NEVADA REGIONAL HAZE 

STATE IMPLEMENTATION PLAN 

A Plan for Implementing 

Section 308 (40 CFR § 51.308) 

of the Regional Haze Rule

State of Nevada 

Division of Environmental Protection 

901 South Stewart Street, Suite 4001 

Carson City, Nevada 89701 

October 2009

NOTE TO READERS 

Nevada’s Regional Haze State Implementation Plan (SIP) was developed for submittal to the 

U.S. Environmental Protection Agency under Section 308 of the Regional Haze Rule (40 CFR § 

51.308) as a revision to the applicable Nevada state implementation plan. The SIP is based on 

data that existed as of January 5, 2009 with one exception. In response to public comments, 

Nevada re-evaluated the Best Available Retrofit Technology emission limits for SO2 at NV 

Energy’s Reid Gardner facility. The limits were lowered based on 2009 data. This document is 

the initial step in a sequential planning effort working toward achieving the national goal of 

returning to natural visibility conditions in mandatory Class I areas by 2064. 

Nevada’s Regional Haze SIP and related documents can be found on the following website: 

http://ndep.nv.gov/baqp/planmodeling/rhaze.html. Western Regional Air Partnership (WRAP) 

reports and documents can be found on the following websites: http://www.wrapair.org/ or at the 

WRAP TSS website: http://vista.cira.colostate.edu/tss/. 

Nevada has chosen to link to websites on the internet for many references cited in this SIP. We

have backed up these links by putting electronic copies of reference documents on the Nevada 

Division of Environmental Protection’s (NDEP) server. If any of the links in this document do 

not work for you, you may contact the NDEP Bureau of Air Quality Planning at 901 South 

Stewart Street, Suite 4001, Carson City, Nevada 89701 or by telephone at 775-687-9349 for 

assistance. 

ACKNOWLEDGEMENTS 

This document was written by the following staff of NDEP, Bureaus of Air Quality Planning and 

Air Pollution Control: 

Principal Authors

Frank Forsgren 

Brenda Harpring 

Valerie Kauffman 

Adele Malone, Supervisor

Contributing Staff

Matthew DeBurle 

Paul Williams

And other staff 

Reviewers

Michael Elges, Chief, Bureau Air Quality Planning 

Greg Remer, Chief, Bureau Air Pollution Control 

The supporting technical information in this plan was assembled with the assistance of the 

WRAP staff, member states and their consultants, the Western Governor’s Association, and the 

Western States Air Resources Council. In addition, NV Energy, Southern California Edison and 

Nevada Cement provided BART analyses for their sources. 

EXECUTIVE SUMMARY

REGULATORY HISTORY 

In 1977, Congress amended the Clean Air Act (CAA) establishing a national goal to protect 

visibility in Class I federal areas -- national parks, forests and wilderness areas. The 

amendments called for the “prevention of any future, and the remedying of any existing, 

impairment of visibility in mandatory class I Federal areas which impairment results from

manmade air pollution.” (CAA § 169A) In 1979, the United States Environmental Protection 

Agency (USEPA), in consultation with the Secretary of Interior, promulgated a list of 156 

mandatory Class I areas in which visibility was determined to be an important factor. In Nevada, 

only one area was designated: the Jarbidge Wilderness Area (Jarbidge WA) in the northeast 

corner of the state. 

On December 2, 1980, USEPA promulgated regulations to address visibility impairment that is 

“reasonably attributable” to a single source or small group of sources. These regulations 

represented the first phase in addressing visibility impairment; action on regional haze was 

deferred. In 1990, the act was amended to require that regional haze issues be addressed. 

Subsequently, USEPA adopted phase II visibility rules, or the Regional Haze Rule (RHR), 

thereby establishing a comprehensive visibility protection program for Class I federal areas. 

The intent of the RHR is to improve visibility over the next 55 years in all 156 mandatory Class I 

areas across the country. It requires each affected state to develop and adopt an implementation 

plan that will improve the haziest days and protect the clearest days at each mandatory Class I 

area in the state with a goal of returning to natural visibility conditions by the year 2064. Each 

plan must provide a comprehensive analysis of natural and man-made sources of haze in each 

mandatory Class I area in the state and contain strategies to control anthropogenic emissions that 

contribute to haze. The plan must also address the transport of haze across state boundaries. 

This document is Nevada’s Regional Haze State Implementation Plan (RH SIP) and has been 

prepared to meet the requirements of the federal RHR as codified in Title 40 of the Code of 

Federal Regulations (CFR) Part 51 Section 308. 

REGIONAL HAZE STATE IMPLEMENTATION PLAN REQUIREMENTS 

The RHR covers a long period, broken into several planning phases to ultimately meet the 

national visibility goal by the year 2064. The approach taken in preparing this RH SIP is to set 

the initial planning period (2008 through 2018) as the “foundational plan” for the subsequent 

planning periods. Though national visibility goals are to be achieved by the year 2064, this plan 

meets the requirements of improving visibility for the most impaired days and ensuring no 

degradation in visibility for the least impaired days for the period ending in 2018, the first 

planning period in the federal rule. 

Nevada’s RH SIP has been prepared by the Nevada Division of Environmental Protection 

(NDEP) and contains strategies and elements related to each requirement of the federal rule. The 

SIP is based on data that existed as of January 5, 2009 with one exception. In response to public 

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comments, Nevada re-evaluated the Best Available Retrofit Technology (BART) emission limits 

for SO2 at NV Energy’s Reid Gardner facility. The limits were lowered based on 2009 data. 

The appendices at the end of this document provide additional information, including new 

Nevada Administrative Code (NAC) associated with this plan and evidence of public 

participation, along with public comments and NDEP responses to those comments. Technical 

support documents and reference material (technical analyses and reports) prepared by the 

Western Regional Air Partnership (WRAP), the Regional Planning Organization (RPO) 

designated by USEPA to assist western states in the development of regional haze plans, and 

other sources are linked in the text to the web site where they are publicly available. 

A brief summary, organized according to the regional haze program requirements in 40 CFR 

51.308, of how Nevada has fulfilled the requirements of the RHR for the first planning period 

and how Nevada intends to fulfill future requirements follows. 

Reasonable Progress Goals and Calculations of Baseline and Natural Visibility Conditions 

The RHR at 40 CFR 51.308(d)(1) requires the state, for each mandatory Class I area within the 

state, to establish reasonable progress goals that will achieve the national goal of a return to 

natural visibility conditions by 2064. 40 CFR 51.308(d)(2) requires the state to calculate 

baseline, current and natural visibility conditions, which in turn are used to calculate the uniform

rate of progress (URP) per year necessary to achieve natural conditions by 2064. States are 

directed to show graphically what would be the URP for each mandatory Class I area within the 

state. To develop the URP, or glidepath, states must determine baseline visibility conditions for 

the period 2000 through 2004 and natural background visibility conditions in 2064. 

Visibility conditions and the glidepath for the Jarbidge WA are presented in Chapter Two. The 

baseline visibility condition for the period 2000 through 2004 for the 20 percent worst days is 

12.07 deciviews (dv) and 2.56 dv for the 20 percent best days. The natural background visibility 

condition at Jarbidge is estimated to be 7.87 dv for the 20 percent worst days and 1.14 dv for the 

20 percent best days. The URP value for the planning period ending in 2018 for Jarbidge WA is 

11.09 dv.

Analysis of baseline period monitoring data at Jarbidge WA shows that organic matter carbon 

(OMC) and elemental carbon (EC) extinction account for more than 45 percent of the total 

average annual reconstructed extinction for the 20 percent worst days. Coarse and fine particle 

mass (CM and SOIL) extinction account for an additional 30 percent. Approximately 20 percent 

of the annual extinction budget results from the formation of ammonium sulfate (sulfate) and 

ammonium nitrate (nitrate) due to emissions of sulfur oxides (SOx) and nitrogen oxides (NOx) 

from predominantly anthropogenic sources. Based on these findings, NDEP concludes that 

windblown dust and natural fire emissions contribute significantly to visibility impairment at the 

Jarbidge WA. The data suggest that visibility improvement due to emissions reductions of SOx

and NOx from anthropogenic sources may be overwhelmed by emissions from natural sources, in 

particular seasonally variable OMC and CM, as well as EC and SOIL. 

Visibility modeling was used to determine the expected 2018 visibility improvements resulting 

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from existing federal and state air quality regulations in effect by 2018. This modeling included 

a limited assessment of the impacts of applying BART to BART-eligible coal-fired electric 

generating units to achieve the presumptive limits for sulfur dioxide (SO2). The modeling results 

are presented in Chapter Four. Modeling shows that as a result of regulatory requirements at the 

local, state and federal levels during the planning period of this SIP, emission reductions will 

result in greater visibility improvement than the URP value for the Jarbidge WA in 2018. 

The demonstration of reasonable progress requires setting goals for the 20 percent worst and the 

20 percent best days in each Class I area, based on an evaluation of how BART and other 

regional haze strategies will reduce emissions and improve or protect visibility. Chapter Six of

this plan describes the reasonable progress demonstration in detail. Nevada has determined that 

implementation of BART and the federal, state and local programs included in the 2018 visibility 

modeling represents reasonable progress in Nevada for the initial regional haze planning period. 

Nevada actually exceeds URP requirements for the Jarbidge WA in 2018 and meets its share of 

emission reduction obligations at out-of-state Class I areas. It is not necessary to consider 

additional emission controls on non-BART Nevada sources at this time. It is appropriate to 

evaluate additional reductions in the future for later planning periods in order to sustain a 

consistent glidepath toward the 2064 goal. 

Long-term Strategy for Regional Haze

The RHR at 40 CFR 51.308(d)(3) requires the state to submit a long-term strategy that addresses 

regional haze visibility impairment at all mandatory Class I areas that may be impacted by 

emissions from the state. The strategy must include enforceable emissions limitations, 

compliance schedules and other measures as necessary to achieve the state’s reasonable progress 

goals. As part of the technical basis for the long-term strategy, the state must identify its 

baseline emissions inventory and all anthropogenic sources of visibility impairment. This SIP 

covers long-term strategies for visibility improvement between baseline conditions and visibility 

conditions projected for 2018. 

Chapter Three describes Nevada’s baseline and 2018 emissions inventories and analyzes the 

sources of visibility impairment by source category. Total emissions for all visibility impairing 

pollutants in 2018 are projected to be 1,336,811 tons. Of that total, 27 percent are from 

anthropogenic sources; 73 percent are from natural sources. Emissions from natural sources are 

considered uncontrollable. Of the eight visibility impairing pollutants analyzed, anthropogenic 

sources are important contributors to three of them: SOx, NOx, and NH3. SOx emissions in 

Nevada come predominantly from point and area sources, 61 and 31 percent, respectively. NOx

emissions come predominantly from point sources, approximately 50 percent; mobile sources 

account for another 27 percent. NH3 emissions come predominantly from area sources, 59 

percent, with another 23 percent from on-road mobile sources. Volatile organic compounds 

(VOC), primary organic aerosol (POA), EC, PM fine and PM coarse emissions are dominated by 

natural source categories, and those source categories are not controllable. 

Chapter Four presents the results of visibility and source apportionment modeling, which show 

that the Jarbidge WA will meet the URP value for 2018. The modeling results and technical 

analyses indicate that, although Nevada sources contribute to visibility impairment at the 

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Jarbidge WA and Class I areas located in adjacent states, sources outside the State of Nevada 

have the greatest impact on regional haze at Jarbidge WA. Furthermore, regional weighted 

emissions potential analyses show the significant role of emissions from windblown dust, 

fugitive dust and natural fire in visibility impairment at the Jarbidge WA. 

The 2018 Particulate Matter Source Attribution Tracking modeling demonstrates that “Outside 

Domain,” or boundary conditions, emissions comprise almost 44 percent of the total sulfate at 

Jarbidge WA -- four times greater than any other regional source. Nevada’s contribution is less 

than six percent. Sulfur oxide emissions from point, area and natural fire sources each contribute 

approximately one third to visibility impairment at Jarbidge WA. For nitrate, Idaho is the largest 

regional source contributor; about 30 percent. Nevada contributes approximately 13 percent. 

Point, mobile and area source emissions contribute the most to nitrate, with a much smaller 

portion from natural fire emissions. 

Nevada evaluated its contribution to visibility impairment at Class I areas in adjacent states: 

Arizona, California, Idaho, Oregon and Utah. Nevada calculated the visibility reductions needed 

at these Class I areas to achieve the 2018 URP; the percentage of the needed reduction achieved; 

Nevada’s emissions reduction share; the contribution of Nevada emissions to sulfate and nitrate 

extinction; the percentage change in Nevada’s emissions from baseline to 2018; and the 

percentage change in Nevada’s weighted emission potential from baseline to 2018. The 

percentage of Nevada’s state-wide emissions reductions exceeds the percentage of Nevada’s 

contribution to visibility impairment at all impacted Class I areas. Therefore, the state meets its 

share of emission reduction obligations necessary for achieving reasonable progress in each 

mandatory Class I area it affects. 

Nevada’s long-term strategy is presented in Chapter Seven and comprises all of the “on-theway” and “on the books” control programs and federal, state and local rules discussed in Chapter 

Six together with additional control programs discussed in Chapter Seven and the BART 

requirements found in Chapter Five. In developing this strategy, Nevada considered ongoing 

control programs, measures to mitigate construction activities, source retirement and replacement 

schedules, smoke management techniques for agriculture and forestry and enforceability of 

specific measures as required by 40 CFR 51.308(d)(3). 

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

Class I areas. Generally, Nevada considers its New Source Review (NSR) and Prevention of 

Significant Deterioration (PSD) programs meet the long-term strategy requirements for 

preventing future visibility impairment from proposed major stationary sources or major 

modifications to existing facilities. 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 a new source or a major modification of an 

existing source. 

As noted above, for the planning period of this SIP, visibility modeling shows that emission 

reductions resulting from the implementation of regulatory requirements at the local, state and 

federal levels will provide greater visibility improvement than the URP for the Jarbidge WA in 

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2018. Furthermore, Nevada is meeting its share of emission reduction obligations at mandatory 

Class I areas that it affects in neighboring states. The RHR requires an evaluation every five 

years of reasonable further progress. Nevada will evaluate reasonable further progress for the 

Jarbidge WA on this schedule and, if necessary, revise its long-term strategy as appropriate. 

Monitoring Strategy, Emission Inventory, Recordkeeping and Reporting 

The RHR at 40 CFR 51.308(d)(4) requires the state to develop a monitoring strategy for 

measuring, characterizing and reporting regional haze visibility impairment that is representative 

of all mandatory Class I areas within Nevada. This strategy must also coordinate with the 

monitoring strategy required in 40 CFR 51.305 for reasonably attributable visibility impairment, 

as well as provide for a variety of other requirements designed to evaluate reasonable progress 

toward meeting national visibility goals. 

Nevada’s monitoring strategy is presented in Chapter Eight. Visibility conditions in mandatory 

Class I areas throughout the United States are presently measured by the Interagency Monitoring 

of Protected Visual Environments (IMPROVE) monitoring network, which is operated and 

maintained through a formal cooperative relationship between USEPA and Federal Land 

Manager (FLM) agencies. Nevada’s regional haze monitoring strategy relies on information 

generated through the IMPROVE network for the Class I area at the Jarbidge WA. Nevada 

commits to continue using the IMPROVE monitoring data and to update Nevada’s emissions 

inventory periodically, as required by the RHR. The inventory updates will be used for state 

tracking of emission changes and trends, to provide input into the evaluation of whether 

reasonable progress goals will continue to be achieved at Jarbidge WA and for other regional 

analyses. 

40 CFR 51.305 requires states to develop a strategy for monitoring reasonably attributable 

visibility impairment in its Class I areas. To satisfy this requirement, Nevada is subject to a 

federal visibility protection plan (visibility FIP). Nevada’s regional haze monitoring strategy 

will coordinate with Nevada’s visibility FIP by continuing to use the data collected by the 

IMPROVE program and will promote reasonable progress toward the national visibility goal. 

The RHR at 40 CFR 51.308(d)(4)(v) requires a statewide emission inventory of pollutants that 

are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class 

I area. Several emission inventories were prepared by the Regional Modeling Center for the 

WRAP as part of the regional haze effort. Chapters One and Three discuss the development of 

these inventories and the baseline and projected emissions for SOx (particulate and gaseous 

phases), SO2 (gas phase only), NOx, VOC, POA, EC, PM fine, PM coarse and NH3 in Nevada. 

Nevada commits to continue developing emission inventory data to allow for tracking emission 

increases or decreases as related to regional haze as funding and resources allow. Information 

collected will be made available periodically, as required by the RHR.

Best Achievable Retrofit Technology 

The RHR at 40 CFR 51.308(e) requires states to determine BART and compliance schedules for 

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each BART-eligible source in the state that emits any air pollutant that may reasonably be 

anticipated to cause or contribute to impairment of visibility in any mandatory Class I federal 

area. Section 169A(b) of the CAA defines BART-eligible sources as sources in 26 specific 

source categories, in operation within a 15-year period prior to enactment of the 1977 PSD rules. 

States must determine BART according to five factors set out in section 169A(g)(2) of the CAA. 

Emission limitations representing BART and schedules for compliance with BART for each 

source subject to BART must be included in the state’s long-term strategy. 

Nevada’s RH SIP fulfills the requirements of 40 CFR 51.308 (e)(1); Chapter Five describes the 

BART determination in detail. The BART analyses conducted by Nevada were based, in part, 

on an assessment of many of the same factors (including the 4-factor analysis) that must be 

addressed in establishing the reasonable progress goal. Four facilities, comprising 10 units, are 

subject to BART: NV Energy’s generating stations at Tracy (units 1, 2 and 3), Ft. Churchill 

(units 1 and 2) and Reid Gardner (units 1, 2 and 3); and Southern California Edison’s generating 

station at Mohave1

 (units 1 and 2). The control requirements imposed by Nevada’s BART 

determinations satisfy the reasonable progress goal-related requirements for source review in the 

first planning period. 

A substantial reduction in NOx, SO2 and PM10 emissions are anticipated upon installation of 

Nevada BART controls. Emissions reductions resulting from the installation and operation of 

BART at these sources are estimated to be greater than 20,000 tpy for NOx, greater than 40,000 

tpy for SO2 and greater than 4,000 tpy for PM10. Nevada will not require non-BART sources to 

install and operate new emissions controls in the first planning period of the RHR. 

Periodic Revisions and Reports; Adequacy Determination

The RHR at 40 CFR 51.308(f)-(h) requires RH SIP revisions every ten years, reports describing 

progress towards the state’s reasonable progress goals every five years and a determination of the 

adequacy of the SIP along with the five year reports. In Chapter Nine, Nevada commits to fulfill 

each of these requirements and each of the elements therein, as funding and resources allow. 

State and Federal Land Manager Coordination

The RHR at 40 CFR 51.308(d)(1)(iv) and (d)(3)(i) requires states to coordinate with other states 

during the development of reasonable progress goals and emission management strategies. 

Nevada has met these requirements through participation in the WRAP and commits to continue 

to coordinate via the WRAP or other means in Chapter Nine. In the WRAP process, Nevada 

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 

 

1

 On June 10, 2009, after the cutoff date for incorporating new information into this SIP (January 5, 2009), the 

owners of the Mohave Generating Station announced the decision to decommission the station and remove the 

generating facility from the site. This new information is noted at relevant places in the SIP, but the SIP has not 

been revised to incorporate this information. 

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the WRAP since its inception, and in the forums, workgroups and committees that were formed 

to address many elements of the SIP. 

40 CFR 51.308(i) further requires states to coordinate with FLMs in developing the RH SIP. 

States must provide a contact to whom FLMs can submit recommendations on the 

implementation of the RHR; provide FLMs an opportunity for consultation at least 60 days prior 

to holding any public hearing on the SIP; provide a public record of how the state addressed any 

FLM comments; and provide procedures for continuing consultation with FLMs on the 

implementation of the state’s RH SIP.

Chapter Nine describes Nevada’s coordination and consultation with FLMs for this SIP and our 

commitment to continued coordination. Again, participation in the WRAP fulfills a significant 

portion of the consultation requirements with FLMs. This included an opportunity to discuss 

their assessment of visibility impairment at the Jarbidge WA and to provide recommendations on 

reasonable progress goals and the development and implementation of visibility control 

strategies. A draft of Nevada’s RH SIP was provided to the FLMs with a 60-day comment 

period prior to the public hearing on the SIP. FLM comments and Nevada’s responses are found 

in Appendix C. Additional FLM comments and other public comments on the RH SIP submitted 

during the public comment period are included in Appendix D, together with NDEP’s responses. 

Nevada commits to continued participation with the WRAP as long as it exists and to 

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

with the WRAP will contribute significantly to Nevada’s inter-state coordination for future SIP 

revisions and progress reports. 

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CONTENTS

PREFACE 

EXECUTIVE SUMMARY ..................................................................................... i 

ACRONYMS, ABBREVIATIONS AND TERMS................................................ xi

LIST OF TABLES ............................................................................................... xiv 

LIST OF FIGURES .............................................................................................. xvi 

CHAPTER ONE: OVERVIEW

1.1 Nevada’s Class I Area – Jarbidge Wilderness Area ...............................................1-2 

1.2 The Western Regional Air Partnership (WRAP) and Nevada..............................1-15 

1.3 Technical Support Background.............................................................................1-16 

1.4 References ............................................................................................................1-32

CHAPTER TWO: BASELINE AND NATURAL VISIBILITY CONDITIONS 

AND UNIFORM RATE OF PROGRESS

2.1 Introduction.............................................................................................................. 2-2 

2.2 Baseline Conditions for the Jarbidge Wilderness Area ........................................... 2-3 

2.3 Natural Conditions for the Jarbidge Wilderness Area ............................................ 2-3 

2.4 Uniform Rate of Progress Glidepath to Natural Conditions in 2064 ...................... 2-6 

2.5 Haze Impacting Particles – Baseline Period ........................................................... 2-7 

2.6 References ............................................................................................................. 2-22 

CHAPTER THREE: SOURCES OF IMPAIRMENT IN NEVADA

3.1 Background ............................................................................................................. 3-2

3.2 Sources of Visibility Impairment............................................................................. 3-3 

3.3 Development of the 2002 And 2018 Emission Inventories .................................... 3-4 

3.4 Point Source Emission Inventory............................................................................. 3-5 

3.5 Fire Emission Inventory......................................................................................... 3-11 

3.6 Area Source Emission Inventory ........................................................................... 3-12 

3.7 Overview of Emission Inventory System – TSS ................................................... 3-12 

3.8 Emissions in Nevada ............................................................................................. 3-13 

3.9 Summary of 2018 Emission Projections ............................................................... 3-40 

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CONTENTS - Continued 

CHAPTER FOUR: VISIBILITY AND SOURCE APPORTIONMENT 

MODELING

4.1 Introduction.............................................................................................................. 4-2 

4.2 Visibility Modeling Results for 2018 ...................................................................... 4-5 

4.3 Source Apportionment Modeling Results ............................................................... 4-9 

4.4 Weighted Emissions Potential Analyses Results................................................... 4-20 

4.5 Visibility and Source Apportionment Modeling Summary .................................. 4-30 

CHAPTER FIVE: BEST AVAILABLE RETROFIT TECHNOLOGY

5.1 Overview of the BART Process............................................................................... 5-2 

5.2 BART Eligible Sources In Nevada .......................................................................... 5-2 

5.3 Exemption Modeling Setup and Analysis ............................................................... 5-4 

5.4 Summary of BART Exemption Modeling Results ................................................. 5-6 

5.5 Summary of BART Control Analysis ..................................................................... 5-8 

5.6 Visibility Improvement Due to BART Implementation ........................................ 5-16 

CHAPTER SIX: REASONABLE PROGRESS FOR THE JARBIDGE 

WILDERNESS AREA 

6.1 Introduction ............................................................................................................. 6-2 

6.2 Steps for Developing Reasonable Progress Goals ................................................... 6-3 

6.3 Establishing Baseline and Natural Visibility Conditions ........................................ 6-3 

6.4 Determining the Uniform Rate of Progress ............................................................. 6-3 

6.5 Identifying the Measures to Achieve the Uniform Rate of Progress ....................... 6-4 

6.6 Establishing Reasonable Progress for Nevada ...................................................... 6-14 

6.7 Demonstration that the RPG for Worst Days is Reasonable ................................. 6-16 

6.8 References..............................................................................................................6-24 

CHAPTER SEVEN: LONG TERM STRATEGY FOR NEVADA

7.1 Long-Term Strategy Overview ............................................................................... 7-2 

7.2 BART Controls ....................................................................................................... 7-3 

7.3 Visibility Improvement ........................................................................................... 7-4 

7.4 Mitigation of Construction Impacts ........................................................................ 7-5 

7.5 Emissions Limitations and Schedules of Compliance ............................................ 7-6 

7.6 Source Retirement and Replacement Schedules ..................................................... 7-7 

7.7 Smoke Management Program ................................................................................. 7-7 

7.8 Enforceability of Emission Limits .......................................................................... 7-9 

7.9 Long-Term Strategy ................................................................................................ 7-9 

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CONTENTS - Continued 

7.10 Reasonable Progress Assessment ......................................................................... 7-26 

CHAPTER EIGHT: MONITORING STRATEGY 

8.1 Introduction .............................................................................................................8-2 

8.2 Nevada’s Regional Haze Visibility Monitoring Strategy ...................................... 8-2 

8.3 Coordination with §51.305 Monitoring Strategy Requirement ............................... 8-3 

8.4 Associated Regional Haze Monitoring Strategy Requirements ............................. 8-3 

8.5 Overview of Improve Site at Jarbidge .................................................................... 8-5 

8.6 Commitment to Future Monitoring ........................................................................ 8-5 

CHAPTER NINE: COORDINATION, FUTURE COMMITMENTS AND 

REQUIREMENTS 

9.1 Plan Development ................................................................................................... 9-2 

9.2 Future Coordination and Consultation Commitments ............................................ 9-4 

9.3 Commitment to Progress Reports ........................................................................... 9-5 

9.4 Determination of Current Plan Adequacy ............................................................... 9-5 

9.5 Commitment to Future SIP Revisions .................................................................... 9-6 

APPENDIX A: Nevada BART Regulation 

APPENDIX B: BART Determination Support Documents 

APPENDIX C: Federal Land Management Agency Comments and Nevada’s 

Response 

APPENDIX D: Evidence of Public Participation; Public Comments and Nevada’s 

Responses 

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Acronyms, Abbreviations and Terms 

Anthropogenic Caused or produced by humans 

BACT Best Available Control Technology 

BART Best Available Retrofit Technology 

Base02 2002 actual baseline emissions 

Base18 2018 base case emissions 

CAA Clean Air Act 

CAIR Clean Air Interstate Rule

CAMD Clean Air Markets Division 

CAMx Comprehensive Air Quality Model with Extensions 

CENRAP Central Regional Air Planning Association 

CFR Code of Federal Regulations 

CIRA Cooperative Institute for Research in the Atmosphere 

CM Coarse matter

CMAQ Community Multi-Scale Air Quality model 

CO Carbon monoxide

COHA Causes of Haze Assessment 

dv Deciview; a measure of light extinction 

EC Elemental carbon

EDMS Emissions Data Management System 

EGAS Economic Growth Analysis System

EGU Electric generating unit 

EI Emissions Inventory

EIA Energy Information Administration 

FETS Fire Emissions Tracking System

FGR Flue gas recirculation 

FIP Federal Implementation Plan 

FLM Federal Land Manager 

Glidepath The linear rate of improvement sufficient to attain natural conditions by 2064 

HI Haze index

IMPROVE Interagency Monitoring of Protected Visual Environments 

IWG Implementation Work Group 

JARB1 IMPROVE monitoring site at Jarbidge Wilderness Area 

lb/MMBtu Pounds per million British thermal units 

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LNB Low NOX Burners 

LTS Long term strategy 

MACT Maximum Achievable Control Technology

Mm-1 Inverse mega meter; a measure of particle extinction 

MM5 Meteorological Mesoscale 5 

MW Megawatt

NAC Nevada Administrative Code

NDEP Nevada Division of Environmental Protection 

NEI National Emission Inventory

NH3 Ammonia 

NMHC Non-Methane Hydrocarbons

NOAA National Oceanic and Atmospheric Administration 

NO3 Ammonium nitrate or NH4NO3

NOx Nitrogen oxides 

NSR New source review 

NTEC National Tribal Environmental Council 

O3 Ozone 

OMC Organic matter carbon 

Plan02 2000 through 2004 typical baseline emissions 

PM Particulate matter

PNG Pipeline natural gas 

POA Primary organic aerosol 

ppm Parts per million 

PRP Preliminary Reasonable Progress 

PRP18 2018 Preliminary Reasonable Progress Emissions 

PSAT Particulate Matter Source Attribution Tracking 

PSD Prevention of significant deterioration

RHR Regional Haze Rule 

RMC WRAP’s Regional Modeling Center 

ROFA Rotating over fire air 

RPG Reasonable progress goal

RPO Regional Planning Organization 

RRF Relative Response Factors 

SCC Source Classification Code 

SIP State implementation plan

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SNCR Selective non-catalytic reduction 

SOA Secondary organic aerosols

SOIL Fine soil

SO2 Sulfur dioxide 

SO4 Ammonium Sulfate or (NH4)2SO4

SOx Sulfur oxides 

TSS Technical Support System 

TSSA Tagged Species Source Apportionment 

URP Uniform rate of progress 

USEPA United States Environmental Protection Agency 

VOC Volatile organic compound 

WA Wilderness Area

WEP Weighted emissions potential 

WESTAR Western States Air Resources Council 

WGA Western Governor’s Association 

WRAP Western Regional Air Partnership 

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List of Tables 

CHAPTER ONE 

Table 1-1 WRAP CAMx/PSAT Source Regions 

Table 1-2 WRAP CAMx/PSAT Emissions Source Groups 

CHAPTER TWO 

Table 2-1 Uniform Rate of Progress for the Jarbidge Wilderness Area 

Table 2-2 Monitored Contributions to Annual Reconstructed Extinction by Species for 

Baseline Period 

CHAPTER THREE 

Table 3-1 Summary of Pollutants, Source Categories, and Source Areas 

Table 3-2 Summary of Anthropogenic and Natural Emission Sources in Nevada 

Table 3-3 Summary of SO2 and NOx Emissions from Nevada Point Sources for the Baseline 

Period 

Table 3-4 Summary of SOx and NOx Emissions from Nevada Point Sources for 2018 

Table 3-5 Proposed 2018 EGUs and Current Permit Activity 

Table 3-6 Emissions Summary Table for Nevada for 2002 and 2018: Natural vs. 

Anthropogenic Sources 

Table 3-7 Nevada SOx Emissions by Source Category for 2002 and 2018 

Table 3-8 Nevada NOx Emissions by Source Category for 2002 and 2018 

Table 3-9 Nevada VOC Emissions by Source Category for 2002 and 2018 

Table 3-10 Nevada POA Emissions by Source Category for 2002 and 2018 

Table 3-11 Nevada EC Emissions by Source Category for 2002 and 2018 

Table 3-12 Nevada PM Fine Emissions by Source Category for 2002 and 2018 

Table 3-13 Nevada PM Coarse Emissions by Source Category for 2002 and 2018 

Table 3-14 Nevada NH3 Emissions by Source Category for 2002 and 2018 

Table 3-15 Predominant Sources for Pollutants: 2018 

CHAPTER FOUR 

Table 4-1 Summary of Model-Predicted Progress toward 2018 Uniform Rate of Progress 

Goal at JARB1 

Table 4-2 Summary of Model Predicted Progress toward Species-Specific 2018 Worst Days 

URP at JARB1 

Table 4-3 Nevada’s Sulfate Extinction Contribution to Class I Areas Outside of Nevada 

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

Table 4-5 Summary of 2018 Model Results for Jarbidge Wilderness Area 

Table 4-6 Change in Worst Days Modeled Concentrations of Sulfate and Nitrate 

CHAPTER FIVE 

Table 5-1 BART-Eligible Sources in Nevada 

Table 5-2 BART Exemption Modeling Results – Sources Subject to BART 

Table 5-3 BART Modeling Results – BART Exempt Sources 

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Table 5-4 Tracy BART Emissions Reductions in Tons per Year 

Table 5-5 Fort Churchill BART Emissions Reductions in Tons per Year 

Table 5-6 Reid Gardner BART Emissions Reductions in Tons per Year 

Table 5-7 Mohave BART Emissions Reductions in Tons per Year 

Table 5-8 Comparison of Exemption Modeling Emission Rates, NV Energy Modeled 

Emission Rates and BART Emission Limits 

Table 5-9 Tracy Pre-BART and Post-BART Control Modeled Visibility Results 

Table 5-10 Fort Churchill Pre-BART and Post-BART Control Modeled Visibility Results 

Table 5-11 Reid Gardner Pre-BART and Post-BART Control Modeled Visibility Results 

Table 5-12 Mohave Pre-BART and Post-BART Control Modeled Visibility Results 

CHAPTER SIX 

Table 6-1 Monitored Contributions to Average Annual Reconstructed Extinction for 

Baseline Period 

Table 6-2 Nonattainment Area Redesignation Status as of September 22, 2008 

Table 6-3 Summary of Model Predicted Progress toward 2018 Uniform Rate of Progress at 

JARB1 

Table 6-4 Large Natural Fires near the Jarbidge Wilderness Area 1999-2008 

CHAPTER SEVEN 

Table 7-1 Additional Annual Emissions Reductions in Tons Resulting from Implementation 

of BART in Nevada 

Table 7-2 Summary of Nevada Anthropogenic and Natural Emissions 

Table 7-3 Nevada’s Extinction Contribution and Emissions by Species 

Table 7-4 Nevada Emissions Source Contributions by Species 

Table 7-5 Summary of SO2 and NOx Emissions from Nevada Point Sources for 2018 

Table 7-6 Summary of Visibility Impairment at Nearby Class I Areas and Nevada’s 

Emissions Reductions 

Table 7-7 Baseline and Projected SO2 Inventories by State 

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List of Figures

CHAPTER ONE 

Figure 1-1 Location Map Showing Mandatory Class 1 Areas in the WRAP Region 

Figure 1-2 Location Map of Nevada and Portions of Adjacent States 

Figure 1-3 Extent of Pleistocene Lakes in the Great Basin 

Figure 1-4 Location Map of Snake River Plain 

Figure 1-5 Jarbidge Wilderness Area and Vicinity 

Figure 1-6 August 2008 Dust Event Near Mill City Nevada 

Figure 1-7 Source Area for Observed Dust Event 

Figure 1-8 August 2008 Convective Dust Event Near Mill City, Nevada 

Figure 1-9 Observed July 2008 Lake Tahoe Smoke Event 

Figure 1-10 September 2007 Regional Smoke Event Eastern Nevada 

Figure 1-11 Map of IMPROVE Monitoring Network in the United States 

Figure 1-12 Light Extinction-Haze Index-Visual Range Scale 

CHAPTER TWO 

Figure 2-1 Reference Vista of the Jarbidge Wilderness Area for Baseline Best Days 

Figure 2-2 Reference Vista of the Jarbidge Wilderness Area for Baseline Worst Days 

Figure 2-3 Reference Vista of the Jarbidge Wilderness Area for Natural Conditions Best 

Days 

Figure 2-4 Reference Vista of the Jarbidge Wilderness Area for Natural Conditions Worst 

Days 

Figure 2-5 Uniform Rate of Progress Glidepath for the Jarbidge Wilderness Area 

Figure 2-6 Annual Reconstructed Extinction for Worst Days of the Baseline Period 

Figure 2-7 Annual Reconstructed Extinction by Species for Worst Days of Baseline Period 

Figure 2-8 Monthly Distribution of Worst Days of Baseline Period 

Figure 2-9 Daily Reconstructed Light Extinction for Worst Days of Baseline Period 

Figure 2-10 Annual Reconstructed Extinction for Best Days of Baseline Period 

Figure 2-11 Annual Reconstructed Extinction by Species for Best Days of Baseline Period 

Figure 2-12 Monthly Distribution of Best Days of Baseline Period 

Figure 2-13 Daily Reconstructed Light Extinction for Best Days of Baseline Period 

Figure 2-14 Annual Reconstructed Extinction for IMPROVE Sample Days of Baseline Period 

Figure 2-15 Annual Reconstructed Extinction by Species for IMPROVE Sample Days of 

Baseline Period 

Figure 2-16 Monthly Reconstructed Extinction for IMPROVE Sample Days of Baseline 

Period 

Figure 2-17 Daily Reconstructed Extinction for IMPROVE Sample Days of Baseline Period 

Figure 2-18 Comparison of Baseline Extinction for Worst and Best Days of Baseline Period 

Figure 2-19 Annual IMPROVE Reconstructed Extinction Trends for Worst and Best Days 

Figure 2-20 Jarbidge Wilderness Area Speciated Extinction Trends for Worst Days 

CHAPTER THREE 

Figure 3-1 Percent Contribution by Source Category for SOx 

Figure 3-2 Percent Contribution by Source Category for NOx

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Figure 3-3 Percent Contribution by Source Category for VOC 

Figure 3-4 Percent Contribution by Source Category for POA 

Figure 3-5 Percent Contribution by Source Category for EC 

Figure 3-6 Percent Contribution by Source Category for PM Fine 

Figure 3-7 Percent Contribution by Source Category for PM Coarse 

Figure 3-8 Percent Contribution by Source Category for Ammonia 

Figure 3-9 Nevada SOx Emission Inventory – 2002 and 2018 

Figure 3-10 Regional Maps of SOx Emissions for 2002 and 2018 

Figure 3-11 Sulfur Oxide Emissions by County (Plan02d) and (PRP18a) 

Figure 3-12 Nevada NOX Emission Inventory – 2002 and 2018 

Figure 3-13 Regional Map of NOx Emissions for 2002 and 2018 

Figure 3-14 Nitrogen Oxide Emissions by County (Plan02d) and (PRP18a) 

Figure 3-15 Nevada VOC Emission Inventory – 2002 and 2018 

Figure 3-16 Volatile Organic Carbon Emissions by County (Plan02d) and (PRP18a) 

Figure 3-17 Nevada POA Emission Inventory – 2002 and 2018 

Figure 3-18 Regional Maps of POA Emissions for 2002 and 2018 

Figure 3-19 Primary Organic Aerosol Emissions by County (Plan02d) and (PRP18a) 

Figure 3-20 Nevada EC Emission Inventory – 2002 and 2018 

Figure 3-21 Regional Maps of EC Emissions for 2002 and 2018 

Figure 3-22 Elemental Carbon Emissions by County (Plan02d) and (PRP18a) 

Figure 3-23 Nevada Soil (PM Fine) Emission Inventory – 2002 and 2018 

Figure 3-24 Regional Maps of PM Fine Emissions for 2002 and 2018 

Figure 3-25 PM Fine Emissions by County (Plan02d) and (PRP18a) 

Figure 3-26 Nevada Coarse Mass (PM Coarse) Emission Inventory – 2002 and 2018 

Figure 3-27 Regional Maps of PM Coarse Emissions for 2002 and 2018 

Figure 3-28 PM Coarse Emissions by County (Plan02d) and (PRP18a) 

Figure 3-29 Nevada NH3 Emission Inventory – 2002 and 2018 

Figure 3-30 Ammonia Emissions by County (Plan02d) and (PRP18a) 

CHAPTER FOUR 

Figure 4-1 CMAQ Model Performance for JARB1 2002 Worst Days 

Figure 4-2 Relative Error of CMAQ Model Prediction versus IMPROVE Data for JARB1 

2002 Worst Days 

Figure 4-3 CMAQ Model Performance for JARB1 2002 Best Days 

Figure 4-4 Relative Error of CMAQ Model Prediction versus IMPROVE Data for JARB1 

2002 Best Days 

Figure 4-5 CMAQ Model Projections in Haze Index for JARB1 2018 Worst Days 

Figure 4-6 CMAQ Model Projections in Extinction by Species for JARB1 2018 Worst Days 

Figure 4-7 CMAQ Model Projections in Haze Index for JARB1 2018 Best Days 

Figure 4-8 Sulfate PSAT Source Region Bar Chart for Worst Days 2002 and 2018 

Figure 4-9 Sulfate PSAT Regional Pie Chart for Worst Days 2002 and 2018 

Figure 4-10 Sulfate PSAT Source Region Bar Chart for Best Days 2002 and 2018 

Figure 4-11 Sulfate PSAT Regional Pie Chart for Best Days 2002 and 2018 

Figure 4-12 Nitrate PSAT Source Region Bar Chart for Worst Days 2002 and 2018 

Figure 4-13 Nitrate PSAT Regional Pie Chart for Worst Days 2002 and 2018 

Figure 4-14 Nitrate PSAT Source Region Bar Chart for Best Days 2002 and 2018 

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Figure 4-15 Nitrate PSAT Regional Pie Chart for Best Days 2002 and 2018 

Figure 4-16 Sulfate PSAT Source Region Bar Chart for Best Days 2002 and 2018 at Sawtooth 

Wilderness Area 

Figure 4-17 Sulfate PSAT Source Region Bar Chart for Worst Days 2018 at Zion National 

Park 

Figure 4-18 Nitrate PSAT Source Region Bar Chart for Best Days 2002 and 2018 at Joshua 

Tree National Park 

Figure 4-19 Nitrate PSAT Source Region Bar Chart for Worst Days 2002 and 2018 at 

Desolation Wilderness Area 

Figure 4-20 Monthly Organic Aerosol PSAT Bar Chart for Worst Days 2002 and 2018 

Figure 4-21 Monthly Organic Aerosol PSAT Bar Chart for Best Days 2002 and 2018 

Figure 4-22 Organic Aerosol PSAT Bar Chart for all Days 2002 and 2018 

Figure 4-23 Regional NOx WEP for 2018 Worst Days 

Figure 4-24 Sources and Areas of Potential Haze-Causing NOx Emissions for JARB1 2002 

and 2018 Worst Days 

Figure 4-25 Regional SO2 WEP for 2018 Worst Days 

Figure 4-26 Sources and Areas of Potential Haze-Causing SO2 Emissions for JARB1 2002 

and 2018 Worst Days 

Figure 4-27 Regional Organic Carbon WEP for 2018 Worst Days 

Figure 4-28 Sources and Areas of Potential Haze-Causing Organic Carbon Emissions for 

JARB1 2002 and 2018 Worst Days 

Figure 4-29 Regional Elemental Carbon WEP for 2018 Worst Days 

Figure 4-30 Sources and Areas of Potential Haze-Causing Elemental Carbon Emissions for 

JARB1 2002 and 2018 Worst Days 

Figure 4-31 Regional Particulate Matter Fine WEP for 2018 Worst Days 

Figure 4-32 Sources and Areas of Potential Haze-Causing Particulate Matter Fine Emissions 

for JARB1 2002 and 2018 Worst Days 

Figure 4-33 Regional Particulate Matter Coarse WEP for 2018 Worst Days 

Figure 4-34 Sources and Areas of Potential Haze-Causing Particulate Matter Coarse 

Emissions for JARB1 2002 and 2018 Worst Days 

Figure 4-35 Nevada SO2 Plan02c and Base18b Emission Inventory Comparison 

Figure 4-36 Nevada SO2 Plan02d and PRP18a Emission Inventory Comparison 

Figure 4-37 Nevada NOx Plan02c and Base18b Emission Inventory Comparison 

Figure 4-38 Nevada NOx Plan02d and PRP18a Emission Inventory Comparison 

CHAPTER FIVE 

Figure 5-1 Location of Nevada’s BART Sources 

Figure 5-2 Cumulative Pre- and Post BART Emissions Calculated from WRAP Baseline 

Figure 5-3 Cumulative Pre-BART and Post-BART Emissions Calculated from NDEP 

Baseline 

CHAPTER SIX 

Figure 6-1 Uniform Rate of Progress Glidepath 

Figure 6-2 CMAQ Model Projected Extinction by Species for JARB1 2018 Worst Days 

Figure 6-3 Sulfate PSAT Source Region Bar Chart for Worst Days 2002 and 2018 

Figure 6-4 Nitrate PSAT Source Region Bar Chart for Worst Days 2002 and 2018 

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Figure 6-5 CMAQ Model Projections in Haze Index for JARB1 2018 Worst Days 

Figure 6-6 Species Time Series Extinction for Period of Record at the Jarbidge Wilderness 

Area 

Figure 6-7 2006 MODIS Fire Detections in California and Nevada 

Figure 6-8 2007 MODIS Fire Detections in California and Nevada 

Figure 6-9 2008 MODIS Fire Detections in California and Nevada 

CHAPTER SEVEN 

Figure 7-1 CMAQ 2018 Worst Days Model Projections for JARB1 Using Base 18b 

Emissions Inventory 

Figure 7-2 CMAQ 2018 Worst Days Model Projections for JARB1 Using RPR18a 

Emissions Inventory 

Figure 7-3 Weighted Emission Potential Analysis for Hells Canyon Wilderness Area 

Figure 7-4 Weighted Emission Potential Analysis for Sawtooth Wilderness Area 

Figure 7-5 Weighted Emission Potential Analysis for Desolation Wilderness Area 

Figure 7-6 Weighted Emission Potential Analysis for Hoover Wilderness Area 

Figure 7-7 Baseline and Projected SOx Emissions by State 

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