quality monitoring/data system:

Requires SIPs to provide for establishment and operation of ambient air quality monitors, collection and analysis of 

ambient air quality data, and to make these data available to EPA upon request.

Clark County operates an extensive air quality monitoring network, including nine permanent and two seasonal ozone monitors, in 

accordance with 40 CFR § 58. The quality control (QC) flow rate verifications and quality assurance (QA) flow rate audits meet

EPA guidelines for all monitors in the network. An Annual Monitoring Network Plan is completed and submitted to EPA as required 

in 40 CFR § 58.10 (Attachment A). Monitoring data is submitted to EPA via the Air Quality System; monitoring data is also 

available on DAQ’s website in near-real time.
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Element

(C)

Program for enforcement of control measures:

Requires SIPs to include a program providing for enforcement of all SIP measures and the regulation of construction 

of new and modified stationary sources as necessary to assure that the NAAQS are achieved, including a permit 

program as required in Parts C and D.

AQR Section 4 - Control Officer, authorizes the Control Officer to enforce all AQRs including the following sections:

• Section 10 - Compliance Schedules;

• Section 12.1 - Permit Requirements for Minor Sources; 

• Section 12.2 - Permit Requirements for Major Sources in Attainment Areas; 

• Section 12.3 - Permit Requirements for Major Sources in Nonattainment Areas; 

• Section 12.4 - Authority to Construct Application and Permit Requirements for Part 70 Sources; 

• Section 12.11 - General Permits for Minor Stationary Sources;

• Section 13 - National Emission Standards for Hazardous Air Pollutants;

• Section 14 - New Source Performance Standards

• Section 25 - Affirmative Defense For Excess Emissions Due to Malfunctions;

• Section 26 - Emission of Visible Air Contaminants;

• Section 27 - Particulate Matter from Process Weight Rate;

• Section 28 - Fuel Burning Equipment.

Section 12.2 was revised in November 2010 to include provisions for GHG, the SIP revision was submitted January 4, 2011.

Other sections from the AQRs are not part of the SIP; therefore they are local-only rules. They have been adopted by the BCC and 

are enforced by the Control Officer.
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Element

(D)

Interstate transport provisions:

Requires SIPs to contain adequate provisions prohibiting emissions generated within the state from contributing 

significantly to nonattainment in, or interfering with maintenance by, any other state with respect to the NAAQS, or 

from interfering with measures required to be included in the SIP of any other state to prevent significant 

deterioration or to protect visibility.

Gina McCarthy, Assistant Administrator of the US EPA issued a memo on November 19, 2012 to EPA Air Division Directors, 

Regions 1-10, regarding states’ and US EPA’s obligations with respect to the requirements of (D)(i)(I). Ms. McCarthy notes:

“I would also like to note that the recent CSAPR decision made certain holdings regarding the requirement for states to 

submit SIPs addressing the provisions of Clean Air Act section 110(a)(2)(D)(i)(I), the good neighbor provision that addresses 

upwind emissions linked to NAAQS attainment problems in downwind states. The decision states that a SIP cannot be 

deemed deficient for failing to meet the good neighbor obligation before the EPA quantifies that obligation. Although we 

have filed a petition for rehearing of the Court’s decision, including this element of the decision, and although the mandate for 

that decision has not yet been issued, we intend to act in accordance with the decision during the pendency of the appeal. 

Therefore, at this time the EPA does not intend to make findings that states failed to submit SIPs to comply with section 

110(a)(2)(D)(i)(I). To the extent that states may inquire about their obligations to submit SIPs addressing this provision, we 

believe it would be appropriate to convey that at this time we do not intend to make such findings with respect to section 

110(a)(2)(D)(i)(I).”

Because US EPA has not informed Nevada of its contribution to any ozone NAAQS attainment problem in downwind states, DAQ

concludes that it is not obligated to address this requirement at this time.
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Element

(E)

Adequate resources:

Requires SIPs to provide necessary assurances for adequate personnel, funding, and authority under state law to carry 

out its SIP, to contain requirements addressing potential conflicts of interest, and to provide necessary assurances that 

the state retains responsibility for ensuring adequate implementation of the SIP where the state relies on a local or 

regional government for implementation of any SIP provision.

NRS 445B.500 authorizes Clark County to implement and administer air quality management programs within the geographic 

boundaries of Clark County. These programs are managed through the DAQ, with a current air quality budget of approximately 

$28.7 million, and 97 full-time equivalent staff positions. Primary sources of funding are:

• Permits and technical services fees collected from regulated emission sources;

• Federal grants;

• Fund distributions and grants from the Nevada Air Pollution Control Account per NRS 445B.830; 

• RTC transportation tax revenue, as established by NRS 377A.090;

• Federal Congestion Mitigation and Air Quality Program (CMAQ) funds.

NRS 445B.520 gives the State Environmental Commission4 the authority to supersede the county program. 

Clark County Code Chapter 2.42 – Ethical Standards - specifies conflict of interest requirements for Clark County public officers and 

officials, including members of the BCC and the Control Officer. These requirements specifically prohibit all local public officials 

from participating in governmental decisions in which they have a financial interest. 

The following provisions of state law address the requirements of CAA Sections 110(a)(2)(E)(ii) and 128:

• NRS 281A.150 (“‘Public employee’ defined”)

• NRS 281A.160 (“‘Public officer’ defined”)

• NRS 281A.400 (“General requirements; exceptions”)

• NRS 281A.410 (“Limitations on representing or counseling private persons before public agencies; disclosure required by 

certain public officers.”)

• NRS 281A.420 (“Requirements regarding disclosure of conflicts of interest and abstention from voting because of certain 

types of conflicts; effect of abstention on quorum and voting requirements; exceptions”).

 4 State Environmental Commission is defined in NRS 445B.200
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Element

(F)

Stationary source monitoring system:

Requires SIPs to establish a system to monitor emissions from stationary sources, to submit periodic emissions 

reports, to correlate the emissions reports with the corresponding SIP emission limits and standards, and to make 

emissions reports available to the public.

The following AQR Sections provide the authority for the installation and maintenance of sampling and testing facilities to measure 

emissions of air contaminants, and for data collection: 

• Section 12.1 - Permit Requirements for Minor Sources;

• Section 12.2 - Permit Requirements for Major Sources in Attainment Areas;

• Section 12.3 - Permit Requirements for Major Sources in Nonattainment Areas;

• Section 12.4 - Authority to Construct Application and Permit Requirements for Part 70 Sources;

• Section 12.9 - Annual Emissions Inventory Requirement;

• Section 12.10 - Continuous Monitoring Requirements for Stationary Sources;

• Section 12.11 - General Permits for Minor Stationary Sources; 

• Section 25 - Affirmative Defense For Excess Emissions Due to Malfunctions.

Sections 12.9 and 12.10 have not been submitted as SIP rules; they are local-only rules

Emissions data is submitted according to the Air Emissions Reporting Requirements (AERR). Emissions data is available to the 

public, except when the data is deemed confidential in accordance with AQR Section 12.6 and NRS 445B.570.
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Element

(G)

Emergency episodes:

Requires SIPs to provide for authority to address activities causing imminent and substantial endangerment to public 

health and to provide for adequate contingency plans to implement such authority.

In accordance with NRS 445B.500(1)(d), Clark County has the authority to provide by rules and regulations for alert, warning, and 

emergency standards and abatement procedures relative to air pollution episodes or emergencies constituting, or likely to constitute, 

an imminent and substantial danger to people’s health pursuant to NRS 445B.560. 

Clark County has adopted AQR Section 70 - Emergency Procedures of the AQRs, which addresses emergency procedures. 

AQR Section 6 - Injunctive Relief, allows Clark County to apply to a court of competent jurisdiction to enforce compliance with—or 

restrain violations of—any provision of the AQRs.

Element

(H)

Future SIP revisions:

Requires SIPs to provide for SIP revisions in response to changes in the NAAQS, or availability of improved 

methods for attaining the NAAQS, and in response to an EPA finding that the SIP is substantially inadequate.

Clark County must provide a method for revision of SIPs when air quality standards are revised, new attainment methods become

available, or EPA informs states that current SIPs are inadequate for attaining standards or complying with additional CAA 

requirements. 

AQR Section 2 - Procedures for Adoption and Revision of Regulations and for Inclusion of those Regulations in the State 

Implementation Plan of the Clark County AQR set forth the general procedural requirements for adoption of regulations and other 

materials to be incorporated in the SIP. These procedures apply to submission of: 

(a) Any revision to the SIP described by 40 C.F.R. § 51.104(a); 

(b) Any individual compliance schedule under 40 C.F.R. § 51.260;

(c) Any other SIP revision submitted to NDEP pursuant to 40 C.F.R. § 51.104(d).
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Element

(J)

CAA § 121

Consultation with government officials, public notification, PSD and visibility protection:

Requires states to provide a process for consultation with local governments and Federal Land Managers carrying out 

NAAQS implementation requirements pursuant to section 121 relating to consultation.

Clark County will continue including local governments and managers of affected federal lands in its consultation process as part of 

carrying out CAA requirements. AQR Section 2 – Procedures for adoption and revision of regulations and for inclusion of those 

regulations in the State Implementation Plan outlines the procedures for adoption and revision of regulations. The procedures 

include provisions for notice to the public and governmental entities as well as public hearings before seeking to amend the SIP 

applicable to Clark County.

Element

(J)

CAA § 127

Requires States to notify the public if NAAQS are exceeded in an area and to enhance public awareness of measures 

that can be taken to prevent exceedances.

AQR Section 70 - Emergency Procedures authorizes the Control Officer to declare an episode, an alert or an emergency if the 

operation of sources of air contaminants are causing or may cause imminent danger to human health.

Additionally, near-real time ambient air monitoring data for O3 is posted on DAQ’s website.

Element

(J)

Requires States to meet applicable requirements of part C related to prevention of significant deterioration and 

visibility protection.

Title I, Part C of the CAA requires states to provide measures relating to PSD and visibility protection. The following AQRs contain 

provisions for PSD areas and visibility protection, as well as provisions for public participation:

• Section 12.1 - Permit Requirements for Minor Sources;

• Section 12.2 - Permit Requirements for Major Sources in Attainment Areas;

• Section 12.3 - Permit Requirements for Major Sources in Nonattainment Areas;

• Section 12.4 - Authority to Construct Application Permit Requirements for Part 70 Sources

• Section 12.11 - General Permits for Minor Stationary Sources;

• Section 25 - Affirmative Defense For Excess Emissions Due to Malfunctions 
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Element

(K)

Air quality modeling/data:

Requires SIPs to provide for the performance of air quality modeling for predicting effects on air quality of emissions 

of any NAAQS pollutant and the submission of such data to EPA upon request.

Clark County’s air quality modeling work complies with EPA’s final guidance on the use of models in attainment demonstrations for 

the NAAQS. Clark County uses the latest methods and techniques and documents modeling information and computer model 

performance evaluations. 

Clark County will continue to use air quality models in accordance with approved EPA and DAQ modeling guidance and protocols 

and continue to submit data and modeling results to EPA as requested. 

AQR Section 12.2 - Permit Requirements for Major Sources in Attainment Areas and AQR Section 12.4 - Authority to Construct 

Application and Permit Requirements for Part 70 Sources, provide provisions to require air quality modeling.

Element

(L)

Permitting fees:

Requires SIPs to require each major stationary source to pay permitting fees to cover the cost of reviewing, acting 

upon, implementing and enforcing a permit until such fee requirement is superseded by EPA approval of a fee 

program under Title V of the CAA.

Permit and technical service fees are authorized under AQR Section 18 - Permit and Technical Service Fees. Section 18 includes 

fees for sources subject to the Title V (Part 70) permit requirements.

Clark County will continue to implement and update major stationary source permit fee regulations to comply with the requirements 

of CAA Sections 501-507.
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Element

(M)

Consultation/participation by affected local entities:

Requires SIPs to provide for consultation and participation in SIP development by local political subdivisions 

affected by the SIP.

Clark County consults with key stakeholder committees on policy decisions and technical issues. The Air Quality Technical 

Advisory Committee (TAC) consists of private sector stakeholders as well as local government representatives, and provides input on 

technical and policy decisions. The TAC has an opportunity to provide input on concerns, challenges, and progress in the 

development and implementation of air quality programs in Clark County, but also discusses and recommends solutions to conflicts, 

challenges, or policy issues.

Additionally, NRS 445B.503 requires Clark County to consult with the Southern Nevada Regional Planning Coalition (SNRPC) and 

the Regional Transportation Commission (RTC) before adopting or amending a plan, policy, or program, and conduct hearings to 

solicit public comment.
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ATTACHMENT A 

2012 Annual Monitoring Network Plan 
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ATTACHMENT B

DAQ SIP approved and local-only rules
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Highlighted Sections are currently in the SIP, have been submitted as revisions to the SIP, or are 

programs delegated by EPA to Clark County. All other sections are “local only” rules. 

Section 0 Definitions 

Section 2 Procedures for Adoption and Revision of Regulations and for Inclusion of those Regulations 

in the State Implementation Plan

Section 4 Control Officer

Section 5 Interference with Control Officer

Section 6 Injunctive Relief

Section 7 Hearing Board and Hearing Officer 

Section 8 Persons Liable for Penalties – Punishment: Defense

Section 9 Civil Penalties 

Section 10 Compliance Schedules

Section 12.0 Applicability, General Requirements and Transition Procedures

Section 12.1 Permit Requirements For Minor Sources 

Section 12.2 Permit Requirements For Major Sources In Attainment Areas (Prevention Of Significant 

Deterioration)

Section 12.3 Permit Requirements For Major Sources In Nonattainment Areas

Section 12.4 Authority To Construct Application And Permit Requirements For Part 70 Sources

Section 12.5 Part 70 Operating Permit Requirements

Section 12.6 Confidentiality

Section 12.7 Emission Reduction Credits 

Section 12.9 Annual Emissions Inventory Requirement

Section 12.10 Continuous Monitoring Requirements for Stationary Sources

Section 12.11 General Permits for Minor Stationary Sources

Section 12.12 Transfer of Permit 

Section 12.13 Posting of Permit 

Section 13 National Emission Standards for Hazardous Air Pollutants 

Section 14 New Source Performance Standards

Section 18 Permit and Technical Service Fees

Section 21 Acid Rain Permits

Section 22 Acid Rain Continuous Emission Monitoring

Section 25 Affirmative Defense for Excess Emissions Due to Malfunctions, Startup, and Shutdown

Section 26 Emission of Visible Air Contaminants

Section 27 Particulate Matter from Process Weight Rate

Section 28 Fuel Burning Equipment

Section 32 Reduction of Animal Matter

Section 33 Chlorine in Chemical Processes

Section 40 Prohibitions of Nuisance Conditions 

Section 41 Fugitive Dust

Section 42 Open Burning

Section 43 Odors in the Ambient Air

Section 44 Prohibitions on Planting, Selling, or Offering to Sell Fruitless Mulberry and European Olive 

Trees

Section 45 Idling of Diesel Powered Motor Vehicles

Section 50 Storage of Petroleum Products
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Section 51 Petroleum Product Loading into Tanks, Trucks And Trailers

Section 53 Oxygenated Gasoline Program

Section 70 Emergency Procedures

Section 80 Circumvention

Section 81 Provisions of Regulations Severable

Section 90 Fugitive Dust From Open Areas and Vacant Lots

Section 91 Fugitive Dust From Unpaved Roads, Unpaved Alleys, and Unpaved Easement Roads

Section 92 Fugitive Dust From Unpaved Parking Lots; Material Handling and Storage Yards; and 

Vehicle and Equipment Storage Yards

Section 93 Fugitive Dust From Paved Roads and Street Sweeping Equipment

Section 94 Permitting and Dust Control for Construction Activities
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ATTACHMENT C

Public Participation
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A. 30-day Public Comment Period Notification

Newspaper notification
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DAQ web pages notifications:
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B. Public Comment Report

Public Notice: Las Vegas Review-Journal, December 29, 2012

Public Comment Period: December 30, 2012 to January 29, 2013

Formal Comments Received: None 

Public Hearing: February 19, 2013

Formal Comments Received: None
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C. Board of County Commissioners Meeting – February 5, 2013

Agenda:
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D. Board of County Commissioners Meeting – February 19, 2013
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