## Chapt er Nine - C o ordin a tion, Futu re Commitments and Requirements

9.1 PLAN DEVELOPMENT

9.1.1 Past Coordination and C onsultation with FLMs 9.1.2 Past Collaboration with Tribes 9.1.3 Past Consultation with other States



### 9.2 FUTURE COORDINATION AND CONSULTATION COMMITMENTS

9.2.1 Future FLM Coordination and Consultation 9.2.2 Future Tribal Coordination and Consultation 9.2.3 Future Inter-state Coordination and C onsultation 9.2.4 Future Regional Planning Coordination and Consultation



### 9.3 COMMITMENT TO PROGRESS REPORTS

9.4 DETERMINATION OF CU RRENT PLAN ADEQUACY

9.5 COMMITMENT TO FUTURE SIP REVISIONS

NEVADA REGIONAL HAZE S T ATE IMP LEMENTATI ON PLAN, October 2009 9-19.1 PLAN DEVELOPMENT

The W e stern Regional Air Partners hip (W RAP) represents a colla boration of western states, tribal governm e nts, federal agen cies, and industry representatives . The WRAP was for m ed in 1997 as the successo r to the Grand Canyon Visib ility Transp ort Comm is sion. The WRAP’s prim ary focus is to develop and implem ent th e technical and policy tools needed by western states and tribes to comp ly with the R e gional Haze Rule (RHR). The WRAP is adm i nistered jointly by the W e stern G overnors' Association an d the National Tribal Environm ental Council. WRAP activ ities are con ducted by a network of comm ittees and forum s composed of WRAP

m e mbers and stakeholders who represent a wide range of viewpoints. An initial long-term strategic plan was comp l e ted by the WRAP in 2003. Through the W R AP, states, tribes, USEPA and Federal Land Managers (FLMs), working with non-governm e ntal or ganizations, including industry and environm ental orga nizations, developed and implem ented num erous air quality polic ies th at have improved the env i r o nm ent in th e western U n ited States. The initial strateg i c plan: (1) iden tif ie d m a jor pro ducts and m ileston es; (2) served as a n instrum e nt of coordination; (3) provided the di rection and transparency n eeded to foster stakeholder participation and consensus-based de cision-m aking, which are key features of the WRAP process; and (4) provided guidance to the WRAP forum s and comm ittees. In March 2008, the 2008-2012 WRAP strategic plan was adopted by the W R AP Board. The 2008-2012 strategic plan ( http://wrapair.org/W RAP/documents/W RAP_2008- 12_Strategic_Plan3_08final.pdf ) addresses implem entation of th e regional haze (RH) SIPs and a
one-atm osphere analysis in the west for the next five years. The 2008- 2012 strategic plan also addresses refinem e nt and development of anal ysis tools for evaluation of ongoing and future control program s for air qua lity planning focusing on: 1. Ongoing imple m entation of the regional haze program ; 2. Technical and policy support re lated to other regional air qual ity issues, such as ozone and particula t e m a tter Natio nal Am bient Air Qu ality Standards, m e rcury and nitrogen deposition impact on ecosystem s , regionally-appr opriate em issions m a nagem e nt strategies; and 3. Technical and policy support on issues related to clim ate change and energy. Through participation in the W R AP, a significant portion of the consultation process with FLMs, tribes and other states has been m e t. In the W R AP process, stakeholders participated in various forum s and workgroups to help develop a coordinated em issions inventory and analysis of the impacts that sources hav e on region al haze in the West. Coordination andevaluation of monitoring data and m odeling processes were also overseen by W R AP participants. Although not a form al m e m b er, Nevada has been an active participan t in the W R AP since its inc e ption and in the forums, workgroups and comm ittees that we re form ed to address m a ny ele m e n ts of this SIP.

9.1.1 Past Coordination and Consultation w i th FLMs

40 CFR 51.308(i) of the RHR requi res coordination between states and the FLMs. Nevada has provided agency contacts to the FL Ms as required in 40 CFR 51.308(i)(1). During developm ent of t h is SIP, the FLMs were consulted in accordan ce with the p r o v isions of

NEVADA REGIONAL HAZE S T ATE IMP LEMENTATI ON PLAN, October 2009 9-2section 51.308(i)(2). Num e rous opportunities were providedby the W R AP for FLM s to participa t e f u lly in the d e velopm ent of tec hnical docum ents developed by the W R AP. This included the opportunity to review and comment on these analyses, reports and policies. Nevada provided ad dition a l opp ortunitie s f o r coordin a tion and cons ulta tion withFLMs as th e SIP was developed through local m eetings and stakehol der workshops. The FLM consultation process included the opportunity to discus s their assessm ent of visibility impairment at the Jarbidge W ilderness Area (Jarbidge W A ), and to provide recomm endations on reasonable progress goals and the deve lopm ent and implem entation of visib i lity contro l s tra tegie s

. This SIP was subm itted to the FLMs on January 5

, 2009 for a 60-day rev i ew and comm ent period. Comments were received from the FLMs on March 4 and 6, 2009. As required by 40 CFR 51.308(i)(3), the FLM comme nts and state re sponses are included in Appendix C.

A docum ent summarizing the W R AP consultation process is provided on the W R AP web site ( http://www.wrapair.o rg/forum s/iwg/m eetings/071115c/W RAP_posted_m eetings_and_conferen ce_calls_10-11-07.pdf ). The purpose of the summ ary is to gather a cons olidated list of each forum

, comm ittee and workgroup, its purpose, m e mbership, significant work products and

m eetings in one place. The draft do cum e nt, although not inclusive of all the m eetings and conference calls held by the W R AP, dem onstrates the extent of consultation am ong the W R AP partners and stakeholders since its inception.

9.1.2 Past Collab o ration w i th Tribes

Nevada sent letters to the W R AP Tribal Ca ucus Coordinator on Septem ber 15, 2006 and March 26, 2008 providing the National Tribal Environm enta l Council (NTEC) with a contact person for the State of Nevada. These letters also stated that Nevada will work closely with the Nevada Division of Environm ental Protectio n’s tribal liaison. As describe d above, Nevada participated in the co llab o rative W R AP process where tribes were repres ented.

9.1.3 Past Consultation w i th other States

Pursuant to 40 CFR 51.308(d)(1)(iv) , Nevada consulted with other W R AP states in developm ent of this SIP. Alaska, Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, North Dakota, Oregon, South Dakota, Utah, W a shi ngton and Wyom ing a g reed to work together to address regional haze in the western contin en ta l United States. The m a jority of state consultation in the developm ent of the RH SIPs was conducted through the Imple m e n tation Work Group (IW G) of the W R AP. Nevada particip ated in the IWG, whic h took the products of the W R AP t echnical analysis and consultation pr ocess discussed above and developed a process for establishing reasonable progre ss g o als in the w e stern C l ass I ar eas. This consultation process ensures that states are aware of each other’s reasonable prog ress goals an d long-term strategies.

Nevada has reviewed and analyzedcontributions from other states that reasonably m a y cause or contribute to visibility impairm e nt in the Jarbid ge WA. As discussed in Ch apter Th ree, em ission sources beyond the control of Nevada, other states or the FL Ms include: em issions from outside the W R AP modeling dom a in; e m issions from Ca na da and Mexico; em issions from wildfires, windblown dust and biogenic em issions; and em i ssions from offshore shipping. Nevertheless, Nevada anticipates that the long-term strategi es adopted by other stat es in their SIPs and approved by USEPA will inc l ude emission reduc tions f r om a varie t y of sources th at will r e duce

NEVADA REGIONAL HAZE S T ATE IMP LEMENTATI ON PLAN, October 2009 9-3visibility impairm e nt in the Jarbidge WA.

9.2 FUTURE COORDINATION AND CONSULTATION CO MMITMENTS

Nevada will continue to coordina te a nd c onsult w ith parties as summarize d below.

9.2.1 Future FLM Coordination and Consultation

The RHR re quires states to subm it periodic SIP revisions and progr ess reports evaluating progress to ward the reasonable pro g ress goal fo r each Class I area. As required by 4 0 CFR 51.308(i)(4), Nevada will continue to coordi nate and consult w ith the FLMs during the developm ent of these future progress reports and plan revisions, as well as during the imple m entation of program s having the potential to contribute to visibility impair m e nt in

m a ndatory Class I areas. The progress reports are to oc cur a tf i ve year in terva l s, withthe f i rs t report du e f i ve years f r o msubm ittal of the initial RH SIP. Plan revis i ons are due ev er y ten year s beginning in 2018. The consultation process will provide on-going and tim ely opportunities to address the status of the contro l prog ram s identif ied in th is SI P, the developm ent of future

assessm ents of sources a nd impacts, and the deve lopm ent of addition a l co ntrol p r ogra m s. Nevada will provide the FLMs an opportunity to review and comm ent on future SIP revisions, the 5-year progress reports and other devel oping program s that m a y contribute to Class I visibility impairm e nt. The consultation will be c oordina ted with the de signated visib ility protection program coordinators for the National Park Servic e, U.S. Fish and W ildlif e Service, Bureau of Land Managem e nt and the U.S. Forest Service. At a m i ni mu m, Nevada will m eet with the FL Ms on an annual basis through the WRAP , as long as the W R AP continues to provide this forum

. All SIP revisions will include a description of how the st ate consulted with and addressed any comments provided by the FLMs.

9.2.2 Future Tribal Coordination and Consultation

Nevada will continue to r e m a in in contact, v i a th e W R AP, with the NTEC to keep trac k of possible future impacts from tribes to visibility at the Jarbidge W A and to provide opportunity for consultation regarding any tribal Class I area that Nevada’s em issions m a y reasonably be anticipated to impact.
9.2.3 Future Inter-state Coordination and Consultation

In acco rdan ce with 40 C F R 51.308(d)(1)(iv) and 51.308( d)(3 )(i), Nevad acomm its to continue consultation with Arizona, California , Idaho, Oregon and Utah, and any other state which m a y reasonab l y b e anticipatedto cause or contribute to visibility im pairm e nt at the Jarbidge WA. Nevada will also con tinu e consultatio n with any s t ate f o r whic h Nevada’s em issions may reasonab l y b e anticipatedto cause or contribute to visibility impa irm e nt in those states’ federal Class I areas

. W ith regard to the established or updated goal fo r reasonable progress, shou ld disagreem e nt arise between ano t her s t ate or group of states and Neva da, Nevada will des c rib e the actions taken to resolve the disagreem e nt in future RH SIP revisi ons for USEPA’s consideration. W ith regard to assessing or updating long-term strategies, Nevada comm its to coordinate its em ission

m a nagem e nt stra tegies with af f

ected states and will continu e to include in its f u tur e RH SIP revis i ons a ll m easures necessary to o b tain its sh are of e m issio n s reduc tions for m eeting other states’ reasonable progress goals.

NEVADA REGIONAL HAZE S T ATE IMP LEMENTATI ON PLAN, October 2009 9-49.2.4 Future Regional Planning C oordination and Consultation

Nevada comm its to continued participation in the W R AP, to the exten tap propria te, an d to coordinating future plan revisions with other WRAP m e mber states in addressing regional haze. This involv e m e nt in the WRAP will contribute s i gnificantly to Nevada’s inter-state an d FLM coordination for future SIP re visions and pr ogress reports.

9.3 COMMITMENT TO PROGRESS REPORTS

40 CFR 51.308(g) requires states to subm it a progress report to USEPA e v ery 5 years evaluating progress towards the reasonable progress goal(s). Th e first progress report is due five years from the subm itta l of the initial implem entation plan a nd mu st be in the f o rm of an implementation plan revision that comp lies with US EPA’s public hearing and plan submittal requirem e nts (40 CFR 51.102-103). At a m i ni mu m, th e progress reports mu st contain the elem ents in paragraphs 51.308(g)(1 -7) for each Class I area, as summ arized below.

1. Imple m entation status of the curren tSIP m easures for achiev i ng reason ab le progress g o als; 2. Summ ary of e m issions reductions achieved; 3. Assessm e n t of m o st and least impaired days; 4. Analysis of e m ission reductions of pollutants c ontr i buting to visib i lity impairm e nt f r om all sources with in the state b a sed on the most recen t updated em issions inv e n t ory, with estim ates projected forward to accou n t for emission changes during th e applicab le 5-year period. 5. Assessm e n t of significant changes in anthropog enic em issions that have occurred during the 5-year period that have lim ited or impede d progress in reducing pollutant em issions and improving visibility; 6. Assessm ent of the current SIP sufficien cy to meet reasonable progress goals; and 7. Review of visibility monitori ng strategy and any m odific a tions to the strategy as necessary.

In acco rdan ce with th e requirem e nts listed in section 51.308(g) of the RHR, Nevada comm its to subm itting a report on re asonable p r o g ress to US EP A every five year s f o llowing the initial subm ittal of the SIP. The reason able progress re port will eva l uate p r ogre ss m a de towards the reasonab l e p r ogress go al for the Jarb idge W A and in each m a ndatory Class I area located outsid e Nevada, which m a y be af f

ected by em issions f r om Nevada. Nevada’s m i d-term revie w will address each of the required elem ents listed above , including a reassessm e n t of the uncertainty in the data. The state will also evaluate the m onitoring strategy adequacy in assessing reasonable progress goals.

9.4 DETERMI NATION O F CUR RENT PLAN ADEQUACY

40 CFR 51.308(h) requires a state to m a ke a de term ination of the adequacy of the current imple m entation plan as part of its five-year pr ogress report. Based on th e findings of the fiveyear progress report, the state mu st take one or more of the actions summ a r ized below at the

sam e tim e the sta t e submits it s five-year progress report.

1. If the state finds that no substantive SIP revisi ons are requ ired to m eetestablished visibility goals, the state shall provide a negative declar ation that no implem e ntation plan revision is needed. 2. If the state finds that the imple m e n tation plan is or m a y be inadequate to ensure reasonable

NEVADA REGIONAL HAZE S T ATE IMP LEMENTATI ON PLAN, October 2009 9-5progress due to em issions from sources in anot her state that participated in a regional planning process, the state shall notif y USEPA an d the other contributing state(s). The plan deficiency shall be addressed through a regi onal planning process to develop additional strategies through the planning efforts described in the progress report(s). 3. If the state finds that the imple m e n tation plan is or m a y be inadequate to ensure reasonable progress due to em issions from another count ry, the state shall notify USEPA and provide the available supporting infor m ation. 4. If the state finds that the imple m e n tation plan is or m a y be inadequate to ensure reasonable progress due to em issions from within the state, the state shall rev i se its implem e ntation plan to address the plan’s deficiencies within one year.

Nevada comm its, in acco rdance with 40 CFR 51.308(h) , to m a ke an adeq uacy determination of the cur r ent S I P at th e sa m e tim e its f i ve-ye a r progress report is due and to comp ly with the requirem e nts of 51.308(g). If Nevada determ ines th at the current implem e n tation plan is or m a y be inadequa te due to em issions f r om within th e state itse lf, Nevada will d e velop additional strategies to address the plan de ficiencies and revise th e SIP with in one year from the date that the progress report is due. If, on the other hand, Nevada determ ines that the plan is or m a y be inadequate d u e to em issions from other states , Nevada will ad dress th e deficien cy thro ugh a regional planning process.

9.5 COMMITMENT TO FUTURE SIP REVISI ONS

In addition to a SIP revision m a de forplan inadequacy, 40 CFR 51.308(f) requires a state to revise and subm it a comprehensive regional h aze imple m entation plan revision to USE P A by July 31, 2018 and every ten years thereafter. Futu re SIP revisions mu st evaluate and reassess all of the elem ents required under 40 CFR 51.308(d) and specifically address the item s listed in 51.308(f)(1-3). The plan revision mu st take in to account improvem e nts in monitoring data collection and analysis, c ontrol technologies and other relevantfactors. Nevada’s commit m ents to comp ly with RHR requirem e nts for future plans follow. By July 31, 2018 and every 10 years thereafter, Nevada comm its to completing and s u bm itting a

comp rehensive RH SIP revision to USEPA, eval uating and reassessing all of the elements required under 40 CFR 51.308(d). In evaluati ng and reassessing these elem ents, Neva da

comm its to:

1. Determ ining curren tvis i bility (m ost recen t fi ve y ear period preceding the required date of the SIP sub m ittal for which data is available) conditions fo r the m o st impaired andleas t impaired days and determ ine the actual pr ogress m a de towards natural conditions. 2. Determ ining the effectiveness of the l ong-term strategy for achieving the reasonable
progress go als for the prior SIP perio d as we ll as include enforceab le em ission lim itations and comp liance schedules. 3. Affirm ing or revising the current reasonable progress goals based on assessm ent of new or updated inform ation, improved te chnologies and on-going legisl ation. If the reasonable
progress go al is found to be insufficient to attain n a tural conditions by 206 4, Nevada will look at additional or new control m e a s ures that m a y be adopted considering comp liance cost, comp liance tim e , the energy and non-air qu ality environm ental impa cts of comp l i ance and the remaining useful life of the affected source(s).

NEVADA REGIONAL HAZE S T ATE IMP LEMENTATI ON PLAN, October 2009 9-6