S TAT E O F N EVA D A jim Gibbons Governor 

ENVIRONMENTAL PROTECTION DlVlSlON OF ENVIRONMENTAL PROTECTION Leo M. Drozdoff; PE., Administrator 

protecting the future for 

September 15,2009 

Laura Yoshii 

Acting Regional Administrator 

ORA- 1, USEPA Region 9 

75 Hawthorne Street 

San Francisco CA 94 105 

Dear Ms. Yoshii: 

On behalf of Governor Gibbons, as his appointed designee, I am submitting two hard copies and 

one electronic copy of Nevada's fine particulate matter (PM2.5) infrastructure state 

implementation plan (SIP): CAA 11 O(a)(2)(A)-(M) Requirements in the Current Nevada State 

Implementation Plan for PM2,s (enclosure 1). This SIP is submitted pursuant to Clean Air Act 

(CAA) Sections 1 10 (a)(l) and (2) and addresses the infrastructure elements in the Nevada SIP 

for the 2006 PM2.5 NAAQS for all areas within NDEP's jurisdiction. We request approval of the 

PM2.5 infrastructure SIP into the applicable Nevada state implementation plan. 

In the absence of new guidance, Nevada followed EPA's October 2,2007 guidance in 

developing this SIP with the concurrence of EPA Region 9. Attachment A to EPA's 2007 

guidance lists the "Required Section 1 10 SIP Elements." NDEP has followed this list in its 

compilation of the state's 2006 PM2.5 infrastructure SIP, reproducing EPA's description of the 

required element in Enclosure 1 accompanied by a description of where in the Nevada SIP or 

other state authority the element is addressed. Copies of the regulatory and statutory elements 

of the current applicable Nevada SIP are enclosed for your reference (enclosures 2 and 3, 

respectively). 

NDEP notes that many of Nevada's current SIP regulatory provisions are seriously outdated and 

do not correspond to current state regulations, creating what EPA has referred to as the "SIP 

gap" (72 FR 71097). In February 2005, NDEP submitted a major SIP update with a revision in 

January 2006 and several supplemental submissions thereafter in response to EPA comments. 

On April 16,2008, EPA acted to disapprove the majority of Nevada's permitting program update 

(73 FR 20536). NDEP challenged EPA's action, and subsequently EPA and NDEP are in court 

supervised mediation to resolve the outstanding issues. NDEP contends that although the current 

Nevada applicable SIP satisfies all of the basic infrastructure requirements of CAA 110(a)(2), 

our PM2 5 SIP will better address the CAA requirements when NDEP's permitting program 

update is approved. 

90 1 S. Stewart Street, Suite 400 1 Carson City, Nevada 8970 1 p: 775.687.4670 f: 775.687.5856 www.ndep.nv.gov 

prrnted on recycled paper 
Page 2 

September 15,2009 

If you should have any questions about this submittal or require additional clarification, you may 

contact Michael Elges, Chief, Bureau of Air Quality Planning at (775) 687-9329. 

Enclosures 

cc: Robin Reedy, Chief of Staff, Office of the Governor 

Allen Biaggi, Director, DCNR 

Colleen Cripps, Deputy Administrator, NDEP 

Dennis Ransel, Planning Manager, Clark County DAQEM 

Andrew Goodrich, Director, Air Quality Management Division, Washoe County DHD 

Lisa Hanf, Chief, Planning Office, Air Division, EPA Region IX (AIR-2) 

Rory Mays, Planning Office, Air Division, EPA Region IX 

Certified Mail No. 7008 1 140 0004 403 1 2478