SUSANA MARTINEZ 

Governor 

JOHN A. SANCHEZ 

Lieutenant Governor 

October 7, 2013 

Mr. Ron Curry 

State of New Mexico 

ENVIRONMENT DEPARTMENT 

Office of the ~ec_re(ffry .. 

Harold Runnels Building 

1190 Saint Francis Drive, PO Box 5469 

Santa Fe, NM 87502-5469 

Telephone (505) 827-2855 Fax (505) 827-2836 

www.nmenv.state.nm.us 

Regional Administrator (6-A) 

U.S. Environmental Protection Agency, Region 6 

1445 Ross Avenue, Suite 1200 

Dallas, TX 75202-2733 

Dear Mr. Curry: 

RYAN FLYNN 

Cabinet Secretary· Designate 

BUTCH TON GATE 

Deputy Secretary 

CD 

On behalf of the New Mexico Environment Department, I am pleased to submit to the 

Environmental Protection Agency the enclosed revisions to the New Mexico State 

Implementation Plan (SIP). These revisions include amendments to New Mexico's Regional 

Haze SIP under 40 CFR § 51.309 and the interstate transport SIP good neighbor provisions under 

Section 110(a)(2)(D)(i)(II) of the Clean Air Act. Both of these revisions involve a multi-pollutant 

emission reduction strategy at Public Service Company of New Mexico's ("PNM") San Juan 

Generating Station. 

The hearing record for all of the SIP revisions is attached, which includes the revised SIPs, 

transcripts, exhibits, public notices, affidavits of publication, the notices of intent to present 

technical testimony, and public comments. 

The timing of this SIP submittal, as well as its substantive contents, are in accordance with the 

"Term Sheet Between the U.S. Environmental Protection Agency, Public Service Company of 

New Mexico and State of New Mexico," which was signed by those parties on February 15, 

2013 ("Term Sheet"). 

Please be aware that the Department anticipates the imminent reception of an application from 

PNM for a construction permit revision to implement certain provisions of these SIP revisions. 

The Department intends to submit to EPA the revised permit, for EPA's consideration in 

determining, in accordance with the schedule provided by the Term Sheet, whether the SIP 

submittal is complete. 
Mr. Ron Curry 

October 7, 2013 

Page 2 of2 

Included with the attached hardcopy of the hearing record is an electronic copy of the record 

provided on disk which I certify to be an exact duplicate of the hardcopy. 

If there are any questions concerning this SIP submittal, please contact Rita Bates, Air Quality 

Planning Section Chief, at (505) 476-4304. 

Sincerely, 

Ryan 

e~- Flynn 

Secretary-Designate 

Enclosures 

cc: Guy Donaldson, EPA Region 6 
1 

New Mexico Regional Haze State Implementation Plan Revisions

September 5, 2013

List of Enclosures:

Chapter 10, Section 309 Revised State Implementation Plan

Appendix D – Revised New Mexico BART Determination for San Juan Generating Station

NMED Notice of Intent to Present Technical Testimony – August 16, 2013

NMED Ex. 1 Clean Air Act § 169A and 169B

NMED Ex. 2 40 C.F.R. § 51.308

NMED Ex. 3 40 C.F.R. § 51.309 

NMED Ex. 4 BART Guidelines – Appendix Y to 40 C.F.R. Part 51 Published at 70 Fed. Reg. 39104

NMED Ex. 5 “Term Sheet” between U.S. EPA, NMED, and PNM

NMED Ex. 6 BART Analysis Addendum, PNM San Juan Generating Station, April 1, 2013

NMED Ex. 7 Affidavits of publication of public hearing notices

NMED Ex. 8 Public Comments Submitted by the U.S. Bureau of Land Management

NMED Ex. 9 Public Comments Submitted by the National Park Service

NMED Ex. 10 Testimony of Ted Schooley

NMED Ex. 10a Resume of Ted Schooley

NMED Ex. 11 Testimony of Elizabeth Bisbey-Kuehn

NMED Ex. 11a Resume of Elizabeth Bisbey-Kuehn

NMED Ex. 12 Testimony of Gi-Dong Kim

NMED Ex. 12a Resume of Gi-Dong Kim

NMED Ex. 13 Resume of Rita Bates

NMED Ex. 14 NMED responses to comments of the National Park Service

NMED Ex. 15 Proposed statement of reasons for adoption of regulatory changes

Public Service Company of New Mexico Notice of Intent to Present Technical Testimony – August 16, 2013 

NMED Notice of Publication of Hearing Notice and Public Review Drafts – July 2, 2013

Attachment 1 Chapter 10 Public Review Draft

Attachment 2 Appendix D Public Review Draft

Attachment 3 Redline/strikeout of Changes between NOI version and Public Review Draft of Chapter 10

Attachment 4 Redline/strikeout of Changes between NOI version and Public Review Draft of Appendix D

Public Comments Received by the New Mexico Environmental Improvement Board

EarthJustice/Western Environmental Law Center – September 3, 2013

Alex J. and Felicity B. Gonzales – August 19, 2013

EDL Consulting – August 23, 2013

Irvin & Norma Jean Jones – undated

Robert E. Reed – August 26, 2013

NMED Exhibit Presented at the September 5, 2013 Hearing

NMED Ex. 16 Corrections to Chapter 10 and Appendix D

Transcript of Hearing – September 5, 2013

New Mexico Environmental Improvement Board Statement of Reasons for Adoption of SIP Revisions