Chapter Seven -- Long-Term Strategy for Nevada

7.1 LONG-TERM STRATEGY OVERVIEW 

7.1.1 Long-Term Strategy Requirements 

7.1.2 Technical Basis of Reasonable Progress Goal 

7.2 BART CONTROLS 

7.3 VISIBILITY IMPROVEMEMT 

7.4 MITIGATION OF CONSTRUCTION IMPACTS

7.5 EMISSIONS LIMITATIONS AND SCHEDULES OF COMPLIANCE 

7.6 SOURCE RETIREMENT AND REPLACEMENT SCHEDULES 

7.7 SMOKE MANAGEMENT PROGRAM 

7.8 ENFORCEABILITY OF EMISSION LIMITS 

7.9 LONG-TERM STRATEGY 

7.9.1 Anthropogenic Sources of Visibility Impairment 

 7.9.1.1 Major and Minor Stationary Sources 

 7.9.1.2 Mobile Sources 

 7.9.1.3 Area Sources 

 7.9.1.4 International Emissions 

7.9.2 Additional Emissions Control Programs

 7.9.2.1 State and Local Mobile Source Programs 

 7.9.2.2 Nevada’s Renewable Portfolio Standard 

 7.9.2.3 Marine Diesel Rule 

7.9.3 Other Considerations 

 7.9.3.1 Uncertainty 

 7.9.3.2 Contributions to Impairment at Class I Areas 

 Outside of Nevada 

7.10 REASONABLE PROGRESS ASSESSMENT 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-1 
7.1 LONG-TERM STRATEGY OVERVIEW 

The long-term strategy is the compilation of enforceable emissions limitations, compliance 

schedules, and other measures as necessary to achieve the reasonable progress goals and is the 

means through which the state ensures that its reasonable progress goal (RPG) will be met (40 

CRF 51.308(d)(3) and Guidance for Setting Reasonable Progress Goals Under the Regional 

Haze Program, U.S. EPA, 2007). This chapter discusses Nevada’s long-term strategy to restore 

natural visibility conditions at the Jarbidge Wilderness Area (Jarbidge WA) by 2064 and its 

relationship to the RPG for the Jarbidge WA. 

The long-term strategy must have the capability of addressing existing and future impairment 

situations as they face the state. Generally, Nevada considers its permitting program meets this 

requirement for existing major stationary facilities, as well as preventing future impairment from 

proposed major stationary sources or major modifications to existing facilities. The New Source 

Review (NSR) and Prevention of Significant Deterioration (PSD) programs are key components 

of Nevada’s regional haze plan designed to improve current visibility on the most impaired days 

and to protect visibility conditions at Class I areas. The state maintains that its existing 

regulations, including the Best Available Retrofit Technology (BART) regulations adopted for 

this SIP, along with the strategies and activities outlined in Chapter Six and below provide for 

reasonable progress toward the national visibility goal. 

The starting point for the identification of additional emission control strategies is the visibility 

improvement achieved as a result of BART and the implementation of other Clean Air Act 

(CAA) programs, including measures for attainment of the ozone and PM 2.5 National Ambient 

Air Quality Standards. Implementation of some of these CAA control programs was 

incorporated into the PRP18a emissions inventory and modeling scenario, as was some of the 

implementation of BART. These programs are described in Chapter Six. Other CAA programs 

and emissions reduction strategies are described below. 

7.1.1 Long-Term Strategy Requirements 

USEPA regulations require the state to: 1) develop a long-term strategy; 2) coordinate its longterm strategy with existing plans and goals, including those of FLMs, which may affect 

impairment in any Class I area; 3) demonstrate why the long-term strategy is adequate for 

making reasonable progress toward the national goal and state why the minimum factors (listed 

in the next paragraph) were or were not addressed in developing the long-term strategy; 4) 

consider the time necessary for compliance as well as the economic, energy, and non-air quality 

environmental impacts of compliance, the remaining useful life of any affected existing source, 

as well as the effect of new sources; 5) review its strategy no less frequently than every three 

years and consult with FLMs during this process; and 6) report to USEPA and the public on 

progress achieved toward the national visibility goal. 

During the development of the long-term strategy the state must consider, at a minimum, the 

following six factors: 1) emissions reductions due to ongoing air pollution control programs; 2) 

measures to mitigate the impacts of construction activities; 3) additional emissions limitations 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-2 
and schedules for compliance; 4) source retirement and replacement schedules; 5) smoke 

management techniques for agricultural and forestry management purposes, including such plans 

as currently exist within the state for this purpose; and 6) enforceability of emission limitations 

and control measures. The long-term strategy for regional haze must also address the anticipated

net effect on visibility due to projected changes in point, area and mobile source emissions over 

the period addressed by the long-term strategy. 

7.1.2 Technical Basis of Reasonable Progress Goal 

NDEP has used the analyses of monitoring, emissions and modeling data in developing Nevada’s 

long-term strategy. Many of the tools and resources used in these analyses were produced by the 

Western Regional Air Partnership (WRAP) and its contractors and are discussed elsewhere in 

this document. The analyses discussed in Chapters Two, Three and Four describe the 

monitoring, emissions, and modeling information and analyses on which Nevada is relying to 

determine the emissions reductions necessary to achieve reasonable progress toward the national 

visibility goal by 2018. These analyses provide the technical basis of our long-term strategy. 

7.2 BART CONTROLS

The installation of BART controls is an integral part of the long-term strategy and RPG of 

Nevada’s regional haze SIP. Chapter Five describes the BART process, identifies Nevada’s 

seven BART-eligible sources and presents the BART requirements for Nevada’s four subject-toBART facilities. Each source subject to BART is required to install and operate BART as 

expeditiously as practicable, but in no event later than January 1, 2015 or 5 years after USEPA 

approval of the implementation plan, which ever occurs first. In addition, each source subject to 

BART is required to establish procedures to ensure the control equipment is properly operated 

and maintained. 

Seven Nevada facilities were identified as BART eligible: NV Energy’s generating stations at 

Tracy, Fort Churchill, Reid Gardner and Sunrise; Southern California Edison’s generating station 

at Mohave; Nevada Cement Company’s Fernley facility; and Chemical Lime Company’s facility 

in Apex, Nevada. Four of these facilities were determined to cause or contribute to visibility 

impairment at a Class I area and were subject to full BART determinations. These facilities are 

Fort Churchill, Tracy, Reid Gardner, and Mohave. 

Significant emissions reductions will be achieved by the installation of BART controls on these 

four facilities. Table 7-1 summarizes the emissions reductions resulting from the installation of

BART control technologies beyond those incorporated in the PRP18a emissions inventory. 

These emissions reductions raise the overall reduction from the baseline to 2018 in Nevada’s 

NOx inventory to 32.9 percent from 16.8 percent and the reduction in the SO2 inventory to 44.0 

percent from 33.0 percent. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-3 
TABLE 7-1

ADDITIONAL ANNUAL EMISSIONS REDUCTIONS IN TONS RESULTING 

FROM IMPLEMENTATION OF BART IN NEVADA

NOx SOx PM10 Total 

26,477 7,611 1,360 35,448

7.3 VISIBILITY IMPROVEMENT 

Utilizing WRAP Regional Modeling Center (RMC) modeling results, Nevada has estimated the 

expected visibility improvements by 2018 at the Jarbidge WA. Two projected 2018 emissions 

inventories were utilized by RMC, Base18b and PRP18a, to project visibility improvement. 

These inventories are more fully discussed in Chapter Three. 

The Base18b inventory included emission reductions due to known controls (i.e., implementation 

of existing federal and state regulations), consent decree reductions, existing SIP control 

measures and other relevant regulations that have gone into effect since 2002 or will go into 

effect before the end of 2018. These controls do not include impacts from any future control 

scenarios that have yet to be determined, such as the installation of BART. 

Figure 7-1 shows the projected 2018 visibility conditions for the worst days at JARB1 resulting 

from the controls included in the Base18b emissions inventory. The projected visibility is 11.85 

dv, reflecting the 0.22 dv or 1.8 percent decrease from baseline visibility conditions resulting 

from the implementation of existing regulations. 

The PRP18a inventory refined the Base18b inventory by applying presumptive BART SO2

emission limits to BART-eligible coal-fired electric generating unit (EGUs) greater than 750 

MW across the WRAP region. BART NOx limits were not incorporated into this inventory. 

Other, less significant refinements to the PRP18a inventory are described in Chapter One, 

section 1.3.2.2. Figure 7-2 shows the modeled 2018 visibility projection of 11.05 deciviews 

(dv), a 1.02 dv or 8.45 percent reduction in visibility impairment. These results suggest the full 

implementation of BART across the WRAP-region will result in additional and noticeable 

improvement of visibility impairment at the Jarbidge WA for the worst days. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-4 
FIGURE 7-1 

CMAQ 2018 WORST DAYS MODEL PROJECTIONS FOR JARB1 

USING BASE18b EMISSIONS INVENTORY

7.4 MITIGATION OF CONSTRUCTION IMPACTS 

Nevada manages the release of fugitive dust from construction related activities through the 

implementation of regulations set forth in the Nevada Administrative Code (NAC). 

NAC 445B.22037 requires fugitive dust to be controlled (regardless of the size or amount of 

acreage disturbed), and requires an ongoing program, using best practical methods, to prevent 

particulate matter from becoming airborne. All activities which have the potential to adversely 

affect the local air quality must implement all appropriate measures to limit controllable 

emissions. Appropriate measures for dust control may consist of a phased approach to acreage

disturbance rather than disturbing the entire area all at once; using wet suppression through such 

application methods as water trucks or water sprays systems to control wind blown dust; the 

application of soil binding agents or chemical surfactant to roadways and areas of disturbed soil; 

as well as the use of wind-break or wind-limiting fencing designed to limit wind erosion of soils. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-5 
FIGURE 7-2 

CMAQ 2018 WORST DAYS MODEL PROJECTIONS FOR JARB1 

USING PRP18a EMISSIONS INVENTORY

Furthermore, no person may disturb or cover 5 acres or more of land or its topsoil until he has 

obtained an operating permit for surface area disturbance to clear, excavate or level the land or to 

deposit any foreign material to fill or cover the land. In addition to requiring a permit for all 

disturbances greater than 5 acres, a dust control plan must be submitted for all disturbances 

greater than 20 acres. The approval of the dust control plan does not limit the permit holder's 

need to control fugitive dust from the disturbance and its related activities, nor from putting into 

effect an ongoing program for using the best practical methods of dust control. 

In addition to the requirements detailed above, there are guidelines for the Pahrump Valley (HA 

162) in southern Nevada. In this area, a dust control plan is required for any disturbance greater 

than 5 acres. Washoe and Clark counties have their own respective air quality departments and, 

therefore, are responsible for managing their particular fugitive dust programs (see Chapter Six, 

section 6.5.2.3). 

It is important to note the requirements above do not apply to agricultural activities occurring on 

agricultural land and mining exploration projects pursuant to Nevada Revised Statute 519A.180. 

7.5 EMISSIONS LIMITATIONS AND SCHEDULES OF COMPLIANCE 

BART emissions limitations and schedule for compliance is addressed directly by a revision to 

the Nevada Administrative Code (NAC) adopted on February 11, 20091

 (Appendix A). The 

regulation identifies the emission limits and control technologies required as BART. For the NV 

Energy facilities it identified January 1, 2015 or five years after approval of Nevada’s SIP, which 

 1

 In response to public comments on the draft RH SIP (contained in Appendix D), Nevada is revising the BART

requirements at NV Energy’s Reid-Gardner Generating Station. A regulatory amendment lowering the SO2

emission limits for units 1, 2 and 3 from 0.25 to 0.15 lb/106

 Btu, 24-hour average, has been submitted to the State 

Environmental Commission for presentation at their December 9, 2009 Hearing. See Appendix A. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-6 
ever occurs first, as the schedule for installation and operation of BART; for the Mohave facility, 

BART must be installed and operating at the time each unit resumes operation.2

 

The CAA programs described in Chapter Six and below have specific emissions limitations and 

schedules of compliance unique to each program. These limitations and schedules are identified 

in the specific rules. 

7.6 SOURCE RETIREMENT AND REPLACEMENT SCHEDULES 

The construction of new sources, which will ensure the early or scheduled retirement of older, 

less well-controlled sources, can greatly aid progress toward the national visibility goal over the 

long term. Nevada’s continued implementation of NSR and PSD requirements with FLM 

involvement for Class I area impact review will protect the least impaired days from further 

degradation and will assure that no Class I areas experience degradation from expansion or 

growth of a single new source or large scale regional development of stationary sources. 

7.7 SMOKE MANAGEMENT PROGRAM 

Anthropogenic fire emissions for 2002 were estimated to be approximately 250 tons per year out 

of nearly 64,000 tons per year of total fire emissions in Nevada or less than 0.5 percent of the 

total fire emissions in Nevada. Further control of anthropogenic fire emissions within the state 

maybe of little benefit in improving visibility at Nevada and other Class I areas. 

In Nevada, preventing and managing emissions from smoke are achieved through 

implementation of two separate elements of the air quality program. Open burning is controlled 

through a comprehensive set of open burning regulations. Prescribed fires used specifically for 

land management purposes are controlled through implementation of the Nevada Smoke 

Management Program. 

Open burning regulations are found in NAC 445B.22067. The regulations apply to federal, state 

and private lands equally and prohibit open burning of combustible refuse, waste, garbage, oil or 

open burning for any salvage operation. Exemptions are granted for open burning conducted for 

the purposes of weed abatement, conservation, disease control, game or forest management and 

fire training. Burning for agricultural purposes is exempt, as is the burning of yard waste and 

untreated wood at single-family residences. Small fires used for cooking, recreation, education 

or ceremonial purposes are also exempt. 

The Nevada Smoke Management Program was developed to coordinate and facilitate the 

statewide management of prescribed outdoor burning. This program is designed to meet the 

requirements of Nevada’s air quality statutes listed in Nevada Revised Statutes (NRS) 445B.100 

through 445B.845, inclusive, and the requirements of the USEPA Interim Air Quality Policy on 

Wildland and Prescribed Fires (EPA OAQPS, April 23, 1998). It supports the visibility 

 2

 On June 10, 2009, the owners of the Mohave Generating Station, including Southern California Edison (SCE),

announced the decision to decommission the station and remove the generating facility from the site. The SCE news

release states that in 2010, the plant’s generating equipment will be removed and its operating permits terminated

(http://www.edison.com/pressroom/pr.asp?bu=sce&year=2009&id=7234).

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-7 
protection goals for Federal class I areas in Section 169A of the CAA. The program does not, 

however, supersede the authority of local governments to regulate and control smoke and air 

pollution under NRS 244.361 and NRS 268.410 or the authority of the state forester to regulate 

controlled fires under NRS 527.122 through 527.128. 

The Nevada Smoke Management Program is administered by NDEP and compliance is achieved 

through a Memorandum of Understanding (MOU) between the various state and federal agencies 

that conduct prescribed burning, including the U.S. Bureau of Land Management, the U.S. Forest 

Service, the U.S. National Park Service, the U.S. Fish and Wildlife Service and Nevada state 

agencies. The MOU lists the objectives as well as both the mutual and individual responsibilities 

of the signatory parties. The MOU has a term of five years and will be renewed in 2011. Land 

managers recognize the importance of the Nevada Smoke Management Program and provide 

fiscal support for its continuation through various financial assistance agreements. 

The Smoke Management Plan (http://ndep.nv.gov/baqp/technical/SMP2005.html) is a 

collaborative document, written by the signers of the MOU, and is the guiding document of the 

program. It details the applicability of the program and responsibilities of affected parties. It 

provides information on open burn variance requirements for those land managers using 

prescribed fire and wildland fires for land management purposes. It also includes information on 

air quality monitoring at prescribed fires, burner qualifications and emission reduction methods. 

The Smoke Management Plan applies to all areas of Nevada except Clark County, Washoe 

County and Bureau of Indian Affairs trust lands. Applications for open burn variances are 

processed by NDEP. Applicants must estimate the prescribed fire’s PM10 emissions. For larger 

fires, additional information is needed and stricter requirements are imposed. For fires emitting 

greater than 1 ton but less than 10 tons PM10 and located greater than 15 miles from a Class I 

area, a smoke sensitive area or a nonattainment area, the application must include an estimate of 

emissions from a model predicting the impact of smoke on smoke sensitive receptors. For 

prescribed fire projects emitting greater than 25 tons, or more than 10 tons if the burn area is 

within 15 miles of a Class I area, a smoke sensitive area or a nonattainment area, the application 

must also include a smoke management plan that lists smoke minimization methods to be used 

and the model or calculations used to make emission estimates. The plan must have a list of 

safety and contingency measures, identification of smoke sensitive areas that may potentially be 

affected, a list of air regulators to be notified and air monitoring to be conducted. 

Variance conditions intended to mitigate smoke impacts apply to open burn variances issued by 

NDEP. These include: variances will be invalid during declared air pollution emergencies and 

alerts in affected areas; pre-ignition notification and approval is required; best smoke 

management and emission reduction techniques shall be practiced; and variances are issued with 

provisions related to supervision, inspection and availability of the variance. Additional 

restrictions and requirements apply where wildland fires are used to achieve land management 

objectives including a burn plan, applicable maps, a list of conditions under which burning will 

be suppressed and a stipulation requiring daily fire evaluation. Burn managers are expected to 

assess meteorological conditions, obtain a burn day forecast and not proceed to ignition unless 

conditions are favorable. All personnel conducting prescribed burns must meet burner 

qualifications. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-8 
Agencies conducting prescribed fires in excess of 10 tons of PM10 annually are required to 

supply NDEP with an annual fire activity report. This report provides a summary of fire 

activities including a listing of: permit number, acreage burned, fuel type, emissions estimates 

and emission factors used. NDEP is in the process of assessing current fire emission data 

collection procedures and future data needs. Consideration is being given to augmenting data 

collection efforts and emission tracking methods for the purposes of enhancing regional haze 

assessments. This may include participation in the WRAP’s Fire Emission Tracking System or 

use of other fire emission tracking tools. 

NDEP’s website includes additional information on the Nevada Smoke Management Program

and can be found at http://ndep.nv.gov/baqp/technical/smoke.html. Permit applications, an 

instruction sheet, links to applicable statutes and regulations and contact information are 

provided. 

7.8 ENFORCEABILITY OF EMISSIONS LIMITS 

Enforceability of the BART emission limits will be through rule. Amendments to the NAC were 

approved by the State Environmental Commission during their February 11, 2009 hearing.3

 

Where CAA programs specify emissions limits, these limits are enforceable through federal rule. 

Some state and local pollution control programs do not have enforceable emissions limits but are 

still effective in reducing emissions of visibility impairing pollutants. 

7.9 LONG-TERM STRATEGY 

Projected 2018 visibility conditions at the Jarbidge WA are better than the glidepath toward 

achieving natural visibility conditions by 2064. For this reason and other factors discussed in 

Chapter Six (see section 6.7) and below, Nevada’s long-term strategy will be limited to those 

pollution control programs described in Chapter Six and below (i.e., the “on-the-books” and “onthe-books” controls included in the PRP18a emission inventory in Chapters Three and Six and 

the reductions realized from the implementation of BART) that result in the RPG identified in 

Chapter Six. 

For the same reasons, Nevada did not take into consideration the costs of compliance; the time

necessary for compliance; the energy and non-air quality environmental impacts of compliance; 

and the remaining useful life of any non-BART sources in establishing our RPGs for this 

planning period. Therefore, this SIP does not include a demonstration showing how these factors 

were taken into consideration in selecting the goals. 

 3

 In response to public comments on the draft RH SIP (contained in Appendix D), Nevada is revising the BART

requirements at NV Energy’s Reid-Gardner Generating Station. A regulatory amendment lowering the SO2

emission limits for units 1, 2 and 3 from 0.25 to 0.15 lb/106

 Btu, 24-hour average, has been submitted to the State 

Environmental Commission for presentation at their December 9, 2009 Hearing. See Appendix A. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-9 
7.9.1 Anthropogenic Sources of Visibility Impairment 

Table 7-2 identifies the relative contribution of each visibility impairing pollutant from

anthropogenic and natural emission sources. These data suggest SO2 and NOx are the dominant 

anthropogenic emissions of primary particulate matter from Nevada sources. Natural sources 

include emissions from the biogenic, natural fire and windblown dust source categories. 

Emissions from natural sources represent nearly three-quarters of all emissions originating from 

within Nevada’s borders. Natural sources are uncontrollable and have little potential for 

effective control of visibility impairing emissions. 

Table 7-3 identifies the relative contribution to visibility impairment by pollutant for the baseline 

and 2018 and the change in emissions from the baseline period to 2018. Table 7-4 identifies the 

largest source categories for each pollutant and the change in emissions from the baseline to 

2018 by source category. The 2018 emission inventory does not include all emissions reductions 

related to the full implementation of BART in Nevada or other WRAP states, so additional 

emissions reductions beyond those shown are likely by 2018. The pollutants are ordered by their 

relative contribution to the baseline worst days visibility impairment. 

TABLE 7-2

SUMMARY OF NEVADA ANTHROPOGENIC AND NATURAL EMISSIONS

2002 2018

Pollutant

Anthropogenic 

Sources Natural Sources

Anthropogenic 

Sources Natural Sources

SO2 96% 4% 94% 6%

NOx 86% 14% 83% 17%

EC 27% 73% 17% 83%

PMF 44% 56% 51% 49%

PMC 38% 62% 47% 53%

NH3 86% 14% 88% 12%

POA (OC) 9% 91% 9% 91%

VOC 10% 90% 10% 90%

Total Emissions 28% 72% 27% 73% 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-10 
TABLE 7-3

NEVADA’S EXTINCTION CONTRIBUTION AND EMISSIONS BY SPECIES

Worst Days Best Days 2002 2018** Change

*OMC 40.0% 26.3% 24,734 24,822 0.4%

CM 22.3% 9.2% 161,142 188,287 17%

SO4 16.7% 40.9% 68,989 46,224 -33%

SOIL 9.7% 2.8% 20,969 24,134 15%

EC 6.5% 9.4% 6,409 5,638 -12%

NO3 4.5% 9.8% 162,475 135,496 -17%

* POA for emissions

** 2018 emissions projection does not include BART reductions

Annual Average Baseline

Extinction Contribution

Emissions 

(tpy)

Examination of Table 7-4 shows the largest source categories for four of the visibility impairing 

pollutants, organic matter carbon (OMC), coarse matter (CM), SOIL and elemental carbon (EC), 

are natural emissions resulting from natural fire and windblown dust. Point sources are the 

dominant emission category for ammonium sulfate (SO4) and ammonium nitrate (NO3), although 

area sources are also significant emitters of SOx; and mobile sources, both on- and off-road, are 

important emitters of NOx. Fugitive dust is an important source category for CM and SOIL 

emissions. The long-term strategy for the first planning period focuses on SOx and NOx

emissions originating from point and mobile sources. These source categories are discussed 

below. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-11 
TABLE 7-4

NEVADA EMISSIONS SOURCE CONTRIBUTIONS BY SPECIES

Largest 2018 

Source Category

Percent of

2018

Inventory

2002 to

2018 

Change for

Category

Second Largest

2018 Source 

Category

Percent of 

2018

Inventory

2002 to

2018

Change for

Category

*OMC Natural Fire 90.6% 0% Area 3.1% 13%

CM Windblow Dust 49.9% 0% Fugitive Dust 36.5% 45%

SO4 Point 61.3% -44% Area 30.1% 10%

SOIL Windblow Dust 43.3% 0% Fugitive Dust 30.0% 44%

EC Natural Fire 82.9% 0% **Mobile 14.0% -50%

NO3 Point 50.0% 13% **Mobile 27.5% -49.5%

* POA for emissions

** Includes on-road and off-road mobile sources

 Bold text indicates natural sources

7.9.1.1 Major and Minor Stationary Sources 

Nevada’s evaluation of the monitoring, emissions and modeling data suggests that point source 

emissions of SOx and NOx are the most likely candidates for additional control, although these 

emissions are not the most significant contributors to visibility impairment at the Jarbidge WA. 

Baseline and 2018 emissions of SOx and NOx from within Nevada are dominated by 

anthropogenic sources, as shown on Table 7-4. Although OMC (formed from Primary organic 

aerosol (POA) and Volatile organic compound (VOC) emissions), EC, PMC and PMF are 

significant contributors to visibility impairment, their emissions are dominated by natural and 

uncontrollable sources. Nevada’s SOx emissions have a greater contribution to visibility 

impairment at JARB1 than NOx (see Figures 2-7 and 2-11), although Nevada’s NOx emissions 

are two to three times greater than SOx emissions. 

As noted in Chapter Three and identified in Table 7-5, the 2018 emissions inventory lists 30 

point sources with NOx emissions greater than 100 tpy and 13 with SOx emissions greater than 

100 tpy. Point sources with emissions greater than 100 tpy represent 97 percent of Nevada’s 

total 2018 point source inventories for SOx and NOx. 

The 30 NOx point sources include all four Nevada sources subject to full BART determinations, 

as well as three other facilities that are BART-eligible but do not cause or contribute to visibility 

impairment at any Class I area. Also included on the NOx list are all five future EGUs proposed 

for Nevada, described in Chapter Three. The 13 SOx sources include two facilities subject to a 

full BART analysis, as well as two other facilities that are BART-eligible but do not cause or 

contribute to visibility impairment at any Class I area. Also included on the SOx list are three 

proposed coal-fired EGUs. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-12 
TABLE 7-5

SUMMARY OF SO2 AND NOX EMISSIONS FROM 

NEVADA POINT SOURCES FOR 2018

SO2 NOx

Annual 

Emissions (tpy) 

Number 

of 

Facilities

Cumulative Percent of 

Total Point Source 

Emissions 

Number 

of 

Facilities

Cumulative Percent of 

Total Point Source 

Emissions 

> 10,000 0 0% 1 29.0% 

2,000 to 10,000 3 78.7% 6 76.3% 

500 to 2000 3 92.5% 8 90.8% 

100 to 500 7 97.7% 15 97.0% 

A discussion of the BART process in Nevada can be found in Chapter Five where links to 

reports documenting the BART analyses are provided. Exemption modeling for one of the 

BART-eligible facilities, Chemical Lime Company located in Clark County, demonstrated that 

the maximum visibility impact of 0.245 delta dv occurred at the Grand Canyon approximately 90 

miles away, roughly half of the cause or contribute threshold of 0.5 dv. The other BARTeligible facility, Nevada Cement Company, holds a permit to reconstruct a state-of-the-art 

facility resulting in an overall reduction of emissions. 

Nevada Cement Company applied for and received a construction permit to construct a new, 

state-of-the-art cement production plant. They netted out of PSD review by shutting down and 

removing their current kilns and other ancillary production-related processes to make room for 

the new kiln. The new plant is subject to the National Emission Standards for Hazardous Air 

Pollutants program and will reduce overall emissions, while increasing production capacity. The 

net permitted (potential to emit) emission decreases for NOx, SO2 and PM10 are 1,812, 186.59 

and 167.29 tons per year, respectively. Actual 2018 emissions reductions at Nevada Cement will 

be slightly less. 

The effects of Nevada’s Renewable Portfolio Standard (RPS) on EGU source retirement and 

replacement schedules are not well known. The portfolio standard requires each electric service 

provider to generate, acquire or save electricity from portfolio energy systems or efficiency 

measures in an amount that is not less than 20 percent of the total amount of electricity sold by 

the provider by 2015. Current 2018 emissions projections include five proposed EGUs for 

Nevada, as discussed in Chapter Three and shown on Table 3-5. The demand for one or more of 

these proposed EGUs may be met by renewable energy sources, negating the emissions 

associated with a projected EGU and therefore reducing 2018 emissions. However, it is 

impossible to predict at this time which or how many of these proposed EGUs will be 

constructed. 

Many of Nevada’s point sources with SO2 or NOx emissions greater than 100 tpy are well 

controlled or will be well controlled through the BART process. In addition, several of the 

federal pollution control programs described in Chapter Six (see section 6.5.2) address emission 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-13 
from point sources (i.e., Maximum Achievable Control Technology standards). The SO2 point 

source inventory for 2018 represents a nearly 60 percent reduction from the baseline inventory, 

and the 2018 NOx point source inventory represents a greater than 30 percent reduction from the 

baseline when proposed BART controls are included. These significant reductions demonstrate 

reasonable progress from point sources in Nevada. 

7.9.1.2 Mobile Sources 

Nevada has achieved significant reductions in SOx and NOx emissions from mobile sources 

through the implementation of federal, state and local emissions control programs. 

Implementation of the federal programs will result in a 49 percent reduction in mobile source 

NOx emissions and a 63 percent reduction in mobile source SOx emissions from the baseline to 

2018 (PRP18a). These significant reductions demonstrate reasonable progress from mobile 

sources, both on-road and off-road, in Nevada. 

Table 3-15 shows mobile sources are significant source categories for NOx and ammonia (NH3). 

On-road and off-road mobile sources contribute approximately 25 percent of the total statewide 

2018 NOx emissions inventory and 23 percent of the NH3 inventory. Many of the federal 

pollution control programs identified in Chapter Six (see 6.5.2.1) focus on reducing NOx 

emissions from mobile sources, both on-road and off-road. In addition, Washoe and Clark 

Counties have implemented mobile source emissions reduction programs to address nonattainment areas, as discussed in Chapter Six (see 6.5.2.3) and this chapter (see 7.9.2.1). The 

emissions reductions related to the implementation of these local programs has not been factored

into the PRP18a emissions projections or modeling. 

7.9.1.3 Area Sources 

Area sources are by nature, relatively small emissions sources with diverse characteristics which 

make effective control difficult. Nevada has not evaluated or addressed emissions reductions 

from area sources in this, the first planning period of the sixty-year regional haze SIP process. 

7.9.1.4 International Emissions 

Emissions from outside the modeling domain, as well as those from Canada and Mexico 

contribute substantially to visibility impairment at the Jarbidge WA and other Class I areas 

across the WRAP. These emissions are beyond the control by federal, state or local regulatory 

agencies in the United States. At the Jarbidge WA, international emissions of SOx and NOx 

contribute 51 percent and 30 percent of the 2018 SO4 and NO3 visibility impairment at JARB1, 

respectively. 

Emissions from Pacific Offshore sources, as discussed in Chapter Four (see 4.3), although not 

strictly international, include emissions from international waters of the Pacific Ocean. 

Emissions of SOx and NOx from Pacific Offshore sources contribute 6.9 percent of SO4 visibility 

impairment and 1.3 percent of NO3 visibility impairment at JARB1. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-14 
7.9.2 Additional Emissions Control Programs 

 

Nevada has numerous existing emission control programs to improve and protect visibility in 

Class I areas. Generally, Nevada considers its NSR and PSD programs meet the long-term

strategy requirements for preventing future visibility impairment from proposed major stationary 

sources or major modifications to existing facilities. In addition to Nevada’s permitting 

program, Nevada also has emission control requirements for motor vehicles in Clark and Washoe 

Counties and residential burning in Washoe Country, as well as PM10

nonattainment/maintenance area requirements, dust suppression for construction areas and 

unpaved roads, and renewable energy requirements. 

The state believes that its existing regulations along with the activities outlined below together

provide for reasonable progress toward the national visibility goal. Nevada’s continued 

implementation of NSR requirements with FLM involvement for Class I area impact review will 

protect the least impaired days from further degradation and will assure that no Class I areas with

a potential to be impacted by Nevada emissions will experience degradation from expansion or 

growth of a single new source. 

7.9.2.1 State and Local Mobile Source Programs 

Nevada’s two major metropolitan areas, Clark County (Las Vegas) and Washoe County (Reno), 

have inspection and maintenance programs per the Clean Air Act requirements for areas that 

were not attaining the national ambient air quality standards for carbon monoxide (CO). 

Washoe County has a basic program while Clark County has a low enhanced program. Both 

reduce CO and VOC emissions from motor vehicles. 

Both Washoe and Clark Counties have Stage I and Stage II gasoline vapor recovery regulations. 

These systems control VOC vapor releases during the refilling of underground gasoline storage 

tanks and the refueling of motor vehicles. The Stage II system controls the release of VOC, 

benzene and toxics emitted from gasoline. Both counties have wintertime oxygenated fuel 

programs that reduce CO emissions. 

Nevada statute requires an additional statewide program to reduce emissions of pollutants from

motor vehicles, the Alternative Fueled Vehicle program. The Alternative Fueled Vehicle 

program requires state and local government fleets to operate 90 percent of their fleet vehicles on 

alternative fuel. This program reduces NOx, SO2, CO, VOCs and PM. Nevada also has a 

statewide regulation prohibiting the emission of smoke from any gasoline powered motor 

vehicle. 

Washoe and Clark Counties were designated nonattainment for CO in 1978, along with the Lake 

Tahoe Basin. The Nevada portion of the Tahoe Basin and Washoe County have each been 

redesignated as attainment. Clark County has submitted a CO redesignation request to USEPA. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-15 
7.9.2.2 Nevada’s Renewable Portfolio Standard 

With large-scale geothermal development in Nevada dating back to the mid-1980’s and use of 

hydroelectric energy since the early part of the last century, Nevada’s electric utilities have 

pioneered the use of renewable energy. In cooperation with the utilities, Nevada was one of the 

first to adopt a RPS in 1997, which is now among the most aggressive in the United States. 

Nevada’s RPS has set the bar high in terms of its percent of renewable energy, timetable and 

solar quota, requiring that not less than 20 percent of the total electricity sold in 2015 and 

thereafter be renewable. Power producers have responded by working with renewable energy 

companies to bring many new renewable projects into operation. As a result, Nevada now leads 

the nation in both geothermal and solar power per capita. 

In 2007, two of the world’s largest solar projects began operation in southern Nevada, the 64 

MW Nevada Solar One concentrating solar power plant and the 14 MW Solar Star photovoltaic 

facility at Nellis AFB. Geothermal energy is a renewable resource particularly abundant in 

Nevada. With three new geothermal plants completed in the past year, and a total of 26 projects 

under contract, Nevada’s main utility, NV Energy, is on-the-books to doubling the geothermal 

portion of its renewable energy portfolio by 2012 to a total of nearly 500 MW. These efforts to 

meet the RPS will replace some of the need for fossil fuel fired EGUs in Nevada. 

7.9.2.3 Marine Diesel Engine Rule 

As part of its National Clean Diesel Campaign, USEPA promulgated a rule to reduce diesel 

emissions from marine engines less than 30 liters per cylinder effective July 7, 2008. These 

engines are used to power a wide variety of vessels, from small fishing and recreational boats to 

large tugs and Great Lakes freighters. They are also used to generate auxiliary vessel power, 

including on ocean-going ships. The new standards will dramatically reduce PM and NOx

emissions by: tightening emissions standards for remanufactured engines; setting near-term

engine-out emissions standards (Tier 3) for newly-built marine diesel engines; and setting 

longer-term standards (Tier 4) that reflect the application of high-efficiency after-treatment 

technology. 

USEPA estimates 90 percent PM reductions and 80 percent NOx reductions from Tier 4 engines 

meeting these standards, compared to engines meeting the current Tier 2 standards. By 2030 this 

program will reduce annual nationwide emissions of NOx by about 800,000 tons and PM 

emissions by 27,000 tons, and those emission reductions continue to grow beyond 2030 as fleet 

turnover is completed. Additional information regarding this program can be found at 

http://www.epa.gov/otaq/regs/nonroad/420f08004.htm.

7.9.3 Other Considerations

WRAP technical analyses of causes of haze in the west show significant impacts from nonanthropogenic and otherwise non-controllable source sectors, such as fire, dust and sources 

outside state jurisdiction. Emissions of NOx and SO2 from point, mobile and area sources are the 

predominant anthropogenic pollutants to be addressed through regional haze SIPs in the West. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-16 
The largest category of stationary source SO2 and NOx emissions is electric generating units, a 

source category from which substantial reductions have already occurred. 

There are significant control programs in place in Nevada and the WRAP region to reduce SO2

and NOx emissions between the baseline period and 2018. Most notable of these programs is the 

implementation of BART requirements, which are anticipated to result in significant reductions

of SO2 and NOx emissions in the WRAP region. These reductions are in addition to significant 

emission reductions of SO2 and NOx from 2002 to 2006 from EGUs (BART and non-BART 

sources) in the west, on the order of 30 percent for SO2 and 10 percent for NOx. 

However, the full impact of these significant emissions reductions has not yet been fully 

evaluated by Nevada. Therefore, for the 2013 interim review, Nevada will determine refined 

reasonable progress at the Jarbidge WA in consideration of: 

• Evolving modeling and technical analyses; 

• Evolving progress on BART and reasonable progress from contributing states; and 

• Limited control Nevada has with respect to natural, interstate and international emissions 

that contribute to visibility impairment at the Jarbidge WA. 

WRAP will conduct additional modeling with updated 2018 emissions inventories that reflect 

additional control measures identified by states. The updated inventories will incorporate the 

results of Nevada and other WRAP states’ BART determinations, as well as other reasonable 

measures states identify for implementation in the initial review period. Additional reductions to 

the WRAP-wide, as well as statewide emissions are expected as states move through 

development of their regional haze programs. These modeling efforts will be scheduled by RMC 

upon completion of BART determinations by all WRAP states, anticipated in 2009 to 2010. 

A complete assessment of Nevada’s RPG cannot be made until the effects on visibility

impairment resulting from emissions reductions due to full implementation of BART and other 

RH SIP control programs are determined. However, 2018 reasonable progress measured at the 

Jarbidge WA is expected to be better than shown by the current modeling projections, which are 

based on the PRP18a emissions inventory. Nevada will continue to work with the WRAP’s 

ongoing modeling program to refine the RPG for the Jarbidge WA as these data become

available. Nevada does not anticipate revision of the RPG based on the updated modeling. The 

modeling results will, however, provide Nevada with additional tools to evaluate and refine its 

long-term strategy as part of the mid-course regional haze SIP review. 

Under the proposed long-term strategy described herein, there may be some additional visibility 

improvements that occur by 2018 beyond those reflected in the RPGs identified in Chapter Six. 

Emissions reductions due to the implementation of some state and local pollution control 

programs have not been or can not be quantified and have not been included or will not be 

included in the emissions inventories used for visibility and source apportionment modeling. 

The following section describes additional control programs in Nevada, the benefits of which 

have not been included in Nevada’s RPG identified in Chapter Six. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-17 
7.9.3.1 Uncertainty 

Nevada’s reasonable progress demonstration and development of a long-term strategy have 

identified numerous factors affecting the implementation of our long-term strategy and resulting 

reasonable progress. These factors have important but unknown impacts to all elements of the 

plan to reduce or contain emissions contributing to regional haze. The most significant factor is 

the uncertainty of the projected 2018 emission inventories, which may not reflect actual 2018 

emissions for Nevada sources. Some of the factors affecting Nevada’s reasonable progress are 

related to projected emissions inventories and the uncertainties associated with growth 

projections and the implications of future regulatory actions. 

Nevada has seen significant reductions in economic and population growth in the last two years, 

which may compromise the earlier growth projections. The observed slowdown in population 

growth may reduce actual area and mobile source emissions from projected 2018 values. The 

current economic slowdown in Nevada has severely curtailed residential and commercial real 

estate construction, a significant component of off-road mobile source emissions. Likewise, the 

high fuel costs of 2008 have resulted in lower fuel demand and therefore less on-road mobile 

source emissions. Current economic forecasts only highlight the uncertainties of projecting 

emissions based on growth estimates, with some experts predicting several years of slow 

economic growth. 

Nevada acknowledges the many difficulties associated with the projection of area and mobile 

source emissions, but remains confident the inventories represent the best available data at the 

time they were developed. However, Nevada also acknowledges there is associated uncertainty 

with the area source projections, which may over-predict future emissions in light of the current 

economic times. 

Repair and replacement schedules for large point sources of NOx and SO2 are difficult for the 

regulatory community to anticipate. It is also difficult to predict the potential permit revisions 

for other large sources in response to growth of any particular industry sector. Repair and 

replacement of current facilities will continue to drive permit revisions at their own pace, but will 

likely reduce emissions as new technology is incorporated into the facilities. 

Another level of uncertainty in the growth projections relates to regulatory uncertainty. The 

consequences of future regulatory actions are not well known at this time. The Clean Air 

Mercury Rule was recently vacated by the courts. Whether USEPA will reissue this regulation 

or what form it will take is not known at this time. The other area of regulatory uncertainty is 

how USEPA will regulate green house gas emissions and what ancillary benefits to visibility will 

be realized. 

PM 2.5 and ozone nonattainment SIPs are due 2012 and 2013. Most Nevada sources will not be

affected by nonattainment SIPs; however sources in Washoe or Clark Counties maybe subject to 

nonattainment SIPs. Certainly there will be localized reductions in PM 2.5 and ozone as SIPs are 

implemented in nonattainment areas, not only in Nevada, but across the west. Additional control 

measures resulting from nonattainment SIPs and other regulatory actions will result in direct

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-18 
reductions of visibility impairing pollutants. The co-benefits of implementing additional controls 

for PM 2.5 and ozone will also reduce emissions of visibility impairing pollutants. 

7.9.3.2 Contributions to Impairment at Class I Areas Outside of Nevada 

Tables 4-3 and 4-4 identify Nevada’s contribution to visibility impairment at Class I areas in the 

five states adjacent to Nevada based on the Particulate Matter Source Attribution Tracking 

modeling discussed in Chapter Four. In order to evaluate whether Nevada’s SIP includes all 

measures necessary to obtain its share of the emission reductions needed to meet the progress 

goals for those Class I areas, NDEP calculated:

• The visibility reductions needed at these Class I areas to achieve the 2018 URP goal; 

• The percentage of the needed reduction achieved based on the Base02d emission 

inventory and modeling scenario; 

• Nevada’s emissions reduction share; 

• The contribution of Nevada emissions to SO4 and NO3 extinction;

• The percentage change in Nevada’s emissions from Plan02d to PRP18a; and 

• The percentage change in Nevada’s weighted emissions potential (WEP) from Plan02d 

to PRP18a. 

This information is presented in Table 7-6 for the Class I area in each adjacent state with the 

highest modeled SO4 and NO3 contribution to visibility impairment for the 2018 worst days (see 

Tables 4-3 and 4-4). NDEP has included the Hoover Wilderness Area at the request of the 

FLMs. 

Examination of Table 7-6 shows that the percentage of Nevada’s emissions reductions or 

weighted emissions reductions exceed the percentage of Nevada’s contribution to visibility 

impairment at all Class I areas listed. Some of the numbers listed in the WEP change column are 

negative, reflecting an increase in Nevada’s WEP. These increases are an artifact of the WEP 

methodology, where all the percentages of emission contribution are normalized to the largest 

valued grid cell. This is especially evident for SO4 at Hells Canyon Wilderness Area in Oregon, 

where Nevada’s WEP contribution increased by nearly 30 percent. This is due to the significant

SOx emissions reductions achieved by sources closer to Hells Canyon Wilderness Area (i.e. 

sources in Idaho, Oregon and Washington) and the inverse distance function of the WEP. 

Chapter One (section 1.3.3.2 Source Apportionment Modeling) describes the WEP methodology 

and the limitations regarding the use of these data. 

In order to more fully understand the significance of the WEP data presented in Table 7-6, the 

upper portion of Figure 7-3 shows the significant contributions and 2018 reductions for Idaho, 

Oregon and Washington sources’ potential contributions and the relatively small potential 

contribution for Nevada sources at Hells Canyon Wilderness Area. The lower portion of Figure 

7-3 presents the SOx weighted emission potential map for Hells Canyon Wilderness Area. Note 

that Nevada has only three grid cells with weighted emission potentials greater than one percent, 

one of which is LS Power’s proposed 1500 MW coal-fired EGU in east central Nevada. 

Figures 7-4, 7-5 and 7-6 show similar WEP analyses for the Sawtooth Wilderness Area, 

Desolation Wilderness Area, and Hoover Wilderness Area, respectively. Review of Chapter 

Three (section 3.8.1 Nevada SOx Emission Inventory for 2002 and 2018, Table 3-7) shows that 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-19 
area sources are the only Nevada source category with significant growth (1,243 tons or 10 

percent) of SO2 emissions. Figure 3-10 is a regional map of gridded SOx emissions, while Figure 

3-11 breaks down Nevada’s SO2 emissions by county. 

These figures and Table 7-6 are all based on the PRP18a emission inventory, which does not 

incorporate the full implementation of BART in Nevada or across the WRAP region (see 

Chapter One 1.3.2 Emissions Analyses and Projections). Table 7-1 identifies the additional 

emissions reductions from the PRP18a inventory resulting from the full implementation of

BART in Nevada. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-20 
TABLE 7-6

SUMMARY OF VISIBILITY IMPAIRMENT AT NEARBY CLASS I AREAS 

AND NEVADA’S EMISSIONS REDUCTIONS

Monitor -

Component

Baseline

Extinction

(dv or

Mm-1)

2018 URP

(dv or

Mm-1)

Extinction

Reduction

Needed

(percent)

2018

RPG 

(dv or

Mm-1)

Reduction

Acheived

(percent)

2018

Pollutant

Contribution

by Nevada

from PSAT

(percent)

Nevada's

Emissions

Reduction 

Share 

(percent)

Reduction

in Nevada

Emissions

Base02d to

PRP18a

(percent)

Reduction

Nevada

Weighted

Emission

Potential*

(percent)

GRCA2 - Deciview 11.66 10.58 9.3% 11.10 4.8%

GRCA2 - SO4 5.36 4.11 23.3% 4.56 14.9% 2.8% 0.7% 33.0% 65.2%

SYCA1 - Deciview 15.25 13.25 13.1% 15.08 1.1%

SYCA1 - NO3 2.03 1.69 16.7% 1.67 17.7% 4.3% 0.7% 16.6% 22.5%

BLIS1 - Deciview 12.63 11.10 12.1% 12.22 3.2%

BLIS1 - SO4 5.07 3.96 21.9% 4.90 3.4% 4.4% 1.0% 33.0% -4.4%

BLIS1 - NO3 2.38 2.01 15.5% 1.59 33.2% 20.0% 3.1% 16.6% 36.2%

HOOV1 - Deciview 12.87 11.66 9.4% 12.45 3.3%

HOOV1 - SO4 5.00 3.91 21.8% 4.61 7.8% 2.6% 0.6% 33.0% -1.0%

HOOV1 - NO3 1.63 1.43 12.3% 1.35 17.2% 8.3% 1.0% 16.6% 23.4%

SAWT1 - Deciview 13.78 12.06 12.5% 13.25 3.8%

SAWT1 - SO4 3.06 2.50 18.3% 2.62 14.4% 2.5% 0.5% 33.0% -7.7%

SAWT1 - NO3 0.63 0.65 -3.2% 0.55 12.7% 3.2% -0.1% 16.6% 12.0%

HECA1 - Deciview 18.55 16.17 12.8% 16.60 10.5%

HECA1 - SO4 8.37 6.35 24.1% 7.41 11.5% 4.0% 1.0% 33.0% -29.2%

HECA1 - NO3 28.47 19.69 30.8% 20.56 27.8% 5.5% 1.7% 16.6% 13.8%

ZION1 - Deciview 13.24 11.78 11.0% 12.76 3.6%

ZION1 - SO4 5.29 4.04 23.6% 4.48 15.3% 5.6% 1.3% 33.0% 43.8%

BRCA1 - Deciview 11.65 10.52 9.7% 11.22 3.7%

BRCA1 - NO3 2.52 2.06 18.3% 2.27 9.9% 8.8% 1.6% 16.6% 21.7%

* Anthropogenic source categories only.

Utah

Arizona

California

Idaho

Oregon

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-21 
FIGURE 7-3 

WEIGHTED EMISSION POTENTIAL ANALYSIS FOR HELLS CANYON WILDERNESS 

AREA

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-22 
FIGURE 7-4 

WEIGHTED EMISSION POTENTIAL ANALYSIS FOR SAWTOOTH WILDERNESS AREA

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-23 
FIGURE 7-5 

WEIGHTED EMISSION POTENTIAL ANALYSIS FOR DESOLATION WILDERNESS 

AREA

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-24 
FIGURE 7-6 

WEIGHTED EMISSION POTENTIAL ANALYSIS FOR HOOVER WILDERNESS AREA 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-25 
Baseline and projected annual SOx emissions for the states adjacent to Nevada are shown in 

Figure 7-7, while Table 7-7 shows the percentage change in the inventories. 

FIGURE 7-7 

BASELINE AND PROJECTED SOx EMISSIONS BY STATE

TABLE 7-7

BASELINE AND PROJECTED SOx INVENTORIES BY STATE

State Plan02d PRP18a Percent Change

AZ 111,709 82,334 26.3%

CA 82,089 83,611 -1.9%

ID 39,163 26,465 32.4%

NV 68,979 46,224 33.0%

OR 52,449 29,336 44.1%

UT 55,640 45,916 17.5%

WA 86,323 52,493 39.2%

7.10 REASONABLE PROGRESS ASSESSMENT 

Nevada has concluded that the emissions reductions due to federal, state and local “on-thebooks” and “on-the-books” emissions control coupled with those resulting from the installation 

of BART requirements represent a reasonable long-term strategy for the first regional haze 

planning period. Modeled visibility improvement at the Jarbidge WA for the 20 percent worst 

days is expected to be better than the uniform rate of progress by 2018 based on reductions from

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-26 
federal and state “on-the-books” and “on-the-books” emissions controls represented by the 

18PRPa emissions inventory. Visibility on the 20 percent best days is also projected to improve 

in 2018 as a result of the emissions reductions expected from federal and state control programs. 

Nevada’s 2018 RPG shows better visibility improvement at the Jarbidge WA than the uniform

rate of progress. This significant progress parallels the uniform rate of visibility improvement 

needed to restore natural visibility conditions by 2064 as required by the regional haze rule. 

Visibility impairment at the Jarbidge WA is dominated by emissions from natural or otherwise 

uncontrollable sources or areas. Air management agencies are unable to control emissions from

natural sources, or emissions from sources beyond the purview of the United States’ regulatory 

authority. 

For these reasons, Nevada has concluded the long-term strategy identified and discussed herein 

makes reasonable progress toward the national goal of remedying existing impairment of 

visibility in the Jarbidge WA resulting from manmade air pollution for the first planning period. 

It is reasonable for Nevada to defer reductions to later planning periods in order to maintain a 

consistent glidepath toward the long-term goal. 

Nevada’s RPG is an interim goal representing incremental visibility improvement over the first 

planning period ending 2018. As such, Nevada will take into account the effects of other state 

and local controls when setting reasonable progress as they become available, even though they 

may not be federally enforceable programs. Nevada will take other states’ SIPs and BART 

determinations into account during the first review and evaluation of our long-term strategy, 

modeling results and RPG. 

To summarize, the regional haze SIP presented here documents the technical basis to determine 

our share of emissions reduction obligations necessary to achieve reasonable progress in the 

Jarbidge WA and other Class I areas affected by Nevada’s emissions of visibility impairing 

pollutants. Nevada considers our progress to incrementally improve visibility at the Jarbidge 

WA and other Class I areas to be reasonable for the first regional haze planning period. In 

addition, Nevada has identified several scenarios that suggest additional reductions in Nevada’s 

projected 2018 emissions inventory that will likely result in better projected visibility 

improvement at the mandatory Class I areas than currently predicted. 

Under the long-term strategy described herein, there will be some additional visibility

improvements that occur by 2018, beyond those reflected in the RPGs identified in Chapter Six. 

Beginning in 2009, Nevada will develop procedures and schedules for evaluation of source 

categories to determine what additional controls are appropriate to achieve further reasonable 

progress. This evaluation will take into account any new relevant monitoring and modeling 

information related to the contribution of Nevada anthropogenic sources to Class I impairment, 

new regulations that may benefit regional haze, and any new guidance related to the identifying 

additional control measures consistent with reasonable progress requirement of the regional haze 

rule. Nevada’s commitment to progress reports and future plan revisions is discussed in Chapter 

Nine. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 7-27