Chapter Nine - Coordination, Future Commitments and Requirements 

9.1 PLAN DEVELOPMENT 

9.1.1 Past Coordination and Consultation 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 Consultation 

9.2.4 Future Regional Planning Coordination and Consultation 

9.3 COMMITMENT TO PROGRESS REPORTS 

9.4 DETERMINATION OF CURRENT PLAN ADEQUACY 

9.5 COMMITMENT TO FUTURE SIP REVISIONS 

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9.1 PLAN DEVELOPMENT 

The Western Regional Air Partnership (WRAP) represents a collaboration of western states, 

tribal governments, federal agencies, and industry representatives. The WRAP was formed in 

1997 as the successor to the Grand Canyon Visibility Transport Commission. The WRAP’s 

primary focus is to develop and implement the technical and policy tools needed by western 

states and tribes to comply with the Regional Haze Rule (RHR). The WRAP is administered 

jointly by the Western Governors' Association and the National Tribal Environmental Council. 

WRAP activities are conducted by a network of committees and forums composed of WRAP 

members and stakeholders who represent a wide range of viewpoints. An initial long-term

strategic plan was completed by the WRAP in 2003. Through the WRAP, states, tribes, USEPA 

and Federal Land Managers (FLMs), working with non-governmental organizations, including 

industry and environmental organizations, developed and implemented numerous air quality 

policies that have improved the environment in the western United States.

The initial strategic plan: (1) identified major products and milestones; (2) served as an

instrument of coordination; (3) provided the direction and transparency needed to foster 

stakeholder participation and consensus-based decision-making, which are key features of the 

WRAP process; and (4) provided guidance to the WRAP forums and committees. In March 

2008, the 2008-2012 WRAP strategic plan was adopted by the WRAP Board. The 2008-2012 

strategic plan ( http://wrapair.org/WRAP/documents/WRAP_2008-

12_Strategic_Plan3_08final.pdf) addresses implementation of the regional haze (RH) SIPs and a 

one-atmosphere analysis in the west for the next five years. The 2008-2012 strategic plan also 

addresses refinement and development of analysis tools for evaluation of ongoing and future 

control programs for air quality planning focusing on: 

1. Ongoing implementation of the regional haze program; 

2. Technical and policy support related to other regional air quality issues, such as ozone and 

particulate matter National Ambient Air Quality Standards, mercury and nitrogen 

deposition impact on ecosystems, regionally-appropriate emissions management strategies; 

and 

3. Technical and policy support on issues related to climate change and energy. 

Through participation in the WRAP, a significant portion of the consultation process with FLMs, 

tribes and other states has been met. In the WRAP process, stakeholders participated in various 

forums and workgroups to help develop a coordinated emissions inventory and analysis of the 

impacts that sources have on regional haze in the West. Coordination and evaluation of 

monitoring data and modeling processes were also overseen by WRAP participants. Although 

not a formal member, Nevada has been an active participant in the WRAP since its inception and 

in the forums, workgroups and committees that were formed to address many elements of this 

SIP. 

9.1.1 Past Coordination and Consultation with FLMs 

40 CFR 51.308(i) of the RHR requires coordination between states and the FLMs. Nevada has 

provided agency contacts to the FLMs as required in 40 CFR 51.308(i)(1). 

During development of this SIP, the FLMs were consulted in accordance with the provisions of 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 9-2 
section 51.308(i)(2). Numerous opportunities were provided by the WRAP for FLMs to 

participate fully in the development of technical documents developed by the WRAP. This 

included the opportunity to review and comment on these analyses, reports and policies. Nevada 

provided additional opportunities for coordination and consultation with FLMs as the SIP was 

developed through local meetings and stakeholder workshops. The FLM consultation process 

included the opportunity to discuss their assessment of visibility impairment at the Jarbidge 

Wilderness Area (Jarbidge WA), and to provide recommendations on reasonable progress goals 

and the development and implementation of visibility control strategies. 

This SIP was submitted to the FLMs on January 5, 2009 for a 60-day review and comment 

period. Comments were received from the FLMs on March 4 and 6, 2009. As required by 40 

CFR 51.308(i)(3), the FLM comments and state responses are included in Appendix C. 

A document summarizing the WRAP consultation process is provided on the WRAP web site 

(http://www.wrapair.org/forums/iwg/meetings/071115c/WRAP_posted_meetings_and_conferen

ce_calls_10-11-07.pdf). The purpose of the summary is to gather a consolidated list of each 

forum, committee and workgroup, its purpose, membership, significant work products and 

meetings in one place. The draft document, although not inclusive of all the meetings and 

conference calls held by the WRAP, demonstrates the extent of consultation among the WRAP 

partners and stakeholders since its inception. 

9.1.2 Past Collaboration with Tribes 

Nevada sent letters to the WRAP Tribal Caucus Coordinator on September 15, 2006 and March 

26, 2008 providing the National Tribal Environmental 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 Environmental Protection’s tribal liaison. As described above, Nevada participated 

in the collaborative WRAP process where tribes were represented. 

9.1.3 Past Consultation with other States 

Pursuant to 40 CFR 51.308(d)(1)(iv), Nevada consulted with other WRAP states in development 

of this SIP. Alaska, Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, 

North Dakota, Oregon, South Dakota, Utah, Washington and Wyoming agreed to work together 

to address regional haze in the western continental United States. The majority of state

consultation in the development of the RH SIPs was conducted through the Implementation 

Work Group (IWG) of the WRAP. Nevada participated in the IWG, which took the products of 

the WRAP technical analysis and consultation process discussed above and developed a process 

for establishing reasonable progress goals in the western Class I areas. This consultation process 

ensures that states are aware of each other’s reasonable progress goals and long-term strategies.

Nevada has reviewed and analyzed contributions from other states that reasonably may cause or 

contribute to visibility impairment in the Jarbidge WA. As discussed in Chapter Three, emission 

sources beyond the control of Nevada, other states or the FLMs include: emissions from outside 

the WRAP modeling domain; emissions from Canada and Mexico; emissions from wildfires, 

windblown dust and biogenic emissions; and emissions from offshore shipping. Nevertheless, 

Nevada anticipates that the long-term strategies adopted by other states in their SIPs and 

approved by USEPA will include emission reductions from a variety of sources that will reduce 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 9-3 
visibility impairment in the Jarbidge WA. 

9.2 FUTURE COORDINATION AND CONSULTATION COMMITMENTS 

Nevada will continue to coordinate and consult with parties as summarized below. 

9.2.1 Future FLM Coordination and Consultation

The RHR requires states to submit periodic SIP revisions and progress reports evaluating 

progress toward the reasonable progress goal for each Class I area. As required by 40 CFR 

51.308(i)(4), Nevada will continue to coordinate and consult with the FLMs during the 

development of these future progress reports and plan revisions, as well as during the 

implementation of programs having the potential to contribute to visibility impairment in 

mandatory Class I areas. The progress reports are to occur at five year intervals, with the first 

report due five years from submittal of the initial RH SIP. Plan revisions are due every ten years 

beginning in 2018. The consultation process will provide on-going and timely opportunities to 

address the status of the control programs identified in this SIP, the development of future 

assessments of sources and impacts, and the development of additional control programs. 

Nevada will provide the FLMs an opportunity to review and comment on future SIP revisions, 

the 5-year progress reports and other developing programs that may contribute to Class I 

visibility impairment. The consultation will be coordinated with the designated visibility 

protection program coordinators for the National Park Service, U.S. Fish and Wildlife Service, 

Bureau of Land Management and the U.S. Forest Service. At a minimum, Nevada will meet 

with the FLMs on an annual basis through the WRAP, as long as the WRAP continues to provide 

this forum. All SIP revisions will include a description of how the state consulted with and 

addressed any comments provided by the FLMs. 

9.2.2 Future Tribal Coordination and Consultation 

Nevada will continue to remain in contact, via the WRAP, with the NTEC to keep track of

possible future impacts from tribes to visibility at the Jarbidge WA and to provide opportunity 

for consultation regarding any tribal Class I area that Nevada’s emissions may reasonably be 

anticipated to impact. 

9.2.3 Future Inter-state Coordination and Consultation 

In accordance with 40 CFR 51.308(d)(1)(iv) and 51.308(d)(3)(i), Nevada commits to continue 

consultation with Arizona, California , Idaho, Oregon and Utah, and any other state which may 

reasonably be anticipated to cause or contribute to visibility impairment at the Jarbidge WA. 

Nevada will also continue consultation with any state for which Nevada’s emissions may 

reasonably be anticipated to cause or contribute to visibility impairment in those states’ federal 

Class I areas. 

With regard to the established or updated goal for reasonable progress, should disagreement arise 

between another state or group of states and Nevada, Nevada will describe the actions taken to 

resolve the disagreement in future RH SIP revisions for USEPA’s consideration. With regard to 

assessing or updating long-term strategies, Nevada commits to coordinate its emission 

management strategies with affected states and will continue to include in its future RH SIP 

revisions all measures necessary to obtain its share of emissions reductions for meeting other 

states’ reasonable progress goals. 

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9.2.4 Future Regional Planning Coordination and Consultation 

Nevada commits to continued participation in the WRAP, to the extent appropriate, and to 

coordinating future plan revisions with other WRAP member states in addressing regional haze. 

This involvement in the WRAP will contribute significantly to Nevada’s inter-state and FLM 

coordination for future SIP revisions and progress reports. 

9.3 COMMITMENT TO PROGRESS REPORTS 

40 CFR 51.308(g) requires states to submit a progress report to USEPA every 5 years evaluating 

progress towards the reasonable progress goal(s). The first progress report is due five years from

the submittal of the initial implementation plan and must be in the form of an implementation 

plan revision that complies with USEPA’s public hearing and plan submittal requirements (40 

CFR 51.102-103). At a minimum, the progress reports must contain the elements in paragraphs 

51.308(g)(1-7) for each Class I area, as summarized below. 

1. Implementation status of the current SIP measures for achieving reasonable progress goals; 

2. Summary of emissions reductions achieved; 

3. Assessment of most and least impaired days; 

4. Analysis of emission reductions of pollutants contributing to visibility impairment from all 

sources within the state based on the most recent updated emissions inventory, with 

estimates projected forward to account for emission changes during the applicable 5-year 

period. 

5. Assessment of significant changes in anthropogenic emissions that have occurred during the 

5-year period that have limited or impeded progress in reducing pollutant emissions and 

improving visibility; 

6. Assessment of the current SIP sufficiency to meet reasonable progress goals; and 

7. Review of visibility monitoring strategy and any modifications to the strategy as necessary. 

In accordance with the requirements listed in section 51.308(g) of the RHR, Nevada commits to 

submitting a report on reasonable progress to USEPA every five years following the initial 

submittal of the SIP. The reasonable progress report will evaluate progress made towards the 

reasonable progress goal for the Jarbidge WA and in each mandatory Class I area located outside

Nevada, which may be affected by emissions from Nevada. Nevada’s mid-term review will 

address each of the required elements listed above, including a reassessment of the uncertainty in 

the data. The state will also evaluate the monitoring strategy adequacy in assessing reasonable 

progress goals. 

9.4 DETERMINATION OF CURRENT PLAN ADEQUACY 

40 CFR 51.308(h) requires a state to make a determination of the adequacy of the current 

implementation plan as part of its five-year progress report. Based on the findings of the fiveyear progress report, the state must take one or more of the actions summarized below at the 

same time the state submits its five-year progress report. 

1. If the state finds that no substantive SIP revisions are required to meet established visibility 

goals, the state shall provide a negative declaration that no implementation plan revision is 

needed. 

2. If the state finds that the implementation plan is or may be inadequate to ensure reasonable 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 9-5 
progress due to emissions from sources in another state that participated in a regional 

planning process, the state shall notify USEPA and the other contributing state(s). The plan 

deficiency shall be addressed through a regional planning process to develop additional 

strategies through the planning efforts described in the progress report(s). 

3. If the state finds that the implementation plan is or may be inadequate to ensure reasonable 

progress due to emissions from another country, the state shall notify USEPA and provide 

the available supporting information. 

4. If the state finds that the implementation plan is or may be inadequate to ensure reasonable 

progress due to emissions from within the state, the state shall revise its implementation plan 

to address the plan’s deficiencies within one year. 

 

Nevada commits, in accordance with 40 CFR 51.308(h), to make an adequacy determination of 

the current SIP at the same time its five-year progress report is due and to comply with the 

requirements of 51.308(g). If Nevada determines that the current implementation plan is or may 

be inadequate due to emissions from within the state itself, Nevada will develop additional 

strategies to address the plan deficiencies and revise the SIP within one year from the date that 

the progress report is due. If, on the other hand, Nevada determines that the plan is or may be 

inadequate due to emissions from other states, Nevada will address the deficiency through a 

regional planning process. 

9.5 COMMITMENT TO FUTURE SIP REVISIONS 

In addition to a SIP revision made for plan inadequacy, 40 CFR 51.308(f) requires a state to 

revise and submit a comprehensive regional haze implementation plan revision to USEPA by 

July 31, 2018 and every ten years thereafter. Future SIP revisions must evaluate and reassess all 

of the elements required under 40 CFR 51.308(d) and specifically address the items listed in 

51.308(f)(1-3). The plan revision must take into account improvements in monitoring data 

collection and analysis, control technologies and other relevant factors. Nevada’s commitments 

to comply with RHR requirements for future plans follow. 

By July 31, 2018 and every 10 years thereafter, Nevada commits to completing and submitting a 

comprehensive RH SIP revision to USEPA, evaluating and reassessing all of the elements 

required under 40 CFR 51.308(d). In evaluating and reassessing these elements, Nevada 

commits to: 

1. Determining current visibility (most recent five year period preceding the required date of 

the SIP submittal for which data is available) conditions for the most impaired and least 

impaired days and determine the actual progress made towards natural conditions. 

2. Determining the effectiveness of the long-term strategy for achieving the reasonable 

progress goals for the prior SIP period as well as include enforceable emission limitations 

and compliance schedules. 

3. Affirming or revising the current reasonable progress goals based on assessment of new or 

updated information, improved technologies and on-going legislation. If the reasonable 

progress goal is found to be insufficient to attain natural conditions by 2064, Nevada will 

look at additional or new control measures that may be adopted considering compliance 

cost, compliance time, the energy and non-air quality environmental impacts of compliance 

and the remaining useful life of the affected source(s). 

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