The EPA Regional Administrator, Jared Blumenfeld signed the following rule on August 19, 2015 

and EPA is submitting it for publication in the Federal Register (FR). While we have taken steps 

to ensure the accuracy of this version of this rule, it is not the official version. Please refer to the 

official version in a forthcoming FR publication appearing on the Government Printing Office 

website, http://fdsys.gpo.gov/fdsys/search/home.action, and on www.regulations.gov in Docket 

Number EPA-R09-OAR-2015-0316.

6560-50-P 

ENVIRONMENTAL PROTECTION AGENCY 

40 CFR Part 52 

EPA-R09-OAR-2015-0316; FRLApproval and Promulgation of State Implementation Plans; Nevada; Regional Haze 

Progress Report

AGENCY: Environmental Protection Agency. 

ACTION: Proposed rule. 

SUMMARY: The United States Environmental Protection Agency (EPA) proposes to approve a 

revision to the Nevada Regional Haze State Implementation Plan (SIP) submitted by the Nevada 

Division of Environmental Protection (NDEP) to document that the existing plan is adequate to 

achieve established goals for visibility improvement and emissions reductions by 2018. The 

Nevada Regional Haze SIP revision addresses the Regional Haze Rule (RHR) requirements 

under the Clean Air Act (CAA) to submit a report describing progress in achieving reasonable 

progress goals (RPGs) to improve visibility in federally designated Class I areas in Nevada and 

in nearby states that may be affected by emissions from sources in Nevada. EPA is proposing to 

approve Nevada’s determination that the existing Nevada Regional Haze Implementation Plan is 

adequate to meet the visibility goals, and requires no substantive revision at this time. 

DATE: Comments must be received by the designated contact at the address listed below on or 

before [insert date 30 days after date of publication in the Federal Register]. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 2 of 45

ADDRESSES: Submit your comments, identified by Docket ID No. EPA-R09-OAR-2015-

0316, to the Federal eRulemaking Portal: http://www.regulations.gov. Follow the online 

instructions for submitting comments. Once submitted, comments cannot be edited or 

withdrawn. EPA may publish any comment received to its public docket. Do not submit 

electronically any information you consider to be Confidential Business Information (CBI) or 

other information whose disclosure is restricted by statute. If you need to include CBI as part of 

your comment, please visit http://www.epa.gov/dockets/comments.html for instructions. 

Multimedia submissions (audio, video, etc.) must be accompanied by a written comment. The 

written comment is considered the official comment and should include discussion of all points 

you wish to make. 

For additional submission methods, the full EPA public comment policy, and general 

guidance on making effective comments, please visit 

http://www.epa.gov/dockets/comments.html. 

The index to the docket (docket number EPA-R09-OAR-2015-0316) for this proposed 

rule is available electronically at http://www.regulations.gov. Although listed in the index, some 

information is not publicly available, such as CBI or other information that is restricted by 

statute. Certain other material, such as copyrighted material, is publicly available only in hard 

copy form. Publicly available docket materials are available electronically at 

http://www.regulations.gov or in hard copy during normal business hours at the Planning Office 

of the Air Division, AIR-2, EPA Region 9, 75 Hawthorne Street, San Francisco, CA 94105. To 

view hard copies of documents listed in the docket index, EPA requests that you contact the 

individual listed in the FOR FURTHER INFORMATION CONTACT section. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 3 of 45

FOR FURTHER INFORMATION CONTACT: Vijay Limaye, U.S. EPA, Region 9, Planning 

Office, Air Division, AIR-2, 75 Hawthorne Street, San Francisco, CA 94105. Vijay Limaye may 

be reached at telephone number (415) 972-3086 and via electronic mail at 

Limaye.Vijay@epa.gov. 

SUPPLEMENTARY INFORMATION: Throughout this document “we,” “us,” or “our” refer 

to EPA.

Table of Contents 

I. Overview of Proposed Action 

II. Background 

 A. Description of Regional Haze 

 B. History of Regional Haze Rule 

 C. Nevada’s Regional Haze Plan 

III. Requirements for Regional Haze Progress Reports 

IV. Context for Understanding Nevada’s Progress Report 

 A. Framework for Measuring Progress 

 B. Relevant Class I Areas 

 C. Data Sources 

V. EPA’s Evaluation of Nevada’s Progress Report 

A. Status of Implementation of All Measures 

B. Summary of Emission Reductions Achieved 

C. Assessment of Visibility Conditions and Changes at Jarbidge 

D. Analysis of Changes in Emissions 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 4 of 45

E. Assessment of Anthropogenic Emissions Impeding Progress 

F. Assessment of Plan Elements and Strategy 

G. Review of Visibility Monitoring Strategy 

H. Determination of Adequacy 

I. Consultation with Federal Land Managers 

J. Public Participation 

VI. EPA’s Proposed Action 

VII. Statutory and Executive Order Reviews 

I. Overview of Proposed Action 

EPA is proposing to approve NDEP’s determination that the existing Nevada Regional 

Haze Implementation Plan1

 is adequate to achieve the established RPGs (i.e., visibility goals) for 

Class I areas by 2018, and therefore requires no substantive revision at this time. The State’s 

determination and EPA’s proposed approval are based on the Nevada Regional Haze 5-Year 

Progress Report (“Progress Report” or “Report”) submitted by NDEP to EPA on November 18, 

2014, that addresses 40 CFR 51.308(g), (h), and (i) of the RHR.2

 Specifically, we propose to find 

that the Progress Report demonstrates that the emission control measures in the existing Nevada 

Regional Haze SIP are sufficient to enable Nevada, as well as other states with Class I areas 

affected by emissions from sources in Nevada, to meet all established RPGs for 2018 in 

accordance with 51.308(g). As a result, we propose to approve NDEP’s determination that the 

 

1

 The Nevada Regional Haze Implementation Plan consists of the Nevada Regional Haze SIP, submitted to EPA in 

November 2009 and partially approved and partially disapproved by EPA in several related actions in 2012, and the 

partial Regional Haze Federal Implementation Plan (FIP) promulgated in 2012 and revised in 2013, as described 

further below. 

2

 The Progress Report was deemed complete by operation of law on May 18, 2015. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 5 of 45

existing Implementation Plan is adequate, and requires no further substantive revision at this 

time to achieve the established goals for visibility improvement in accordance with 51.308(h). In 

addition, we are proposing to find that NDEP fulfilled the requirements in 51.308(i)(2), (3), and 

(4) regarding State coordination with Federal Land Managers (FLMs). This coordination 

includes providing FLMs with an opportunity for consultation on the Progress Report, describing 

how NDEP addressed any comments from the FLMs, and providing procedures for continuing 

consultation with the FLMs. Finally, we propose to find that NDEP has fulfilled the requirements 

of CAA 110(a) and (l) and 40 CFR 51.102 regarding reasonable notice and public hearings with 

regard to the Progress Report. 

II. Background 

A. Description of Regional Haze 

Regional haze is visibility impairment produced by many sources and activities located 

across a broad geographic area that emit fine particles that impair visibility by scattering and 

absorbing light, thereby reducing the clarity, color, and visible distance that one can see. These 

fine particles also can cause serious health effects and mortality in humans and contribute to 

environmental impacts, such as acid deposition and eutrophication of water bodies. 

The RHR uses the deciview as the principle metric for measuring visibility and for the 

RPGs that serve as interim visibility goals toward meeting the national goal of achieving natural 

visibility conditions by 2064. A deciview expresses uniform changes in haziness in terms of 

common increments across the entire range of visibility conditions, from pristine to extremely 

hazy conditions. Deciviews are determined by using air quality measurement to estimate light 

extinction, and then transforming the value of light extinction using a logarithmic function. A 

deciview is a more useful measure for tracking progress in improving visibility than light 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 6 of 45

extinction because each deciview change is an equal incremental change in visibility perceived 

by the human eye. Most people can detect a change in visibility at one deciview. 

B. History of Regional Haze Rule 

In section 169A(a)(1) of the CAA Amendments of 1977, Congress created a program to 

protect visibility in designated national parks and wilderness areas, establishing as a national 

goal the “prevention of any future, and the remedying of any existing, impairment of visibility in 

mandatory Class I Federal areas which impairment results from manmade air pollution.” In 

accordance with section 169A of the CAA and after consulting with the Department of Interior, 

EPA promulgated a list of 156 mandatory Class I Federal areas where visibility is identified as 

an important value.3

 In this notice, we refer to mandatory Class I Federal areas on this list as 

“Class I areas.” Nevada has one Class I area, Jarbidge Wilderness Area (“Jarbidge”), in the 

northeast corner of the State. 

With the CAA Amendments of 1990, Congress added section 169B to address regional 

haze issues. EPA promulgated a rule to address regional haze on July 1, 1999, known as the 

Regional Haze Rule.4

 The RHR revised the existing visibility regulations in 40 CFR 51.308 to 

integrate provisions addressing regional haze impairment and to establish a comprehensive 

visibility protection program for Class I areas. As defined in the RHR, the RPGs must provide 

for an improvement in visibility for the most impaired days (“worst days”) over the period of the 

implementation plan and ensure no degradation in visibility for the least impaired days (“best 

days”) over the same period.5

 

3

 44 FR 69122, November 30, 1979. 

4

 See 64 FR 35713. 

5

 40 CFR 51.308(d)(1). 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 7 of 45

C. Nevada’s Regional Haze Plan 

NDEP submitted its Regional Haze SIP to EPA on November 18, 2009, as required by 40 

CFR 51.308 for the first regional haze planning period ending in 2018. EPA approved most of 

the Nevada Regional Haze SIP on March 26, 2012,6 with the exception of NDEP’s determination 

of best available retrofit technology (BART) to control emissions of nitrogen oxides (NOX) at the 

Reid Gardner Generating Station (Reid Gardner). EPA published a new proposal on April 12, 

2012, to approve in part and disapprove in part NDEP’s BART determination for NOX at Reid 

Gardner.7

 EPA published a final rule on August 23, 2012, approving NDEP’s BART 

determination for NOX on Units 1 and 2, but disapproving NDEP’s determination for Unit 3 and 

the averaging time for the emission limits at all three units.8 This final rule included a Federal 

Implementation Plan (FIP) for the disapproved elements. EPA subsequently agreed to reconsider 

the compliance date for Units 1, 2, and 3 at Reid Gardner in the FIP, which we extended by 18 

months.9

III. Requirements for Regional Haze Progress Reports 

 The RHR requires states to submit a report every five years in the form of a SIP revision 

to evaluate progress toward achieving the RPGs for each Class I area in the state and for those 

areas outside the state that may be affected by emissions from within the state.10 The first 

progress reports are due five years from the submittal date of each state’s initial Regional Haze 

SIP. Progress reports must be in the form of SIP revisions that comply with the procedural 

 

6

 See 77 FR 17334. 

7

 See 77 FR 21896. 

8

 See 77 FR 50936. 

9

 See proposed rule to grant extension, 78 FR 18280 (March 26, 2013), and final rule granting extension, 78 FR 

53033 (August 28, 2013). 

10 40 CFR 51.308(g). 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 8 of 45

requirements of 40 CFR 51.102 and 51.103. These reports must contain an evaluation of seven 

elements, at a minimum, and include a determination of the adequacy of the state’s existing 

Regional Haze SIP. In summary,11 the seven elements are: 1) a description of the status of 

implementation of all measures included in the current Regional Haze SIP for achieving the 

RPGs in Class I areas within and outside the state; 2) a summary of the emission reductions 

achieved in the state through implementation of these measures; 3) an assessment of visibility 

conditions and changes on the most impaired and least impaired days for each Class I area in the 

state in terms of five-year averages of the annual values; 4) an analysis of changes in emissions 

over the past five years contributing to visibility impairment from all sources and activities 

within the state based on the most recently updated emissions inventory; 5) an assessment of any 

significant changes in anthropogenic emissions within or outside the state over the past five years 

that have limited or impeded progress in reducing pollutant emissions and improving visibility; 

6) an assessment of whether the elements and strategies in the current Regional Haze SIP are 

sufficient to enable the state, or other states affected by its emissions, to achieve the established 

RPGs; and 7) a review of the state’s visibility monitoring strategy and any necessary 

modifications. 

 Based on an evaluation of the factors listed above as well as any other relevant 

information, a state is required to determine the adequacy of its existing Regional Haze SIP.12

The state must take one of four possible actions based on the analysis in its progress report. In 

summary, these actions are to 1) provide a negative declaration to EPA that no further 

substantive revisions to the state’s existing Regional Haze SIP is needed to achieve the RPGs; 2) 

 

11 Please refer to 40 CFR 51.308(g) for the exact requirements. 12 40 CFR 51.308(h). 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 9 of 45

provide notification to EPA and to other states in its region that its Regional Haze SIP is or may 

be inadequate to ensure reasonable progress due to emissions from sources in other states, and 

collaborate with other states to develop additional strategies to address the deficiencies; 3) 

provide notification and available information to EPA that the state’s Regional Haze SIP is or 

may be inadequate to ensure reasonable progress due to emissions from sources in another 

country; or 4) revise its Regional Haze SIP within one year to address the deficiencies if the state 

determines that its existing plan is or may be inadequate to ensure reasonable progress in one or 

more Class I areas due to emissions from sources within the state.13

 A state also must document that it provided FLMs with an opportunity for consultation 

prior to holding a public hearing on a Regional Haze SIP or plan revision.14 A state must include 

a description of how it addressed any comments from the FLMs, and provide procedures for 

continuing consultation with the FLMs.15

IV. Context for Understanding Nevada’s Progress Report 

To facilitate a better understanding of the Progress Report as well as EPA’s evaluation of 

the Report, this section provides background information on how the regional haze program 

applies to Nevada. This information describes the framework for measuring visibility progress, a 

profile of the relevant Class I areas, and the sources of data used in the Progress Report. 

Framework for Measuring Progress: Visibility conditions at Class I areas are described 

by a “haze index” measured in deciviews and calculated using data collected from the 

Interagency Monitoring of Protected Visual Environments (IMPROVE) network monitors. 

 

13 Id. 

14 40 CFR 51.308(i)(2). 

15 40 CFR 51.308(i)(3) and (4). 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 10 of 45

Nevada has an IMPROVE monitor at Jarbidge that is designated “JARB1.” To measure progress 

in deciviews, current visibility conditions (2008-2012) are compared to baseline conditions 

(2000-2004), and to projected conditions at the end of the planning period (2018). A state 

establishes two RPGs for each of its Class I areas: one for the 20 percent best days and one for 

the 20 percent worst days. The RPGs must provide for an improvement in visibility on the 20 

percent worst days and ensure no degradation in visibility on the 20 percent best days, compared 

to average visibility conditions during the baseline period. In establishing the RPG, a state must 

consider the uniform rate of improvement in visibility (from the baseline to natural conditions in 

2064) and the emission reductions measures needed to achieve it. Nevada set the RPGs for 

Jarbidge using atmospheric air quality modeling based on projected emission reductions from 

control strategies in the Nevada Regional Haze SIP as well as emission reductions expected to 

result from other Federal, state and local air quality programs, among other factors. The purpose 

of a progress report is to assess whether a state’s plan is adequate to achieve the established 

RPGs and emissions reductions goals for 2018, and if not, whether additional emission reduction 

strategies are needed. 

Relevant Class I Areas: Nevada’s one Class I area, the Jarbidge Wilderness Area, is 

located within the Humboldt National Forest in the northeastern corner of the State within the 

populated Snake River Basin and less than 10 miles from the Idaho border. The baseline 

visibility conditions (2000-2004) at Jarbidge are 12.07 deciviews (dv) on the worst days and 2.56 

dv on the best days. The RPG for the worst days in 2018 at Jarbidge is 11.05 dv, which is 

slightly under, and therefore better than, the uniform rate of progress (URP) in 2018, which is 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 11 of 45

11.09 dv.16 While a subsequent correction for the worst days in 2018 resulted in projected 

visibility impairment of 11.8 dv on the worst days,17 NDEP has retained the RPG of 11.05 dv for 

Jarbidge. The RPG for the best days in 2018 at Jarbidge is 2.50 dv, which represents a slight 

improvement from baseline conditions. The Progress Report addresses whether Nevada’s RH 

SIP is making adequate progress from the baseline toward these RPGs. 

The Nevada Regional Haze SIP identified 24 other Class I areas located in five 

neighboring states that are potentially affected by emissions of sulfates and nitrates from sources 

in Nevada.18 Based on projections from air quality modeling for 2018, the highest contribution to 

sulfate extinction on the worst days from Nevada’s emissions is 5.6 percent at Zion National 

Park in Utah, and on the best days is 7.2 percent at Sawtooth Wilderness Area in Idaho. For 

nitrate extinction in 2018, Nevada’s highest contribution on the worst days is 20 percent at 

Desolation Wilderness in California, and on the best days is 12.4 percent at Joshua Tree National 

Park in California.19 The remaining 20 Class I areas outside Nevada are projected to have smaller 

fractions of haze attributable to Nevada’s emissions. 

Data Sources: Nevada’s Progress Report is based on information available prior to 

March 2014. For the most part, NDEP relies on technical data and analysis in two reports from 

the Western Regional Air Partnership (WRAP), the regional planning organization that provides 

technical support to western states. The WRAP’s reports are based on monitoring data from the 

 

16 The URP is a straight line from the baseline visibility condition (5-year annual average from 2000-2004) to the 

estimated natural background condition in 2064, as measured on the 20 percent best and worst days. The URP 

values for 2018 are the number of deciviews where the lines drawn to 2064 for best and worst days intersect 2018. 

17 See 76 FR 36464, June 22, 2011, footnote 18 (“In April 2011, the WRAP issued a draft report regarding an error 

in its visibility projections for about 15 Class I areas in the West, including Jarbidge. The draft report indicated that, 

as a result of the error, the projected visibility at Jarbidge in 2018 is 11.8 dv instead of 11.1 dv (rounded up from 

11.05 dv).”). 

18 Nevada Regional Haze State Implementation Plan, Chapter 4.3.3, October 2009. Light extinction is based on a 

model known as Particulate Matter Source Attribution Tracking (PSAT). 

19 76 FR 36459, June 22, 2011. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 12 of 45

IMPROVE network and emissions data from EPA’s National Emissions Inventory (NEI). The 

first report is the “Western Regional Air Partnership Regional Haze Rule Reasonable Progress 

Summary Report,” dated June 28, 2013, which includes Section 6.8 Nevada (Appendix A of the 

Progress Report). This report is based on the time period 2005-2009 and relies on the NEI from 

2008. The WRAP updated the inventory before completing a second report titled “West-Wide 

Jump-Start Air Quality Modeling Study—Final Report” dated September 30, 2013. NDEP also 

uses NEI data from 2011, State emission inventory data for 2012, acid rain data from EPA’s Air 

Market Program Database, and IMPROVE monitoring data from 2008 to 2012 to provide more 

current information and additional analysis. NDEP further relies on the WRAP’s Technical 

Support System and the Visibility Information Exchange Web System as analytic tools. 

V. EPA’s Evaluation of Nevada’s Progress Report 

This section describes Nevada’s Progress Report and EPA’s evaluation of the Report in 

relation to the seven elements listed in 40 CFR 51.308(g), the determination of adequacy in 40 

CFR 51.308(h), the requirement for state and FLM coordination in 40 CFR 51.308(i) and the 

requirements for public participation in CAA section 110(a) and (l) and 40 CFR 51.102. While 

the Progress Report focuses on the elements of the Nevada Regional Haze SIP, the requirements 

in 40 CFR 51.308(g) and (h) apply to "implementation plans," which are defined to include 

approved SIPs and FIPs.20 Accordingly, EPA has considered our regional haze BART FIP for 

Reid Gardner as well as the Nevada Regional Haze SIP in assessing the Progress Report. 

However, as described further below, all three of the BART-eligible units at Reid Gardner have 

 

20 40 CFR 51.302.
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 13 of 45

been shut down. Therefore, the partial disapproval and partial FIP for Reid Gardner does not 

substantively influence our evaluation of the Progress Report. 

A. Status of Implementation of All Measures 

1. NDEP’s Analysis 

The Progress Report describes the status of state and federal measures in the Nevada 

Regional Haze SIP as well as new programs, rules, and legislation that will provide further 

emission reductions before the first phase of the regional haze program ends in 2018. Nevada’s 

measures to control or otherwise reduce emissions that contribute to haze are organized into 

three broad categories: Review of BART Determinations, State Measures Other than BART, and 

Federal Programs.21 The status of measures in each of these categories is summarized below. 

BART Implementation: NDEP describes BART implementation in Nevada and in 

neighboring states that contribute to visibility impairment at Jarbidge. The four BART facilities 

in Nevada are Reid Gardner, Tracy Generating Station (Tracy), Fort Churchill Generating 

Station (Fort Churchill), and Mohave Generating Station (Mohave). Mohave closed in 2005.22

The Nevada Regional Haze SIP requires the remaining three facilities to meet the emission limits 

associated with all BART control measures by January 1, 2015, with the exception of NOX at 

Reid Gardner, which has a compliance date of June 30, 2016, as shown in Table 1. As noted in 

the table, three units at Reid Gardner and two units at Tracy were scheduled to retire by the 

compliance date. Subsequent to NDEP’s submittal of the Progress Report, all five of these units 

 

21 Progress Report, Chapter Two, Status of Implementation of Control Measures, pages 2-1 thru 2-13. 

22 Even though Mohave’s closure in 2005 predates the first phase of the RH program (2008-2018), NDEP addresses 

Mohave’s emissions in its Progress Report because these emissions are included in the inventories and modeling 

that form the basis for the Nevada Regional Haze SIP. For example, the projected emission inventory for 2018 

includes about 19,595 tpy of NOX and 8,701 tpy of SO2 from Mohave. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 14 of 45

were shut down and are now in the process of being decommissioned and demolished.23 The 

retirement of these five units, and the switching of three other units at Tracy and Fort Churchill 

to natural gas, is largely in response to the passage of Senate Bill (SB) 123 by the Nevada 

legislature in 2013, which is described in more detail in the next section regarding other State 

measures. 

TABLE 1—STATUS OF BART CONTROL MEASURES

Facility Units BART Control Measures 

Reid Gardner 

Generating Station 

1, 2, 3 NV Energy retired these three units as of December 31, 2014, 

as approved by the Public Utilities Commission of Nevada 

(PUCN) 

Tracy Generating 

Station 

1, 2 NV Energy retired these two units as of December 31, 2014, 

as approved by the PUCN and in response to SB 123. 

3 NV Energy is relying on alternative control technology and 

burning only natural gas to comply with the BART emissions 

limits as of the December 31, 2014, compliance date. 

Fort Churchill 

Generating Station 

1, 2 NV Energy is relying on alternative control technology and 

burning only natural gas to comply with the BART emissions 

limits as of the December 31, 2014, compliance date. 

Mohave 

Generating Station 

All This facility ceased operations in December 2005 and was 

subsequently fully decommissioned and demolished. 

 NDEP explains in the Progress Report that BART implementation in neighboring states 

is expected to contribute to visibility improvement at Jarbidge, which is located very near the 

Idaho border and downwind from sources in Oregon. Since source apportionment modeling 

identified substantial contributions of sulfur dioxide (SO2) from point sources in Idaho and 

Oregon,24 NDEP provides updates on two facilities in Idaho (Amalgamated Sugar Company in 

Nampa and Monsanto/P4 Production in Soda Springs) and one facility in Oregon (Boardman 

 

23 See Reid Gardner Generating Station Fact Sheet from Nevada Energy (May 2015), Frank A. Tracy 

Generating Station Fact Sheet from Nevada Energy (June 2015). 

24 Nevada Regional Haze SIP, Section 4.3, November 2009. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 15 of 45

Power Plant) that are subject to BART control measures. Each of these three facilities is 

reportedly in compliance with the required BART emission limits for SO2 and NOX. However, 

since some of the compliance dates are not yet effective, more emission reductions are expected 

by 2018. 

Other State Measures: Other State measures contributing to reasonable progress at 

Jarbidge and other Class I areas include cancellations of applications to build power plants, State 

legislation to reduce emissions from coal-fired power plants (i.e., SB 123), an expanded 

renewable energy portfolio, and implementation of control measures to attain the National 

Ambient Air Quality Standards (NAAQS) as listed in Table 2. Regarding cancellations, NDEP 

explains that these measures represent additional emission reductions because the emissions 

from these unbuilt sources were included in the baseline and projected emission inventories in 

the Nevada Regional Haze SIP. Of the five proposed power plants that NDEP assumed would be 

producing emissions, three withdrew applications (White Pine, Toquop, and Copper Mountain), 

and two were built (Newmont TS Power Plant near Dunphy in northern Nevada and Chuck 

Lenzie Generating Station near Las Vegas).25 

The Nevada Legislature in 2013 enacted SB 123 requiring the reduction of emissions 

from coal-fired power plants in Clark County, Nevada. SB 123 requires the retirement or 

elimination of not less than 800 megawatts of coal-fired electric generating capacity: 300 MW by 

December 2014, an additional 250 MW by December 2017, and an additional 250 MW by 

December 2019. This legislation also mandates the construction or acquisition of 350 MW from 

new renewable energy facilities. NV Energy must construct or acquire and own facilities with a 

 

25 Newmont TS is a 220-megawatt power plant using coal-fired boilers with modern control technologies operating 

since 2008. Chuck Lenzie is 1,102-megawatt generating station using gas-fired steam engines operating since 2006. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 16 of 45

total capacity of 550 MW to replace the coal-fired capacity eliminated between 2014 and 2019.26

NV Energy’s decision to retire BART units at Reid Gardner and Tracy, and to convert other 

BART units to natural gas at Tracy and Fort Churchill, was in response to this legislation. 

 NDEP also reports that Nevada is one of the first states to adopt a renewable portfolio 

standard that establishes a schedule requiring electric utilities to generate, acquire, or save a 

percentage of electricity from renewable energy systems or efficiency measures. Not less than 20 

percent must come from renewable energy or efficiency measures from 2015 to 2019. The 

Nevada legislature also has enacted the “Solar Energy Systems Incentive Program,” which 

requires the Public Utilities Commission of Nevada to set incentives and schedules to produce at 

least 250 MW of capacity from solar energy by 2021. At the time of the Progress Report, Nevada 

had installed 38 MW of capacity at a cost of $160 million. Another example of renewable energy 

is the “Solar Thermal Demonstrations Program” that promotes the installation of at least 3,000 

solar thermal systems in homes, businesses, schools, and government buildings throughout the 

State. The Progress Report mentions several other programs to establish solar, wind, and 

waterpower energy systems along with a list of proposed generation plants that will rely on 

renewable energy.27 

TABLE 2—STATUS OF OTHER STATE MEASURES

State Measure Effective Date 

Three Power Plants included in Inventory for 2018 Never Built 

Legislation to Retire Coal-Fired Plants (800 mw) 2014 – 2019 

Legislation for New Renewable Energy (350 mw) 2014 – 2021 

Renewable Energy Portfolio 2015 – 2025 

NAAQS Attainment/Maintenance Regulations Ongoing 

 

26 Public Utilities Commission of Nevada, Docket No. 14-05003, May 1, 2014, (Appendix C). 

27 Progress Report, Chapter 2, pages 2-8 thru 2-9. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 17 of 45

Federal Measures: The Progress Report provides a summary of existing federal 

measures, those that were included in the Nevada Regional Haze SIP, as well as new federal 

measures as listed in Table 3. NDEP describes in the Report how each of these federal programs, 

rules, and standards contribute further reductions in visibility impairing pollutants.28 All eight 

areas in Nevada that were designated non-attainment for one more NAAQS either have been 

redesignated to attainment and are operating under a maintenance plan or have a determination 

of attainment indicating that the area is attaining the NAAQS. The control measures for 

attainment that remain in place include fugitive dust regulations, oxygenated fuel programs, 

gasoline vapor recovery, transportation control measures, residential wood burning regulations, 

woodstove replacement programs, and alternative fuel vehicle program. 

 

 

28 Progress Report, Chapter 2, pages 2-3 thru 2-6. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 18 of 45

TABLE 3—STATUS OF FEDERAL MEASURES 

Existing Federal Measures 

Heavy Duty Highway Rule (PM, NOX, SOX) Phased in 2006 - 2010 

Tier 2 Vehicle and Gasoline Program (NOX, VOC) Effective in 2005 

Non-Road Mobile Diesel Emissions Program (NOX, CO) Phased in 2004 - 2012 

Maximum Achievable Control Technology Program Ongoing Applicability 

New Federal Measures 

Mercury and Air Toxics Rule (Toxic Gases, SO2) Final Rule in 2011 

Revised NAAQS for Sulfur Dioxide Final Rule in 2010 

Revised NAAQS for Nitrogen Dioxide Final Rule in 2010 

Revised NAAQS for Fine Particulate Matter Final Rule in 2012 

North American Emission Control Areas (NOX, PM2.5, SO2) Effective in 2012; 2015 

Tier 3 Vehicle Emission and Fuel Standards Program (SOX) Effective in 2017 

PM = Particulate Matter 

VOC = Volatile Organic Compounds 

2. EPA’s Evaluation 

EPA proposes to find that NDEP adequately addresses the requirement in 40 CFR 

51.308(g)(1) to describe the status of all measures included in the Nevada Regional Haze SIP. 

NDEP provides a detailed and comprehensive update of state and federal measures, including 

new measures that are expected to contribute further to visibility improvement. The Progress 

Report’s description of BART implementation, legislation, programs, and rules provides a 

thorough summary of the regulatory requirements that underpin Nevada’s regional haze 

program. 

B. Summary of Emission Reductions Achieved 

1. NDEP’s Analysis 

The Progress Report focuses on SO2 and NOX emissions, which are the primary 

pollutants of concern from anthropogenic sources. NDEP reports that SO2 and NOX emissions 

have decreased substantially in Nevada due to the implementation of control measures as well as 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 19 of 45

other changes in State energy policy and source activity as described above in the status of 

measures. According to EPA’s acid rain data,29 annual SO2 emissions from Electricity 

Generating Units (EGUs) in Nevada decreased by 44,107 tpy (82 percent) from 53,346 tpy in 

2005 to 9,239 tpy in 2006. Similarly, NOX emissions from power plants decreased by 23,257 tpy 

(54 percent) from 43,242 tpy in 2005 to 19,985 tpy in 2006. NDEP points out that while these 

large decreases from 2005 to 2006 are mostly due to the closure of Mohave Generating Station, 

emissions continued to decrease steadily thereafter. From 2006 to 2013, power plant emissions 

of SO2 decreased by about 20 percent (9,239 to 7,427 tpy) and NOX emissions decreased by 

about 61 percent (19,985 to 7,796 tpy).30 The closure of units at Reid Gardner and Tracy, and the 

implementation of control measures on other units at Tracy and Fort Churchill, should contribute 

further emission reductions not reflected in the acid rain data for 2013. 

The Progress Report also quantifies emission reductions resulting from the cancellation 

of plans to construct three power plants and lower actual emissions from the two plants that were 

built. NDEP includes this analysis because projected emissions from these five sources are 

included in the emission inventory for 2018 that provides the basis for the RPG at Jarbidge. The 

reductions due to permit cancellations are 5,814 tpy of SO2, 6,136 tpy of NOX, and 5,814 tpy of 

particulate matter (PM10). Moreover, the two new plants that were built (Newmont and Chuck 

Lenzie) have combined actual emissions in 2012 that are less than projected for the emission 

inventory in 2018.31 NDEP states that these unrealized emissions, in effect, would result in lower 

modeled visibility impairment in 2018, particularly at Class I areas near southern and eastern 

 

29 USEPA Clean Air Markets Division, Air Markets Program Data, Acid Rain Program. 30 Progress Report, Chapter 3, Table 3-2, page 3-5. 

31 Progress Report, Chapter 3, Table 3-1, page 3-4. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 20 of 45

Nevada where the two built sources are located and the three cancelled sources had planned to 

locate. 

2. EPA’s Evaluation 

EPA proposes to find that NDEP adequately addresses the requirement in 40 CFR 

51.308(g)(2) to provide a summary of the emission reductions from implementing the measures 

in the Nevada Regional Haze SIP. NDEP documents that SO2 and NOX emissions from 

Nevada’s power plants have decreased substantially, especially due to the closure of Mohave. 

NDEP makes the case that emissions from the power sector should continue to decline as BART 

controls and SB 123 are implemented, further reducing emissions from Reid Gardner, Tracy, and 

Fort Churchill. While it is difficult to quantify emission reductions from other state and federal 

programs, we agree that other state and federal measures should contribute to declining 

emissions, particularly from mobile and stationary sources. While the cancellation of proposed 

facilities does not constitute emission reductions per se, we recognize that the inclusion of these 

projected emissions in the 2018 inventory likely inflated the projected emissions used as the 

basis of the RPGs for Jarbidge and Class I areas affected by Nevada’s emissions. We also note 

that NDEP’s summary of emission reductions is complemented by its analysis of recent changes 

in emissions from all sources in Section D of this proposal. 

 C. Assessment of Visibility Conditions and Changes at Jarbidge 

 1. NDEP’s Analysis 

Current Visibility Conditions: NDEP reports on current visibility conditions for the 20 

percent worst days and 20 percent best days at Jarbidge for the five-years from 2008 to 2012 as 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 21 of 45

displayed in Table 4.32 The five-year annual average haze index at Jarbidge for this current time 

period is 12.0 dv on worst days and 1.9 dv on best days. On worst days, the annual averages for 

visibility impairment are strongly influenced by light extinction due to particulate organic matter 

(POM), followed by coarse mass and sulfate. On the best days, visibility impairment is 

dominated by light extinction due to sulfate, followed by POM and coarse mass. The Progress 

Report notes that sources of POM are predominantly natural, while sources of fine soil and 

coarse mass are about equally split between natural and anthropogenic. The dominant source of 

sulfate is SO2 from anthropogenic sources. 

TABLE 4—CURRENT ANNUAL AND FIVE-YEAR ANNUAL AVERAGE VISIBILITY 

CONDITIONS FOR WORST AND BEST DAYS AT JARBIDGE33

Year Haze 

Index 

(dv) 

Sulfate 

(Mm-1) 

Nitrate 

(Mm-1) 

POM 

(Mm-1) 

EC 

(Mm-1) 

Soil 

(Mm-1) 

Coarse 

Mass 

(Mm-1) 

Sea Salt 

(Mm-1) 

Worst Days 

2008 12.5 3.72 1.12 12.06 1.48 2.61 4.84 0.04

2009 11.1 4.43 0.53 7.32 1.12 2.31 5.66 0.30

2010 10.0 3.30 1.04 4.33 0.77 2.49 5.66 0.06

2011 11.7 4.16 0.67 7.71 1.21 2.49 6.85 0.40

2012 14.9 3.87 1.18 23.97 3.11 2.63 5.17 0.21

Average 12.0 3.9 0.9 11.1 1.5 2.5 5.6 0.2

Best Days 

2008 1.9 1.14 0.22 0.23 0.09 0.12 0.27 0.05

2009 1.8 0.95 0.16 0.31 0.11 0.12 0.28 0.03

2010 1.8 1.09 0.15 0.30 0.12 0.06 0.24 0.03

2011 2.1 1.21 0.19 0.39 0.13 0.10 0.26 0.07

2012 2.0 0.95 0.18 0.37 0.18 0.10 0.37 0.04

Average 1.9 1.1 0.2 0.3 0.1 0.1 0.3 0.0

EC = Elemental Carbon 

 

32 Progress Report, Chapter 4, Table 4-1, page 4-3. 

33 The data on visibility conditions is from the IMPROVE monitor at Jarbidge (JARB1) that measures light 

extinction in terms of inverse megameters (Mm-1) that are directly related to gaseous and aerosol concentrations. 

The haze index is measured in deciviews, which is a metric of haze proportional to the logarithm of the light 

extinction. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 22 of 45

Difference between Current and Baseline Visibility Conditions: NDEP presents the 

difference between the current five-year annual average (2008-2012) and the baseline five-year 

annual average (2000-2004) for Jarbidge, as displayed in Table 5, which also includes successive 

five-year annual averages for the intervening time periods (2005-2009, 2006-2010, and 2007-

2011).34 The differences calculated in the table are between the baseline and the current visibility 

condition represented by the time period 2008-2012. A negative difference indicates a reduction 

in haze (i.e., improved visibility). Comparing baseline to current visibility conditions on worst 

days, the haze index declined slightly (12.1 to 12.0 dv) with corresponding decreases in light 

extinction for sulfate, nitrate, and elemental carbon, but a noticeable increase in POM. On the 

best days, the haze index decreases from the baseline to current visibility conditions (2.6 to 1.9 

dv) with corresponding decreases in light extinction for sulfate, nitrate, POM, and elemental 

carbon, with the three other pollutants remaining the same. 

NDEP also analyzes the relative percentage contribution and rank of each pollutant to 

visibility impairment on the worst and best days for the five-year annual average baseline and 

successive five-year time periods, as displayed in Table 5.35 This analysis reveals that POM 

(ranging from 35.5 to 43.0 percent), coarse mass (21.9 to 26.1 percent), and sulfate (15.1 to 17.0 

percent) rank first, second, and third, respectively, as the largest contributors to light extinction 

on worst days in each of the five-year periods from the baseline to current time period. On the 

worst days, POM dominates the contributions to visibility impairment for the baseline as well as 

all subsequent time periods. The data for sulfate and nitrate show small but continued 

improvement on worst days based on these five-year annual averages. 

 

34 See Progress Report, Chapter 4, Table 4-2, page 4-4. 

35 Progress Report, Table 4-4, Percent Contribution to Aerosol Extinction by Species, page 4-10. These results 

excluded Rayleigh and are expressed as a percentage of Mm-1. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 23 of 45

On the best days for each five-year period of annual averages, sulfate (ranging from 4.10 

to 50.5 percent), POM (15.1 to 26.1 percent), and coarse mass (12.4 to13.2 percent) rank first, 

second, and third except for the baseline period in which nitrate is third, contributing 9.8 percent. 

On average across all five-year periods, nitrate and elemental carbon each contribute about 10 

percent to visibility impairment on best days. NDEP explains that the sulfate contribution is most 

likely high because best days represent times when there are fewer emissions from natural 

sources, resulting in relatively higher contribution to impairment from anthropogenic emissions. 

Although the ranking changes from worst days to best days, POM, coarse mass, and sulfate are 

the three largest contributors to visibility impairment at Jarbidge. 

TABLE 5—BASELINE AND FIVE-YEAR ANNUAL AVERAGE VISIBILITY CONDITIONS FOR THE 

WORST AND BEST DAYS AT JARBIDGE

Time Period Haze 

Index 

(dv) 

Sulfate 

(Mm-1) 

Nitrate 

(Mm-1) 

POM 

(Mm-1) 

EC 

(Mm-1) 

Soil 

(Mm-1) 

Coarse 

Mass 

(Mm-1) 

Sea Salt 

(Mm-1) 

Worst Days 

Baseline 12.1 4.0 1.1 10.0 1.6 2.4 5.5 0.1

2005-2009 12.4 4.4 1.4 10.0 1.7 2.6 5.9 0.2

2006-2010 12.2 4.0 1.1 9.6 1.6 2.7 6.1 0.1

2007-2011 11.7 3.9 1.0 8.4 1.2 2.7 6.2 0.2

2008-2012 12.0 3.9 0.9 11.1 1.5 2.5 5.6 0.2

Difference -0.1 -0.1 -0.2 1.1 -0.1 0.1 0.1 0.1

Best Days 

Baseline 2.6 1.2 0.3 0.8 0.3 0.1 0.3 0.0

2005-2009 2.2 1.1 0.2 0.5 0.2 0. 0.3 0.0

2006-2010 2.0 1.1 0.2 0.4 0.1 0.1 0.3 0.0

2007-2011 2.0 1.1 0.2 0.3 0.1 0.1 0.3 0.0

2008-2012 1.9 1.1 0.2 0.3 0.1 0.1 0.3 0.0

Difference -0.7 -0.1 -0.1 -0.5 -0.2 0.0 0.0 0.0

To support its analysis of current conditions, NDEP presents a set of rolling five-year 

averages of the annual averages, and includes the current estimate of natural conditions, as 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 24 of 45

shown in Table 6.36 The rolling five-year average of the annual averages reveals more clearly the 

trend in visibility conditions over time. 

TABLE 6—FIVE-YEAR ANNUAL AVERAGE HAZE INDEX FOR BASELINE AND SUCCESSIVE 

TIME PERIODS MEASURED AT JARB1 (IN DECIVIEWS) 

Days 

Measured 

(20 Percent) 

Baseline 

Conditions 

Interim Five-Year Time Periods Current 

Conditions 

Natural 

Conditions

2000-2004 2005-2009 2006-2010 2007-2011 2008-2012 2064 

Worst 12.1 12.4 12.2 11.7 12.0 7.9

Best 2.6 2.2 2.0 2.0 1.9 1.1

NDEP also presents the change in visibility conditions between the baseline and current 

period for best and worst days in comparison to the RPG in 2018 using the 2008 to 2012 average 

as displayed in Table 7.37 While visibility on the best days shows improvement, only modest 

progress is shown for the worst days due to significant contribution of POM to light extinction at 

Jarbidge, particularly in 2012 as shown in Table 4. 

TABLE 7—REASONABLE PROGRESS GOAL SUMMARY FOR JARBIDGE

(IN DECIVIEWS) 

Best Days Worst Days 

Baseline 

(2000-

2004) 

Current 

(2008-

2012) 

Visibility 

Improvement 

Baseline

(2000-

2004) 

Current 

(2008-

2012) 

Visibility 

Improvement 

2018 

RPG 

Progress 

in 2012 

to 2018 

RPG 

2.6 1.9 0.7 12.1 12.0 0.1 11.05 9.5% 

 Changes in Visibility Impairment over Past Five Years: The distinguishing feature of 

annual visibility impairment on the worst days from 2008 to 2012 is the variability of light 

extinction due to POM and its corresponding effect on the haze index as shown in Table 4. While 

 

36 Progress Report Table 4-3, page 4-6. 

37 Progress Report Table 4-6, page 4-14. This table omits the RPG for the best days, which is 2.56 dv. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 25 of 45

light extinction for other pollutants is relatively flat during this current five-year period, POM 

varies by almost 20 Mm-1, from a low of 4.33 Mm-1 in 2010 to a high of 23.97 Mm-1 in 2012. 

Levels of POM spiked in 2012, which NDEP attributes to emissions from wildfires. As the table 

shows, on the worst days POM has a strong influence on the year-to-year variability in visibility 

conditions, and can cause a corresponding increase in the 2008-2012 five-year annual average. 

Visibility impairment on worst days generally has not changed much over the five years except 

for the variations due to light extinction from POM. Visibility on best days, by contrast, 

generally is improving over the current time period with little variability from year to year. For 

the best days, there is a noticeable reduction in visibility impairment due to sulfate, nitrate, POM, 

and elemental carbon. 

NDEP presents a trend analysis for the period from 2000 to 2012, focusing on sulfates 

and nitrates, as an annual average and as a rolling five-year average during this 13-year time 

period based on IMPROVE data.38 Analyzing this longer time period demonstrates that on the 

worst and best days visibility impairment resulting from light extinction due to sulfate and nitrate 

is improving over time, both on an annual basis as well as five-year annual averages. NDEP also 

includes an analysis showing the effect of a large spike in nitrates in December 2005 (41 Mm-1) 

that increases the annual average as well as all the five-year averages that include data from 

2005. 

2. EPA’s Evaluation 

EPA proposes to find that NDEP adequately addresses the requirement in 40 CFR 

51.308(g)(3) to assess the visibility conditions and changes in each of the State’s Class I areas 

 

38 Nevada RH Progress Report, Chapter 4, Figures 4-12 through 4-15, pages 4-15 thru 4-19. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 26 of 45

for the least and most impaired days in terms of the current conditions, difference between 

current and baseline conditions, and over the past five years. The analysis indicates that visibility 

on the best days at Jarbidge is getting better, but that visibility on the worst days is flat or only 

minimally improving. However, NDEP offers compelling evidence that light extinction due to 

POM has dominated visibility conditions on the worst days, particularly in 2012 as shown in 

Table 4. 

D. Analysis of Changes in Emissions

1. NDEP’s Analysis 

 NDEP relies on the WRAP’s analysis39 to describe the changes in emissions from the 

baseline40 in 2002 to the emissions inventory in 2008, the beginning of Nevada’s current fiveyear time period. NDEP also uses NEI data from 2008 to 2011 to augment its analysis.41 As 

shown in Table 8, emissions of all visibility-impairing pollutants decreased from the baseline 

inventory to 2008, except for fine soil and coarse mass. Notably, actual emissions in 2008 are 

lower than the projected 2018 emissions for all pollutants, with the exception of fine soil and 

coarse mass. For example, point source emissions of SO2 decreased by 78 percent, while point 

source emissions of NOX decreased by over 50 percent from the baseline to 2008. These large 

reductions in the anthropogenic emissions of SO2 and NOX represent a successful strategy of 

reducing anthropogenic emissions within the State. NDEP notes that the increase in fine soil and 

coarse mass are likely due to updates in inventory development methods rather than actual 

 

39 WRAP Regional Haze Rule Reasonable Progress Summary Report, June 28, 2013. West-Wide Jump-Start Air 

Quality Modeling Study—Final Report, September 30, 2013. 40 WRAP refers to the baseline as 2002, the midyear of the baseline inventory period from 2000 to 2004. 

41 Data from the NEI are slightly different from the WestJump2008 inventory, which leverages more recent 

inventory development performed by the WRAP. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 27 of 45

increases, which is plausible given the small changes in soil and coarse mass observed at the 

Jarbridge monitor. 

TABLE 8—COMPARISON OF EMISSION INVENTORIES IN 2002, 2008, AND 2018 FOR NEVADA

OF ALL VISIBILITY IMPAIRING POLLUTANTS42

 

Pollutants 2002 Baseline 

(tpy) 

2008 Inventory 

(tpy) 

2018 Projection 

(tpy) 

2008 Actuals as 

a Percent of 

2018 Projections 

Sulfur Dioxide 67,743 17,058 46,224 37%

Nitrogen Oxides 162,397 119,513 135,496 88%

Ammonia 12,092 9,382 14,503 65%

Volatile Organic 

Compounds 

897,102 351,142 897,707 39%

Primary Organic 

Aerosol 

24,734 11,816 24,822 48%

Elemental 

Carbon 

6,409 4,425 5,638 78%

Fine Soil 21,208 40,301 24,134 167%

Coarse Mass 161,142 321,257 188,287 171%

NDEP analyzes the differences between the baseline and current emissions based on 

WRAP’s WestJump2008 inventory for eight categories of emissions as summarized below. This 

analysis focuses on the percentage change in the emissions of each pollutant by source category 

in 2002 and 2008, and adds an analysis of changes in emissions from 2008 to 2011 where NEI 

data is available. 

Sulfur Dioxide: Total anthropogenic emissions of SO2 decreased by 75 percent from 

65,543 tons in 2002 to 16,552 tons in 2008, representing a significant reduction in particular 

from point and area sources as shown in Table 9. Point source emissions alone decreased by 78 

percent (50,720 to 11,067 tpy) during this period, and area source emissions decreased by 63 

percent (12,953 to 4,863 tpy). As a percentage of total statewide emissions, anthropogenic and 

 

42 The WRAP compared data between the baseline (2002) and emission inventory (2008) for nine source categories: 

point sources, area sources, oil and gas, on-road mobile, off-road mobile, fugitive dust and road dust, windblown 

dust, biogenic, and fires. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 28 of 45

natural, point source emissions decreased from 75 percent of the total in the 2002 (50,720 of 

67,743 tons) to 65 percent of the total in the 2008 (11,067 tons of a total 16,552 tons). Moreover, 

the NEI inventories show a further decrease in SO2 emissions from point sources of 44 percent 

from 10,409 tpy in 2008 to 5,863 tpy in 2011, primarily due to reductions in coal-fired emissions 

from power plants. On-road and off-road mobile emissions decreased by 34 percent (454 to 298 

tpy) and 77 percent (1,403 to 322 tpy), respectively, from 2002 to 2008. Data from the NEI 

indicate further reductions in emissions from mobile sources from 2008 to 2011, a 47 percent 

decrease in on-road emissions (511 to 270 tpy) and a 87 percent decrease in off-road emissions 

(316 to 41 tpy). 

TABLE 9—CHANGES IN SULFUR DIOXIDE EMISSIONS BY CATEGORY (TPY) 

Source Category 2002 

(Baseline) 

2008 

(WestJump2008) 

Difference 

(Percent Change) 

Anthropogenic Sources 

Point 50,720 11,067 -39,653 (-78%)

Area 12,953 4,863 -8,090 (-62%)

On-Road Mobile 454 298 -156 (-34%)

Off-Road Mobile 1,403 322 -1,081 (-77%)

Area Oil and Gas 0 0 0

Fugitive and Road Dust 0 0 0

Anthropogenic Fire 12 2 -10 (-83%)

Total Anthropogenic 65,543 16,552 -48,991 (-75%)

Natural Sources 

Natural Fire 2,200 506 -1,694 (-77%)

Biogenic 0 0 0

Windblown Dust 0 0 0

Total Natural 2,200 506 -1,694 (-77%)

All Sources 

Total Emissions 67,743 17,058 -50,685 (-75%)

Nitrogen Oxides: The total statewide inventory of NOX emissions from all sources 

decreased by 26 percent from 162,397 tpy in 2002 to 118,766 tpy in 2008 as shown in Table 10. 

Over this time period, NOX emissions from anthropogenic sources decreased by 23 percent 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 29 of 45

(139,353 tpy to 107,827 tpy), and natural emissions decreased by 53 percent (23,044 tpy to 

10,939 tpy). Anthropogenic emissions of NOX in Nevada are primarily from point and on-road 

mobile sources, followed by off-road and area sources. From the 2002 to 2008 inventories, NOX

emissions from point sources decreased by about 50 percent (59,864 to 29,344 tpy), on-road 

mobile increased by about 22 percent (41,089 to 50,068 tpy), off-road mobile decreased by about 

48 percent (32,565 to 17,081 tpy), and area sources increased by 98 percent (5,725 to 11,321 

tpy). Increases in on-road mobile and area source emission inventories were offset by larger 

decreases in emissions from point and off-road mobile sources. The NEI point source inventory 

shows a decrease of 57 percent in NOX emissions from 2008 to 2011. NDEP attributes the 22 

percent increase in on-road mobile emissions to the use of different air quality models to 

estimate emissions in 2002 (MOBILE6) and in 2008 (MOVES2010), a growth in the number of 

vehicles, and the fact that federal vehicle emissions standards were not fully implemented. NEI 

data from 2008 and 2011 show a 36 percent increase in on-road mobile NOX emissions, possibly 

related to population growth. The NEI shows a continuing decrease in off-road mobile emissions 

of 12 percent from 2008 to 2012. NDEP states that the increase in emissions from area sources 

may be a result of a reclassification of some off-road mobile sources into area source category, 

which may have contributed to the decrease in emissions from off-road mobile sources. This is 

consistent with the reclassification of in-flight aircraft emissions and locomotive emissions 

outside of rail yards from the off-road mobile category to the area source category in the 2008 

NEI.43

TABLE 10—CHANGES IN NITROGEN OXIDE EMISSIONS BY CATEGORY (TPY) 

Source Category 2002 2008 Difference 

 

43 See http://www.epa.gov/ttnchie1/net/2008inventory.html (“Description of NEI Data Categories”)
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 30 of 45

(Baseline) (WestJump2008) (Percent Change) 

Anthropogenic Sources 

Point 59,864 29,344 -30,520

Area 5,725 11,321 5,597

On-Road Mobile 41,089 50,068 8,979

Off-Road Mobile 32,565 17,081 -15,484

Area Oil and Gas 63 0 -63

Fugitive and Road Dust 0 0 0

Anthropogenic Fire 48 13 -35

Total Anthropogenic 139,353 107,827 -31,526 (-23%)

Natural Sources 

Natural Fire 8,026 3,575 -4,451

Biogenic 15,018 7,364 -7,654

Windblown Dust 0 0 0

Total Natural 23,044 10,939 -12,105 (-53%)

All Sources 

Total Emissions 162,397 118,766 -43,631 (-26%)

Ammonia: Total statewide emissions of ammonia decreased by 22 percent (12,092 to 

9,382 tpy) from 2002 to 2008. Of this total, anthropogenic emissions decreased by 34 percent 

(10,408 to 6,893 tpy) while natural emissions increased by 48 percent (1,684 to 2,490 tpy). The 

primary source of anthropogenic emissions of ammonia is area sources, and to a lesser extent onroad mobile sources, while fire is the dominant natural source.44 Area sources of ammonia 

emissions decreased by about 29 percent (8,009 to 5,717 tpy) from 2002 to 2008. On-road 

mobile sources, the next largest category of anthropogenic emissions, decreased by about 58 

percent (2,030 to 849 tpy). Despite an increase of 48 percent in natural fire (1,684 to 2,490 tpy), 

there was a net decrease in statewide emissions. Ammonia is not a criteria pollutant and is not 

included in the NEI, so no data for 2011 were provided. 

 

44 The WRAP has created an operational policy level definition of fire activity as discretely natural or 

anthropogenic. See the WRAP Regional Haze Rule Reasonable Progress Summary Report, section 3.2.1 and the 

WRAP’s Policy for Categorizing Fire Emissions (November 15, 2001), available at 

http://www.wrapair.org/forums/fejf/documents/nbtt/FirePolicy.pdf.
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 31 of 45

Volatile Organic Compounds: Data from the 2002 and 2008 inventories as well as from 

the NEI for the 2008 to 2011 time period show large reductions in volatile organic compounds 

(VOC) emissions from natural sources with lesser reductions from anthropogenic sources. 

Biogenic emissions from natural sources dominate the Nevada VOC emissions inventory. Total 

statewide VOC emissions decreased by 61 percent from 897,102 tpy in 2002 to 351,142 tpy in 

2008. This large reduction is mostly due to a decrease in biogenic emissions over this time 

period by 67 percent from 794,139 tpy to 262,912 tpy. NDEP notes that these changes may 

reflect enhancements to the inventory method, use of different meteorological years, and 

improved emission factors and data sources. There were also decreases in on-road mobile 

(36,257 to 21,302 tpy) and natural fire (17,606 to 4,204 tpy), and an increase in area sources 

(28,592 to 40,973 tpy), all of which are a very small part of the total inventory. VOC emissions 

in the NEI show a decrease in point source (17 percent), on-road mobile (20 percent), and off 

road mobile (18 percent) from 2008 to 2011. 

Primary Organic Aerosol: Wildfires are the dominant source of primary organic aerosol 

(POA) emissions, 90 percent of the total in 2002 (22,501 of a total 24,734 tpy) and 58 percent in 

2008 (6,831 of a total 11,816 tpy). Anthropogenic sources, namely area and mobile, also are 

important contributors. Overall, total emissions of POA decreased by 52 percent from 2002 to 

2008. Natural fire emissions of POA decreased 70 percent (22,501 to 6,831 tpy), reflecting the 

high variability of wildfires from year to year. Except for anthropogenic fire, all other categories 

of anthropogenic sources of POA (primarily area, mobile, and fugitive) increased during this 

time period with the total anthropogenic emissions increasing by 123 percent from 2,233 to 

4,985 tpy. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 32 of 45

Elemental Carbon: Natural fire (i.e., wildfires) also dominate EC emissions at 73 percent 

of the 2002 inventory (4,674 of 6,409 tpy), but only 23 percent of the 2008 inventory (1,130 to 

4,425 tpy), a reduction of 76 percent (4,674 to 1,130 tpy). Consequently, total emissions 

decreased by 31 percent (6,409 to 4,425 tpy) mostly due to the decrease in natural fire. Total 

anthropogenic emissions increased by 90 percent (1,735 to 3,295 tpy) due mostly to an increase 

in on-road mobile sources from 235 to 1,891 tpy over this time period. On-road mobile is the 

largest source of elemental carbon in the 2008 inventory at 43 percent, while the next largest 

category is natural fire emissions contributing 26 percent. Area and point sources, by contrast, 

contribute less than one percent each to the 2008 inventory. 

Fine Soil: Total emissions of fine soils increased by 90 percent (21,208 to 40,301 tpy) 

from the 2002 to the 2008 inventory. The largest increases were in fugitive dust (6,128 to 19,216 

tpy) and windblown dust (10,438 to 17,051 tpy). NDEP reports that increases in these source 

categories were likely due to updates to inventory development methods rather than actual 

increases. 

Coarse Mass: Total emissions of coarse mass increased by about 99 percent (161,142 to 

321,257 tpy), mostly due to large increases in anthropogenic fugitive and road dust (56,799 to 

161,532 tpy) and in natural windblown dust (93,946 to 153,459 tpy). Fugitive dust includes 

sources such as agricultural operations, construction, and mining operations. Windblown dust is 

largely from vacant lands. NDEP attributes these increases in part to updates in the inventory 

development methods rather than actual increases. Nonetheless, increases in fugitive dust may be 

due to increases in population, while increases in road dust may be due to increases in vehicle 

miles traveled. Point source and natural fire emissions decreased. 

2. EPA’s Evaluation 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 33 of 45

We propose to find that NDEP adequately addresses the requirement in 40 CFR 

51.308(g)(4) to analyze the change in emissions over the past five years of pollutants 

contributing to visibility impairment from all sources and activities within the state, using the 

most recently updated emission inventories. NDEP’s analysis of emission data makes a strong 

case that the State is reducing emissions of SO2 and NOX from anthropogenic sources, especially 

point sources. 

E. Assessment of Anthropogenic Emissions Impeding Progress 

1. NDEP’s Analysis 

 NDEP reports that progress toward achieving its visibility goal of 11.05 dv at Jarbidge by 

2018 has not been impeded by any significant anthropogenic emission changes within or outside 

the State. NDEP reaches this conclusion by evaluating significant emission changes within 

Nevada, the effect of emissions from sources outside of Nevada on Jarbidge, and the effect of 

Nevada’s emissions on nearby Class I areas. 

Emission Changes within Nevada and Visibility Conditions at Jarbidge: NDEP analyzes 

the baseline and rolling five-year annual averages of light extinction data from the JARB1 

monitor for the best and worst days from 2005 through 2012. For the worst days, the data show a 

reduction in sulfate and nitrate extinction for the three most recent five-year periods (2006-2010, 

2007-2011, and 2008-2012), but an increase in POM extinction, due to a spike in 2012 that 

NDEP attributes to wildfires.45 On the best days, visibility impairment is reduced from the 

baseline to the current period due to decreases in extinction from sulfate, nitrate, POM, and 

 

45 Progress Report, Chapter 6, pages 6-2 thru 6-3. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 34 of 45

elemental carbon. Light extinction for soil, coarse mass, and sea salt remain fairly constant on 

best days. 

Actual emissions of SO2, NOX, PM10, and VOC from point sources in Nevada46 have 

decreased significantly over a 10-year period (2002-2012) and over the last five years (2008-

2012) as presented in Table 11.47 The years 2002, 2005, 2008, and 2011 are the most complete 

inventory years submitted to EPA for the NEI. The data for 2012 are actual emission values for 

major and minor point sources from Nevada’s permitting database. As shown in the table, SO2

emissions from point sources dropped dramatically after the closure of Mohave in 2005, and 

decreased by another 50 percent from 2008 to 2012. Likewise, NOX emissions decreased by 

30,000 tpy after 2005, and decreased another 62 percent from 2008 to 2012. 

TABLE 11—ACTUAL EMISSIONS OF NEVADA POINT SOURCES (TPY) 

Year SO2 NOX PM10 VOC 

2002 50,619 55,876 6,868 2,132

2005 54,243 52,087 4,643 1,646

2008 10,497 21,680 3,465 1,600

2011 5,959 10,548 3,331 971

2012 5,278 8,324 2,629 986

 PM10 = particulate matter less than 10 microns 

Emissions from Outside Sources Effecting Jarbidge: NDEP’s analysis focuses on three 

BART sources in Idaho and Oregon to determine whether these previously identified point 

sources are impeding progress on the worst days at Jarbidge. Comparing baseline emissions to 

the NEI in 2011, total SO2 emissions from these three sources decrease by about 40 percent 

(26,243 to 15,782 tpy) from 2002 to 2011. Total NOX emissions decrease by about 31 percent 

 

46 SO2 emissions from point sources were 68 percent of the total anthropogenic emissions in Nevada in 2008 

(WestJump2008). Area source emissions of SO2 were 29 percent of total anthropogenic emissions in 2008. 47 Progress Report, Table 6-1, page 6-4. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 35 of 45

(11,010 to 7,611 tpy) over the same time period. Moreover, emissions from these sources will 

continue to decline over time given staggered compliance dates through 2018. With visibility 

impairment resulting from sulfate and nitrate trending downward at Jarbidge and the 

implementation of BART controls in Idaho and Oregon, NDEP concludes that there are no 

significant changes in anthropogenic emissions from outside the State that are impeding progress 

at Jarbidge. 

In assessing point source emissions from Idaho and Oregon, NDEP references source 

apportionment modeling of particulate sulfate and nitrate extinction for 2018 that was performed 

by the WRAP for the Nevada Regional Haze SIP.48 The purpose of the modeling is to determine 

source areas that contribute to visibility impairment on the worst days at Jarbidge. The area of 

greatest sulfate contribution is Outside Domain49 (43.8 percent), followed by Idaho (10.3 

percent), Oregon (7.2 percent), and Pacific Offshore (6.9 percent). The area of greatest nitrate 

contribution is Idaho (30.3 percent), followed by Outside Domain (27.5 percent), Nevada (13.1 

percent), and Utah (10.6 percent). Based on these results, Idaho is the second largest contributor 

of modeled sulfate and the largest contributor of modeled nitrate concentrations. Oregon is the 

third largest contributor of modeled sulfate concentrations. While this analysis supports the focus 

on emissions from Idaho and Oregon, the fact that Outside Domain contributes 43.8 percent of 

the modeled sulfate and 27.5 percent of the modeled nitrate is another indication that Nevada has 

limited control over a large subset of the emissions impairing visibility at Jarbidge. 

 

48 Nevada Regional Haze SIP, Chapter 4, Table 4-5: Summary of 2018 Model Results for Jarbidge Wilderness Area, 

based on Particulate Matter Source Attribution Tracking, page 31. 

49 Outside Domain as a source category represents the background concentrations of pollutants from international 

sources that enter the modeling domain, in this case the western United States and portions of Canada and Mexico. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 36 of 45

Nevada’s Emissions Effect on Nearby Class I Areas: NDEP also addresses the potential 

effect of Nevada’s emissions on nearby Class I areas in other states using particulate source 

apportionment modeling conducted by the WRAP for the first round of regional haze SIPs. This 

modeling estimated Nevada’s projected contributions to light extinction from sulfates and 

nitrates at Class I areas in adjacent states in 2018.50 In light of the 75 percent reduction in 

Nevada’s SO2 emissions (see Table 9) and 26 percent reduction in NOX emissions (see Table 10) 

between 2002 and 2008, NDEP concludes that Nevada’s emission reductions are not impeding 

progress in reducing visibility impairment at Class I areas in adjacent states. 

2. EPA’s Evaluation 

EPA proposes to find that NDEP adequately addresses the requirement in 40 CFR 

51.308(g)(5) to assess any significant changes in anthropogenic emissions within or outside the 

state over the past five years that have limited or impeded progress in reducing emissions and 

improving visibility. NDEP provides a comprehensive analysis of emission changes within and 

outside the State, and examines the potential effect of these changes at Jarbidge and at other 

Class I areas. All indications are that the total statewide emissions of SO2 and NOX are 

decreasing (see Tables 9, 10, and 11), and most of the pollutants are already at levels below those 

in the projected emission inventory for 2018 (see Table 8). Based on NDEP’s analysis, EPA 

proposes to concur with NDEP that there is no evidence that any recent changes in emissions 

from any specific sources or source categories are impeding progress. 

F. Assessment of Plan Elements and Strategy 

 

50 Nevada Regional Haze SIP, Chapter 4, Tables 4-3: Nevada’s Sulfate Extinction Contribution to Class I Areas 

Outside of Nevada and Table 4-4: Nevada’s Nitrate Extinction Contribution to Class I Areas Outside of Nevada, 

pages 14-17. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 37 of 45

1. NDEP’s Analysis 

The Progress Report concludes that the existing elements and strategies in the Nevada 

Regional Haze Implementation Plan are sufficient to enable Nevada and other neighboring states 

to meet the RPGs by 2018 in terms of reducing emissions from anthropogenic sources. Nevada 

has already achieved significant emission reductions in the first phase of the regional haze 

program, with additional reductions expected by 2018. Actual emissions of visibility impairing 

pollutants in 2008, with the exception of fine soil and coarse mass, are already less than the 

projected emissions in 2018 (see Table 8). Notably actual SO2 emissions in 2008 are about 40 

percent and actual NOX emissions are about 90 percent of the respective totals in the projected 

emission inventory for 2018. The NEI data for 2008 and 2011 also demonstrate further 

reductions in SO2 and NOX emissions from point sources in Nevada (see Table 11). Moreover, 

further reductions in anthropogenic emissions are expected from the power sector as a result of 

BART implementation, shutdowns, and conversions to natural gas or lower sulfur fuels. In the 

case of Jarbidge, NDEP notes that emissions from natural sources can dominate visibility 

impairment on the worst days, and much of the anthropogenic emissions are from out-of-state. 

NDEP states that given the current and expected SO2 and NOX emission reductions from power 

plants, further reductions from any other non-utility or industrial point sources are unnecessary at 

this time. 

Regarding visibility conditions, trend analysis of monitoring data at Jarbidge from 2000 

to 2012 demonstrates improvement in visibility impairment from sulfate and nitrate on the worst 

and best days, both on an annual average basis as well as five-year annual averages.51 NDEP 

notes that, although the visibility benefit from anthropogenic emission reductions is 

 

51 Progress Report, Chapter 4, Section 4.6: Visibility Trends, pages 4-15 thru 4-19. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 38 of 45

overshadowed by contributions from natural sources, visibility is slowly improving at Jarbidge 

on the worst days and shows considerable improvement on the best days (see Tables 5, 6, and 7). 

Where it appears that visibility improvement on worst days is not keeping pace with emission 

reductions (e.g., the 14.9 dv annual average for 2012 in Table 4), NDEP asserts that this is due to 

large contributions from natural sources (e.g., light extinction from POM of 23.97 Mm-1 in 

2012). In terms of anthropogenic sources, NDEP notes that sulfate contributes the most to 

visibility impairment on worst days at Jarbidge, but most of the sulfate is from out-of-state 

sources. Nitrate has only a small contribution to visibility impairment on the worst days. 

2. EPA’s Evaluation 

EPA proposes to find that the Progress Report adequately addresses the requirement in 40 

CFR 51.308(g)(6) to assess whether the current elements and strategies in the Regional Haze 

Implementation Plan are sufficient to enable Nevada, and other states affected by Nevada’s 

emissions, to meet all established RPGs. 

In particular, the Report analyzes trends in statewide emissions and visibility conditions 

at Jarbidge, as well as the additional emission reductions expected through 2018. The Report 

indicates that anthropogenic emissions of SO2, NOX, ammonia and VOC are decreasing. In 

particular, the emission reductions reflect substantial decreases in total anthropogenic emissions 

of SO2 and NOX. However, anthropogenic emissions of POA, fine soil, elemental carbon and 

coarse mass are increasing. While these increases may be partially attributable to changes in 

inventory development methodologies, they highlight the need for greater attention to these 

pollutants in future planning periods. 

With regard to visibility trends, the Progress Report explains that Jarbidge is not on track 

to meet the 2018 RPG for the worst days due to the large contribution from POM, which NDEP 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 39 of 45

attributes mostly to wildfires and windblown dust. EPA concurs that POM has a large impact on 

the worst days and that much of the POM is attributable to natural sources, particularly wildfires. 

Furthermore, we note that the trend of high POM extinction (with significant interannual 

variability) dominating the worst days at Jarbidge has continued during 2013 and 2014, for 

which the IMPROVE data are now available, as shown in Tables 12 and 13. 

TABLE 12 - 2013 AND 2014 AVERAGE VISIBILITY CONDITIONS FOR WORST AND BEST 

DAYS AT JARBIDGE

Year Haze 

Index 

(dv) 

Sulfate 

(Mm-1) 

Nitrate 

(Mm-1) 

POM 

(Mm-1) 

EC 

(Mm-1) 

Soil 

(Mm-1) 

Coarse 

Mass 

(Mm-1) 

Sea Salt 

(Mm-1) 

Worst Days 

2013 11.7 3.5 1.0 8.4 1.3 2.7 5.9 0.1 

2014 12.2 3.1 0.6 14.5 2.3 2.2 4.5 0.2

Best Days 

2013 1.5 0.9 0.1 0.2 0.0 0.1 0.2 0.0

2014 1.8 1.0 0.2 0.3 0.1 0.1 0.2 0.1

TABLE 13 - FIVE-YEAR ANNUAL AVERAGE VISIBILITY CONDITIONS FOR WORST AND BEST 

DAYS AT JARBIDGE

Year Haze 

Index 

(dv) 

Sulfate 

(Mm-1) 

Nitrate 

(Mm-1) 

POM 

(Mm-1) 

EC 

(Mm-1) 

Soil 

(Mm-1) 

Coarse 

Mass 

(Mm-1) 

Sea Salt 

(Mm-1) 

Worst Days 

2009-2013 12.0 3.8 0.9 10.7 1.5 2.5 5.9 0.2

2010-2014 12.2 3.6 0.9 12.1 1.8 2.5 5.6 0.2

Best Days 

2009-2013 1.9 1.0 0.2 0.4 0.1 0.1 0.3 0.0

2010-2014 1.9 1.0 0.2 0.4 0.1 0.1 0.3 0.0

However, we also note that not all POM is from natural sources. POA and VOC, the 

precursors to POM, are also emitted by anthropogenic sources, particularly area and mobile 

sources. Moreover, other pollutants, particularly coarse mass and sulfates, both of which have a 

significant anthropogenic component, also contribute to impairment on the worst days at 

Jarbidge. Accordingly, in developing its Regional Haze SIP for the next planning period, NDEP 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 40 of 45

should consider implementing additional control measures to address anthropogenic emissions of 

POA, VOC, SO2, and coarse mass. 

Nonetheless, given the substantial reductions in anthropogenic emissions of SO2 and 

NOX, improvement in visibility conditions on the best days, and evidence that the worst days are 

slowly improving, we propose to find that the current plan is sufficient for meeting the RPGs. 

G. Review of Visibility Monitoring Strategy 

1. NDEP’s Analysis 

The primary monitoring network, nationally and in Nevada, for the measurement and 

characterization of pollutants contributing to regional haze is the IMPROVE network. NDEP 

intends to rely on the continued availability of quality assured data collected through the 

IMPROVE network to comply with the regional haze monitoring requirements in the RHR. 

NDEP finds that the IMPROVE site at Jarbidge, Nevada’s only Class I area, is sufficiently 

representative to support a determination of reasonable progress. NDEP concludes that no 

modification to the State’s visibility monitoring strategy is necessary at this time. 

2. EPA’s Evaluation 

EPA proposes to find that NDEP adequately addresses the requirement in 40 CFR 

51.308(g)(7) to review its visibility monitoring strategy and make any modifications as 

necessary. We are not aware of any evidence of a need to modify Nevada’s monitoring strategy 

for measuring visibility at this time. 

H. Determination of Adequacy 

1. NDEP’s Determination 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 41 of 45

 NDEP has determined that no substantive revision of the Nevada Regional Haze 

Implementation Plan is warranted at this time in order to achieve the RPGs in 2018 for visibility 

improvement at Jarbidge and at other Class I areas affected by emissions from Nevada. NDEP 

concludes that no additional controls are necessary based on the evidence presented in the 

Progress Report regarding the first half of the first phase of the program. The Report documents 

a substantial reduction in anthropogenic emissions in Nevada as well as an improvement in 

visibility at Jarbidge even though BART controls and other state and federal measures are not yet 

fully implemented. Further changes in source activity that were not included in the State’s plan 

further support the conclusion that progress is adequate. 

2. EPA’s Evaluation 

 EPA proposes to find that NDEP adequately addresses the requirements in 40 CFR 

51.308(h) by determining that the existing Nevada Regional Haze Implementation Plan requires 

no substantive revisions at this time to achieve the established RPGs at Jarbidge and at other 

Class I areas affected by emissions from Nevada. We propose to concur with the State’s negative 

declaration based on the analysis and documentation presented in the Progress Report. 

 NDEP demonstrates that emissions from anthropogenic sources within the State are 

decreasing as are emissions from point sources in Idaho and Oregon that contribute to visibility 

impairment at Jarbidge. While the monitoring data indicates that best days at Jarbidge are getting 

better, we are concerned that visibility conditions on the worst days are relatively flat or only 

slightly improving. However, this lack of progress on the worst days is largely attributable to the 

impact of POM, which results primarily from natural sources. Therefore, we propose to approve 

NDEP’s determination that the Nevada Regional Haze Implementation Plan requires no 

substantive revisions at this time. 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 42 of 45

I. Consultation with Federal Land Managers 

1. NDEP’s Consultation 

NDEP provided FLMs with a draft Progress Report on June 14, 2014, for a 60-day 

review prior to the public comment period, received comments from the U.S. Department of 

Interior National Parks Service (NPS) and the U.S. Department of Agriculture Forest Service 

(USFS), and responded to those comments as documented in Appendix C of the Progress Report. 

The letter from NPS dated August 15, 2014, supported the Report’s findings, and provided four 

short comments on how to improve specific aspects of the analyses. The letter from USFS dated 

August 29, 2014, acknowledged the opportunity to work with NDEP, but provided no specific 

comments. In the Progress Report, NDEP reaffirmed its commitment to continue participating in 

the WRAP and consulting with other states, FLMs, and tribes regarding SIP revisions and 

implementation of other programs that may contribute to visibility impairment. 

2. EPA’s Evaluation 

EPA proposes to find that NDEP has addressed the requirements in 40 CFR 51.308(i)(2), 

(3), and (4) to provide FLMs with an opportunity for consultation in person and at least 60 days 

prior to a public hearing on the revised plan; include a description in the revised plan of how it 

addressed any comments from the FLMs; and provide procedures for continuing consultation 

between the State and FLMs. These procedural requirements for the Progress Report, a revision 

to the Regional Haze SIP in this case, are documented in Appendices C and D attached to the 

Report. 

J. Public Participation 

1. NDEP’s Public Process 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 43 of 45

NDEP provided a 30-day public comment period on the draft Progress Report as well as 

an opportunity for a public hearing. The public hearing, scheduled for October 15, 2014, was 

cancelled because no request for a hearing was received. During the public comment period, 

NDEP received one set of comments from the Sierra Club and National Parks Conservation 

Association in a letter dated October 16, 2014.52 These organizations questioned whether 

NDEP’s analysis supports its determination that progress in implementing the Nevada Regional 

Haze Implementation Plan is adequate to achieve the 2018 RPGs for Jarbidge and other Class I 

areas affected by Nevada’s emissions. NDEP provided detailed responses to these comments in 

Appendix D of the Progress Report. 

2. EPA’s Evaluation 

EPA proposes to find that NDEP has fulfilled the requirements of CAA 110(a) and (l) 

and 40 CFR 51.102 regarding reasonable notice and public hearings. 

VI. EPA’s Proposed Action 

EPA is proposing to approve the Nevada Regional Haze Progress Report submitted to 

EPA on November 18, 2014, as meeting the applicable requirements of the CAA and RHR. 

VII. Statutory and Executive Order Reviews 

Under the CAA, the Administrator is required to approve a SIP submission that complies 

with the provisions of the Act and applicable Federal regulations.53 Thus, in reviewing SIP 

submissions, EPA’s role is to approve state decisions, provided that they meet the criteria of the 

 

52 The letter to Adele Malone, NDEP, is signed by David VonSeggern, Chair, Sierra Club Toiyabe Chapter; Gloria 

Smith, Managing Attorney, Sierra Club; and Lynn Davis, Senior Program Manager, Nevada Field Office, National 

Parks Conservation Association. 

53 42 U.S.C. 7410(k); 40 CFR 52.02(a). 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 44 of 45

CAA. Accordingly, this proposed action is to approve state law as meeting Federal requirements, 

and does not impose additional requirements beyond those imposed by state law. For that reason, 

this proposed action: 

• is not a ‘‘significant regulatory action’’ subject to review by the Office of Management and 

Budget under Executive Order 12866 (58 FR 51735, October 4, 1993); 

• does not impose an information collection burden under the provisions of the Paperwork 

Reduction Act (44 U.S.C. 3501 et seq.); 

• is certified as not having a significant economic impact on a substantial number of small 

entities under the Regulatory Flexibility Act (5 U.S.C. 601 et seq.); 

• does not contain any unfunded mandate or significantly or uniquely affect small governments, 

as described in the Unfunded Mandates Reform Act of 1995 (Pub. L. 104–4); 

• does not have Federalism implications as specified in Executive Order 13132 (64 FR 43255, 

August 10, 1999); 

• is not an economically significant regulatory action based on health or safety risks subject to 

Executive Order 13045 (62 FR 19885, April 23, 1997); 

• is not a significant regulatory action subject to Executive Order 13211 (66 FR 28355, May 22, 

2001); 

• is not subject to requirements of Section 12(d) of the National Technology Transfer and 

Advancement Act of 1995 (15 U.S.C. 272 note) because it does not involve technical 

standards; and 

• does not provide EPA with the discretionary authority to address, as appropriate, 

disproportionate human health or environmental effects, using practicable and legally 

permissible methods, under Executive Order 12898 (59 FR 7629, February 16, 1994). 
This document is a prepublication version signed by EPA Regional Administrator Jared 

Blumenfeld on August 19, 2015. We have taken steps to ensure the accuracy of this version, but 

it is not the official version. 

Page 45 of 45

In addition, this proposed action does not apply on any Indian reservation land or in any other 

area where EPA or an Indian tribe has demonstrated that a tribe has jurisdiction. In those areas of 

Indian country, the rule does not have tribal implications and will not impose substantial direct 

costs on tribal governments or preempt tribal law as specified by Executive Order 13175 (65 FR 

67249, November 9, 2000). 

List of Subjects in 40 CFR Part 52 

Environmental protection, Air pollution control, Incorporation by reference, Intergovernmental 

relations, Nitrogen oxides, Organic carbon, Particulate matter, Reporting and recordkeeping 

requirements, Sulfur oxides, Visibility, Volatile organic compounds. 

AUTHORITY: 42 U.S.C. 7401 et seq.

August 19, 2015 /s/ 

__________________________________ __________________________________ 

Dated: Jared Blumenfeld 

 Regional Administrator 

 Region IX