Chapter Six – Reasonable Progress for the Jarbidge Wilderness Area 

6.1 INTRODUCTION 

6.2 STEPS FOR DEVELOPING REASONABLE PROGRESS GOALS 

6.3 ESTABLISHING BASELINE AND NATURAL VISIBILITY 

CONDITIONS 

6.4 DETERMINING THE UNIFORM RATE OF PROGRESS 

6.5 IDENTIFYING THE MEASURES TO ACHIEVE THE UNIFORM RATE 

OF PROGRESS 

6.5.1 Key Pollutants and Sources of Impairment 

6.5.2 Emissions Reductions due to Existing Air Pollution Control Measures 

6.5.2.1 Federal Rules 

6.5.2.2 Consent Decrees 

6.5.2.3 Other Air Pollution Control Measures 

6.5.3 Resulting Improvement in Visibility 

6.6 ESTABLISHING REASONABLE PROGRESS FOR NEVADA 

6.7 DEMONSTRATION THAT THE RPG FOR WORST DAYS IS 

REASONABLE 

6.7.1 The Role of Natural Fire in Nevada 

6.8 REFERENCES 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-1 
6.1 INTRODUCTION 

The Regional Haze Rule (RHR) requires states to establish reasonable progress goals for each 

Class I area within the state (expressed in deciviews) that provide for reasonable progress 

towards achieving natural visibility conditions by 2064. 40 CFR 51.308(d)(1) USEPA also 

released guidance, Guidance for Setting Reasonable Progress Goals Under the Regional Haze 

Program, on June 7, 2007 for setting reasonable progress goals. The reasonable progress goals 

must provide for improvement in visibility for the most-impaired (20 percent worst) days over 

the period of the SIP and ensure no degradation in visibility for the least-impaired (20 percent 

best) days over the same time. The planning period for the initial regional haze SIP is 2004 

through 2018, with an interim review due five years after submittal of the initial implementation 

plan. 

Chapter Two identifies the uniform rate of progress (URP) for Nevada’s only Class I area, the 

Jarbidge Wilderness Area (Jarbidge WA). Nevada compared baseline visibility conditions to 

natural visibility conditions to determine the uniform rate of visibility improvement (in 

deciviews) that would need to be maintained during each implementation period in order to 

attain natural visibility conditions by 2064, as shown on Table 2-1 and Figure 2-5. 

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

Jarbidge WA resulting from existing federal and state regulations, including presumptive sulfur 

dioxide (SO2) Best Available Retrofit Technology (BART) limits for coal-fired electric 

generating units (EGU) with capacity greater than 750 MW. Visibility modeling indicates that 

implementation of existing rules coupled with installation of BART controls, as captured by the 

projected PRP18a emissions inventory, provides for an improvement in visibility better than the 

URP for the Jarbidge WA on the most-impaired days over the period of the SIP and identifies no 

degradation in visibility for the least-impaired days over the same period. 

The modeled 2018 extinction of 11.05 dv represents Nevada’s reasonable progress goal (RPG). 

Nevada’s long-term strategy to achieve this RPG is detailed in Chapter Seven. Given the 

significant emissions reductions anticipated from Nevada’s BART requirements and the 

implementation of other Clean Air Act (CAA) programs during this planning period, 

implementation of these programs represents reasonable progress in Nevada for the initial 

regional haze planning period. The resulting modeled visibility improvement is identified as 

Nevada’s 2018 RPG. 

The BART analyses conducted by Nevada were based, in part, on an assessment of many of the 

same factors addressed in establishing the RPG. The control requirements imposed by Nevada’s 

BART determinations also satisfy the RPG-related requirements for source review in the first 

planning period. Therefore, Nevada will not require additional emissions controls beyond BART 

for these sources during the first planning period. 

Nevada concludes, based on its assessment of the state’s significant emissions reductions in this 

first planning period, that it achieves reasonable progress toward the national visibility goal for 

this planning period. Furthermore, Nevada deems it is unreasonable at this time to request 

additional emission controls on Nevada sources beyond those discussed below due to the 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-2 
negative “...implication of compliance costs to the health and vitality of industries within ...”

Nevada (USEPA June 2007, p.5-1). It is reasonable for Nevada to defer additional reductions to 

later planning periods in order to maintain a consistent glidepath toward the long-term goal. Our 

assessment is consistent with guidance provided in sections 1.2, 4.1, and 5.0 of USEPA’s 

Guidance for Setting Reasonable Progress Goals under the Regional Haze Program.

6.2 STEPS FOR DEVELOPING REASONABLE PROGRESS GOALS

The steps in USEPA’s guidance for developing a RPG are listed below. 

1. Establish Baseline and Natural Visibility Conditions. 

2. Determine the Glidepath (or Uniform Rate of Progress). 

3. Identify and Analyze the Measures Aimed at Achieving the Uniform Rate of Progress: 

a. Identify the key pollutants and sources and/or source categories that are contributing 

to visibility impairment at each Class I area. 

b. Identify the control measures and associated emission reductions that are expected to 

result from compliance with existing rules and other available measures for the 

sources and source categories that contribute significantly to visibility impairment. 

c. Determine what additional control measures would be reasonable based on the 

statutory factors and other relevant factors for sources and/or source categories you 

have identified. 

d. Estimate the improvement in visibility that would result from implementation of the 

control measures you have found to be reasonable and compare this to the uniform

rate of progress. 

4. Establish a RPG. 

The following sections describe how Nevada’s regional haze SIP addresses each of the steps 

listed above and documents the technical basis of each component of the RPG. The discussion 

of Step3c, listed above, is deferred to Chapter Seven, which details Nevada’s long-term strategy. 

6.3 ESTABLISHING BASELINE AND NATURAL VISIBILITY CONDITIONS 

Chapter Two, sections 2.2 and 2.3, of this SIP discusses the methodologies employed to identify 

the baseline and natural visibility conditions for the Jarbidge WA. These data were used to 

determine the rate of progress needed to attain natural visibility conditions by the year 2064. 

6.4 DETERMINING THE UNIFORM RATE OF PROGRESS 

Chapter Two, section 2.4, of this SIP identifies the URP needed to attain natural visibility 

conditions for the Jarbidge WA. Nevada compared the baseline visibility conditions to natural 

visibility conditions to identify the uniform rate of visibility improvement that would need to be 

maintained during each implementation period in order to attain natural visibility conditions by 

2064. 

The URP or glidepath is shown on Figure 6-1, reproduced from Chapter Two. The baseline 

conditions for the 20 percent worst days are shown by the upper short line on Figure 6-1, while 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-3 
natural visibility conditions for the worst days are shown by the long horizontal line. The 

baseline visibility conditions for the 20 percent best days are shown by the short lower line. The 

diamonds represent the annual average visibility conditions for each of the baseline years for the 

worst and best days. The URP or glidepath is shown by the sloping line interrupted by open 

triangles identifying the URP in five-year increments. The 2018 URP for the Jarbidge WA is 

11.09 deciviews. 

FIGURE 6-1 

UNIFORM RATE OF PROGRESS GLIDEPATH

Uniform Rate of Reasonable Progress Glidepath

Jarbidge Wilderness Area - 20% Best and Worst Days

12.07 11.79 11.44 11.09 10.74 10.39 10.04 9.69 9.34 8.99 8.64 8.29 7.87

0

2

4

6

8

10

12

14

16

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haze Index (Deciview)

Baseline Obs 20% W 2000-2004 Baseline 20% W Glide Path

Baseline Obs 20% B 2000-2004 Baseline 20% B Natural Conditions S i 7 S i 8

2018 - End of 1st Planning Period

6.5 IDENTIFYING THE MEASURES TO ACHIEVE THE UNIFORM RATE OF 

PROGRESS 

40 CFR 51.308(d)(1)(i)(B) requires states to consider the uniform rate of progress and the 

emission reductions needed to achieve it for the period covered by the plan. The next step in 

setting the RPG is identifying and analyzing the measures aimed at achieving the URP, 

including: identifying the key visibility-impairing pollutants and their sources; identifying the 

existing control measures and the associated reductions; identifying reasonable additional control 

measures; and estimating the resulting visibility improvement, as discussed in the following 

sections. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-4 
6.5.1 Key Pollutants and Sources of Impairment 

The analyses of the Interagency Monitoring of Protected Visual Environments (IMPROVE) 

monitor data, as presented in Chapter Two, section 2.5, identify organic matter carbon (OMC) 

and coarse matter (CM) as the two most significant components of annual average visibility 

impairment at the Jarbidge Wilderness Area for the worst days of the baseline period. For the 

worst days, OMC and CM account for more than sixty percent of the average annual 

reconstructed extinction at JARB1. For these days, SO4 and NO3 account for less than a quarter 

of the extinction, as shown on Table 6-1, modified from Table 2-2. 

TABLE 6-1

MONITORED CONTRIBUTIONS TO AVERAGE ANNUAL 

RECONSTRUCTED EXTINCTION FOR BASELINE PERIOD

 OMC 

Extinction 

CM 

Extinction 

SO4

Extinction 

Soil 

Extinction 

EC 

Extinction 

NO3

Extinction 

Sea Salt

Extinction 

20% Worst Days 

Average 40.0% 22.3% 16.7% 9.7% 6.5% 4.5% 0.3%

20% Best Days 

Average 26.3% 9.2% 40.9% 2.8% 9.4% 9.8% 1.6%

Compilation and analyses of baseline (2002) and 2018 emissions inventories, presented in 

Chapter Three, demonstrate that nearly three quarters of Nevada’s total emissions originate from

natural (i.e., non-anthropogenic) sources, see Table 3-2. Sulfur oxides (SOx), nitrogen oxides 

(NOx), and ammonia (NH3) are the only pollutants whose 2018 emissions are dominated by 

anthropogenic sources, although both particulate matter fine (PMF) and particulate matter coarse 

(PMC) 2018 emissions are sub-equally divided between natural and anthropogenic sources. 

Note that the existing 2018 emission inventories do not include reductions resulting from the 

installation of BART, except for SOx presumptive limits for subject-to-BART EGU’s with 

capacity greater than 750 MW. 

Analyses of the projected 2018 emissions data have led to the following conclusions. 

• The majority of the emissions that form the monitored species OMC, volatile organic 

compounds (VOC) and primary organic aerosol (POA) emissions, are from biogenic (88 

percent) and natural fire (91 percent) sources, respectively. 

• Emissions of PMC are predominantly from windblown dust (50 percent) and fugitive 

dust (36 percent) sources. 

• Point sources account for the majority (61 percent) of emissions of SOx, a component of 

monitored species SO4. 

• Emissions of PMF are predominantly windblown dust (43 percent) and fugitive dust (30 

percent) sources. 

• Emissions of elemental carbon (EC) are dominated by natural fire (83 percent). 

• Point sources account for the majority (50 percent) of NOx emissions, a component of 

monitored species NO3; although mobile sources are also a significant (27 percent) 

contributor. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-5 
Visibility modeling projections, shown in Figure 6-2, indicate the relative contribution to 2018 

visibility impairment at the Jarbidge WA for each visibility impairing species in units of inverse 

megameters (Mm-1). This graph shows an extinction reduction for each species by the end of the 

first planning period, except Sea Salt and CM. CM emissions were held constant from the 

baseline to 2018 and Sea Salt is not an importance component of extinction at JARB1. As noted 

above, VOC and POA, and CM emissions leading to OMC (shown by the green line on Figure 6-

2) and CM (shown by gray line) extinction respectively, are dominated by natural sources. 

FIGURE 6-2 

CMAQ MODEL PROJECTED EXTINCTION 

BY SPECIES FOR JARB1 2018 WORST DAYS

The SO4 and NO3 source apportionment modeling identifies the relative concentration due to 

SOx and NOx emissions by source area and source category, as shown in Figures 6-3 and 6-4, 

respectively. Figure 6-3 shows the dominating effect of uncontrollable emissions from outside 

the modeling domain (right side of the x axis) on SO4 concentrations at the Jarbidge WA. 

Outside Domain contributions are four times greater than any other source category. SOx

emissions from the Pacific Offshore source category (PO on x axis of graph) are also a 

significant contributor to SO4 concentrations at JARB1. Emissions from three other states, 

Idaho, Oregon, and Washington, have larger contributions to the SO4 concentration than does 

Nevada for both 2002 and 2018. 

Figure 6-4 shows the largest contributor to NO3 concentrations at the Jarbidge WA is NOx

emissions from Idaho, closely followed by the uncontrollable emissions from outside the 

modeling domain. Idaho’s NOx contribution to baseline NO3 formation is largely due to mobile 

and area sources, with a large increase in the importance of area source emissions for 2018. 

Emissions from Utah have a larger contribution to NO3 concentration than does Nevada for 

2002, but slightly less than Nevada for 2018 due to mobile source emissions reductions. Note 

the significant reduction in 2018 concentrations due to reductions in mobile source emissions 

from all states. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-6 
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

6.5.2 Emissions Reductions due to Existing Air Pollution Control Measures 

The RHR requires states to submit a long-term strategy that includes such measures as are 

necessary to achieve the RPG for each Class I area. RPGs are interim goals that represent 

incremental improvement over time toward the goal of natural background conditions. Prior to 

developing a long-term strategy, existing control measures must be assessed. As stated in 

USEPA guidance (June 2007): 

“One important factor to keep in mind when establishing a RPG is that you cannot 

adopt a RPG that represents less visibility improvement than is expected to result 

from the implementation of other CAA requirements. You must therefore determine 

the amount of emissions reductions that can be expected from identified sources or 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-7 
source categories as a result of requirements at the local, State, and federal levels 

during the planning period of the SIP and the resulting improvements in visibility at 

Class I areas. Given the significant emissions reductions that we anticipate to result 

from BART, the CAIR, and the implementation of other CAA programs, including 

ozone and PM2.5 NAAQS, for many States this will be an important first step in 

determining your RPG, and it may be all that is necessary to achieve reasonable 

progress in the first planning period for some States.” (p. 4-1) emphasis added 

There are significant control programs being implemented between the baseline period and 2018, 

on the federal, state and local levels. Emissions reductions from “on-the-way” and “on-thebooks” control programs and the implementation of BART, as captured in the PRP18a emission 

inventory, are projected to achieve substantial visibility improvement by 2018 at the Jarbidge 

WA and other Class I areas in the west. In fact, the Jarbidge WA represents the only western 

Class I area where the RPG meets or exceeds the URP for 2018. In general, these programs

consist of regulations affecting mobile source emissions and, to a lesser degree, stationary 

sources. The following sections describe emissions control programs considered in developing 

the 2018 emissions inventory PRP18a based on control measures that are expected to result from 

compliance with existing rules and other available measures. 

6.5.2.1 Federal Rules 

Emissions reductions due to the following federal pollution control programs were incorporated 

into the PRP18a emissions inventory. These programs affect mobile, point and area source 

emissions. 

Heavy Duty Diesel (2007) Engine Standard (On-road trucks and buses) 

The USEPA set a PM emissions standard for new heavy-duty engines of 0.01 grams per brakehorsepower-hour (g/bhp-hr), to take full effect for diesel engines in the 2007 model year. This 

rule also included standards for NOx and non-methane hydrocarbons (NMHC) of 0.20 g/bhp-hr 

and 0.14 g/bhp-hr, respectively. These NOx and NMHC standards will be phased in together 

between 2007 and 2010 for diesel engines. Sulfur in diesel fuel must be lowered to enable 

modern pollution control technology to be effective on these trucks and buses. Pursuant to 

USEPA rule, a 97 percent reduction in the sulfur content of highway diesel fuel from 500 ppm

(low sulfur diesel) to 15 ppm (ultra-low sulfur diesel) became effective in Nevada in October 

2006. 

Tier 2 Tailpipe (On-road vehicles) 

The USEPA mobile source rules include the Tier 2 fleet averaging program, modeled after the 

California Low Emission Vehicle II standards. Manufacturers can produce vehicles with 

emissions ranging from relatively dirty to zero emissions, but the mix of vehicles a manufacturer 

sells each year must have average NOx emissions below a specified value. Tier 2 standards 

became effective in the 2005 model year. 

Large Spark Ignition and Recreational Vehicle Rule 

The USEPA has adopted new standards for emissions of NOx, hydrocarbons and carbon 

monoxide from several groups of previously unregulated non-road engines. Included in these are 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-8 
large industrial spark-ignition engines and recreational vehicles. Non-road spark-ignition 

engines are those powered by gasoline, liquid propane gas or compressed natural gas rated over 

19 kilowatts (25 horsepower). These engines are used in commercial and industrial applications, 

included forklifts, electric generators, airport baggage transport vehicles, and a variety of farm

and construction applications. Non-road recreational vehicles include snowmobiles, off-highway 

motorcycles and all-terrain-vehicles. These rules were initially effective in 2004 and will be 

fully phased in by 2012. 

Non-road Diesel Rule 

This rule sets standards that will reduce emissions by more than 90 percent from non-road diesel 

equipment and reduce sulfur levels by 99 percent from current levels in non-road diesel fuel 

starting in 2007. This step will apply to most non-road diesel fuel in 2010 and to fuel used in 

locomotives and marine vessels in 2012. 

Industrial Boiler/Process Heater MACTs 

The USEPA issued final rules to substantially reduce emissions of toxic air pollutants from

industrial, commercial, and institutional boilers and process heaters. These rules reduce 

emissions of a number of toxic air pollutants, including hydrogen chloride, manganese, lead, 

arsenic and mercury by 2009. This rule also reduces emissions of SO2 and PM in conjunction 

with the toxic air pollutant reductions. The applied Maximum Achievable Control Technology 

(MACT) control efficiencies were 4 percent for SO2 and 40 percent for PM10 and PM2.5. The 

USEPA’s industrial boiler MACT rules were vacated on June 8, 2007. WRAP states decided to 

leave these controls in the modeling since it is believed that by 2018 the USEPA will have repromulgated a boiler MACT rule or states will have addressed the issue through rulemaking. 

Combustion Turbine and Reciprocating Internal Combustion Engines MACT 

The projection inventories do not include the NOx co-benefit of the MACT regulations for Gas 

Turbines or Stationary Reciprocating Internal Combustion Engines, which the USEPA estimates 

to be small compared to the overall inventory. 

VOC 2-, 4-, 7- and 10-year MACT Standards 

Various point source MACTs and associated emission reductions were implemented. 

Reductions occurring before 2002 were assumed to be accounted for in the 2002 base year 

inventory. 

6.5.2.2 Consent Agreements 

The following section describes consent agreements for the Mohave Generating Station 

(Mohave) and Reid Gardner Generating Station (Reid Gardner). Mohave is owned by Southern 

California Edison (SCE) and is located in Laughlin, Nevada. Reid Gardner is owned by NV 

Energy (formerly Nevada Power Company) and is located near Moapa, Nevada. Both facilities 

are located in Clark Country and permitted through NDEP. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-9 
Mohave Generating Station1

On February 8, 2002, USEPA promulgated a final rule revising Nevada’s federal implementation 

plan for protection of visibility in Class I areas (visibility FIP; 40 CFR 52.1488). That revision 

concerned emissions reduction requirements for Mohave. The requirements were based on a 

consent decree between the owners of Mohave and the Grand Canyon Trust, the Sierra Club and 

the National Parks and Conservation Association, addressing issues raised by the U.S. 

Department of the Interior (DOI) regarding Mohave’s contribution to visibility impairment at the 

Grand Canyon National Park (GCNP) from SO2 emissions. In addition, by incorporating the 

requirements of the consent decree into the long-term strategy of the Nevada visibility FIP, 

USEPA argued that there would be allowance for reasonable progress toward the national 

visibility goal with respect to Mohave’s contribution to visibility impairment at GCNP from SO2

emissions according to the criteria set forth in Section 169A(g)(1) of the CAA. 

This rule was USEPA’s first report assessing the long-term visibility strategy for Nevada since 

promulgating the Nevada visibility FIP. USEPA reviewed the long-term strategy only for the 

purpose of addressing DOI’s certification of existing visibility impairment at GCNP and 

Mohave’s contribution to that impairment, and evaluating whether the terms of the Mohave 

consent decree would make reasonable progress toward the national visibility goal. The revision 

of the long term strategy of the Nevada visibility FIP was to allow for reasonable progress 

toward the CAA national visibility goal with respect to Mohave’s contribution to visibility 

impairment at GCNP due to SO2 emissions. USEPA did not conduct a comprehensive review of 

the long-term strategy of the Nevada visibility FIP at that time. According to the Federal Register

notice (67 FR 6130), federal land managers did not provide any information for such a review 

and USEPA did not have any evidence that visibility impairment at any other Class I area could 

be attributed to a specific source or group of sources located in Nevada. USEPA reasoned that 

the regional haze rule would result in a regional strategy for western states and would provide for 

additional progress toward the national visibility goal. The National Park Service did review the 

consent decree and believed that a USEPA rulemaking which adopts the emission limits and 

other requirements from the decree was an appropriate means of addressing its concerns 

regarding the impact of SO2 emissions from Mohave on visibility impairment at GCNP. 

The requirements of the visibility FIP were included as an applicable requirement in the schedule 

of compliance section of Mohave’s Title V operating permit: 

Interim Emission Limits - For the period of time between the entry of the decree (December 

15, 1999) and the date on which each unit must commence compliance with the final 

emission limitations set forth in Section VI.A.2.b of the Operating Permit, the following SO2

and opacity emission limits shall apply: 

a. SO2 emissions shall not exceed 1.0 lb/MMBtu of heat input calculated on a 90 boiler 

operating day rolling average basis for each unit. 

 1 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 6-10 
b. The opacity of emissions shall be no more than 30 percent, as averaged over each 

separate 6-minute period within an hour, beginning each hour on the hour, measured at 

the stack, with no more than 375 exceedances of 30 percent allowed per calendar quarter 

(including any pro rated portion thereof), regardless of reason. 

The consent decree required installation of low NOx burners with over-fire air and fabric filter 

dust collection devices, but no associated emission limitations for either NOx or PM/PM10; 

however, opacity was limited to 20 percent. The consent decree required the controls to be 

installed and operational by January 1, 2006 or the plant would need to cease operations. The 

plant has been in a period of temporary shutdown since January 1, 2006. 

However, Mohave has maintained their operating permit during this period in anticipation of 

restarting or selling the facility, and SCE has submitted a BART analysis, discussed in Chapter 

Five, as Mohave is subject to BART under the RHR as an EGU with capacity greater than 750 

MW. As such, the PRP18a emission inventory incorporated the presumptive BART SO2 limit. 

The PRP18a inventory has projected SO2 and NOx emissions from Mohave of 8,701 tpy and 

19,595 tpy, respectively. Mohave emissions represent 19 percent of projected 2018 (18PRPa) 

statewide SO2 emissions and 14 percent of projected statewide NOx emissions. 

However, SCE’s BART analysis proposes fuel switching from coal to natural gas. Fuel 

switching will result in significant emissions reductions of SO2 and NOx with a greater than 95 

percent reduction in SO2 emissions from the PRP18a projections and a 75 percent reduction in 

NOx emissions from the PRP18a projections. The BART emissions limits required by this SIP 

will be incorporated in future Western Regional Air Partnership (WRAP) visibility modeling and 

are anticipated to reduce visibility impairment at Class I areas. SCE’s BART analysis is 

discussed in Chapter Five, where a link is provided to the complete analysis. 

Reid Gardner Generating Station

The recent action at Reid Gardner was not related to any visibility impairment certification. 

Rather, the order issued by NDEP and the consent decree issued by USEPA in cooperation with 

NDEP and Reid Gardner were related to compliance issues at the station, specifically, record 

keeping and opacity exceedances. Nevertheless, some of the reductions ordered at Reid Gardner 

may result in visibility improvements. 

In a letter and order, dated April 3, 2007, NDEP required Nevada Power Company (now NV 

Energy) to install natural gas igniters on units 1 through 4 at Reid Gardner no later than July 1, 

2009, and install baghouses on units 1 through 3 Reid Gardner no later than July 1, 2010. These 

requirements were also found in the Reid Gardner consent decree entered into by Nevada Power 

Company, NDEP and the USEPA on April 3, 2007 and approved by the United States District 

Court on June 14, 2007. The consent decree further imposed SO2 limitations beginning on the 

effective date of the decree: Measured separately, units 1, 2 and 3 shall not have SO2 emissions 

in excess of 0.40 lb/MMBtu, based on a 10-day rolling average period. 

Installation of the mandated emissions controls will have the effect of reducing projected 2018 

(18PRPa) SO2 emissions by 11 percent or 219 tpy and NOx emissions by 17 percent or 1822 tpy 

from the Plan02d inventory. Reid Gardner is also subject to BART under the RHR. Proposed 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-11 
BART controls for Reid Gardner will result in a 60 percent reduction in NOx emissions from

those projected in the PRP18a emissions inventory but a 30 percent increase in SO2 emissions 

from the PRP18a inventory, resulting in an overall reduction of nearly 5,000 tpy of NOx/SOx

combined. The BART analysis is discussed in Chapter Five where a link is provided to NV 

Energy’s BART report. The BART emissions limits required by this SIP will be incorporated in 

future WRAP visibility modeling and are anticipated to reduce visibility impairment at Class I 

areas. 

6.5.2.3 Other Air Pollution Control Measures 

Additional air pollution control measures were incorporated in the PRP18a emissions inventory 

to account for emissions reductions due to all on-the-way or on-the-books control programs. 

Some of these programs are specific to Nevada, while others have broader application in the 

WRAP states. These programs are identified below: 

• Emissions reductions resulting from smoke management programs were accounted for by 

applying emissions reduction techniques to the 2000 to 2004 average fire emissions. 

• Emissions reductions resulting from state oil and gas emissions control programs for Rocky 

Mountain States. 

• Emissions reductions resulting from the installation of known BART for facilities in 

Colorado, Utah, North Dakota and one facility in Oregon. 

• Application of presumptive SO2 BART limits for EGU’s with capacity greater than 750 MW

across the WRAP region. 

• Emissions reductions resulting from ozone and PM10 SIPs in place across the WRAP region. 

Nevada’s ozone and PM10 SIPs are discussed below. 

In 2000, Nevada had several nonattainment area SIPs in place. These SIPs are effective in 

Washoe and Clark Counties, the locations of Reno and Las Vegas, respectively. In NDEP’s 

jurisdiction, the only nonattainment area was the Central Steptoe Valley, which was out of 

attainment for SO2 because of emissions from a copper smelter. This area was designated 

attainment in 2002. Table 6-2 shows the designation status for Nevada’s nonattainment areas. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-12 
TABLE 6-2

 

NONATTAINMENT AREA 

REDESIGNATION STATUS AS OF SEPTEMBER 2008

Planning Area Nonattainment Date Redesignations 

Carbon Monoxide 

Lake Tahoe Basin (HA90) 3/3/78 USEPA approved 12/15/03; 

effective 2/13/04 

Las Vegas Valley (HA212) 3/3/78 and 11/15/90 Request submitted 9/18/08 

Truckee Meadows (Reno) (HA87) 3/3/78 and 11/15/90 USEPA approved 7/3/08 

Ozone 

Washoe County 1/6/92 (1 hr) 

1/16/01 (1 hr) 

6/15/05 1 hr NAAQS revoked; 

Maintenance plan approved 

1/18/08; effective 3/18/08 

Clark County 9/13/2004 (8 hr) 

PM10

Las Vegas Valley (HA212) 11/15/90 

Pahrump Valley2 (HA162) does not apply MOU Sept 2003 

Truckee Meadows (Reno) (HA87) 11/15/90 

SO2

Central Steptoe Valley (HA179M) 3/3/78 USEPA approved 4/12/02; 

effective 6/11/02 

Clark County 

Clark County has PM10 and carbon monoxide (CO) SIPs. For many years, the Las Vegas Valley 

severely violated air quality standards for PM10 airborne particulate matter. Fugitive dust 

contributed substantially to this problem, but there were thousands of PM10 sources spanning an 

area of over 300,000 acres. In an unprecedented strategy, Clark County adopted fugitive dust 

rules more stringent than any prior program in the country and employed a team of 28 field 

compliance officers dedicated to enforce fugitive dust regulations. To make its approach 

effective, the program targeted large construction sites and conducted an extensive public 

outreach campaign to educate owners of large expanses of vacant residential land. The 

department also funded new research in PM10 paved-road and vacant-land emissions, which 

provides new techniques with greater accuracy for estimating emissions. Clark County’s 

advanced dust control program serves as a national model and has been integral in leading the 

Las Vegas Valley to achieve PM10 concentrations below the USEPA’s standard. In the June 

2007 Milestone Achievement Report, Clark County demonstrated achievement of the 24-hour 

PM10 National Ambient Air Quality Standards (NAAQS) and continued attainment of the annual 

PM10 standard. CO control strategies include cleaner burning gasoline, transportation control 

measures, the state Alternative Fueled Vehicle program and woodstove and fireplace regulations. 

 2

 Pahrump Valley is not a designated nonattainment area. A Memorandum of Understanding is in place, which 

defers a nonattainment designation, to accelerate attainment of the PM10 national ambient air quality standards. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-13 
Washoe County 

Washoe County or the Truckee Meadows Hydrographic Area (HA 87) has SIPs for ozone, CO 

and PM10. Control measures focus on off-road and on-road vehicles, oxygenated fuel, gasoline 

vapor recovery, transportation control measures, residential wood burning and dust control 

measures such as the street sweeping program. 

This section summarized the significant federal, state, and local control programs that are being 

implemented between the baseline period and 2018. These control program focus primarily on 

mobile (both on- and off-road) emissions sources and to a lesser degree area and stationary 

source emissions. Emissions projections based on implementation of all the described programs 

have been incorporated into the preliminary reasonable progress emissions inventory (PRP18a). 

The emission inventory will be updated in late 2008 or 2009 to incorporate BART emissions 

estimates for further visibility modeling. 

6.5.3 Resulting Improvement in Visibility

Utilizing WRAP Regional Modeling Center modeling results, Nevada has estimated the expected 

visibility improvements by 2018 at the Jarbidge WA resulting from the implementation of 

existing federal and state regulations discussed above. Figure 6-5 shows the URP glide slope 

with a modeled 2018 visibility projection of 11.05 dv, although the value in Figure 6-5 has been 

rounded to one decimal place. 

6.6 ESTABLISHING REASONABLE PROGRESS FOR NEVADA 

WRAP baseline modeling demonstrates that the 2018 preliminary reasonable progress scenario 

(PRP18a) provides for an improvement in visibility better than the uniform rate of progress at the 

Jarbidge WA for the most impaired days over the period of the implementation plan, and ensures 

no degradation in visibility for the least impaired days over the same period (see Figure 6-5 and 

Table 6-3). The improvement is the result of the emissions reductions from existing and planned 

emissions controls due to federal and state programs (i.e., on-the-way and on-the-books), as 

discussed in Chapter Three. 

For the 20 percent worst days, the reasonable progress goal for Jarbidge provides for greater 

visibility improvement by 2018 than the area’s uniform rate of progress, as shown on Table 6-3. 

For the 20 percent best days, the reasonable progress goal for Jarbidge indicates an improvement 

of visibility by 2018 greater than current best day conditions. These projections are based on the 

modeling results discussed in Chapter Four. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-14 
FIGURE 6-5 

CMAQ MODEL PROJECTIONS IN HAZE INDEX 

FOR JARB1 2018 WORST DAYS

Identification of the 2018 reasonable progress goal for Jarbidge is a required element of 

Nevada’s regional haze SIP. Nevada’s reasonable progress goal for the Jarbidge WA is 11.05 dv 

for the 2018 worst days and 2.50 dv for the 2018 best days, as shown in Table 6-3. 

TABLE 6-3

SUMMARY OF MODEL PREDICTED PROGRESS 

TOWARD 2018 UNIFORM RATE OF PROGRESS AT JARB1

20% Worst Days 20% Best Days 

Mandatory

Class I 

Federal 

Area 

Worst 

Days

Baseline 

(Deciview) 

2018 URP 

(Deciview) 

RPG 2018

Modeling 

Results 

(Deciview) 

CMAQ 

Modeling 

Percent 

Toward 

2018

URP 

Best Days 

Baseline 

(Deciview) 

2018

Modeling 

Results 

(Deciview) 

CMAQ 

2018

Modeling 

Result 

Less Than 

Baseline?

Jarbidge

Wilderness

Area 

12.07 11.09 11.05 104.1% 2.56 2.50 Yes

The background and results of the monitoring, emissions and modeling analyses are discussed in 

Chapters Two, Three, and Four of this SIP and provide the technical basis for the establishment 

of Nevada’s reasonable progress. Nevada has utilized the technical analyses developed by the 

WRAP to comply with USEPA’s guidance for developing its RPG. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-15 
6.7 DEMONSTRATION THAT THE RPG FOR WORST DAYS IS REASONABLE

USEPA guidance (June 2007) indicates, “. . . States may establish a RPG that provides for 

greater, lesser, or equivalent visibility improvement as that described by the glidepath,” (p. 1-3) 

and goes on to state, “It is reasonable for you to defer reductions to later planning periods in 

order to maintain a consistent glidepath toward the long-term goal.” (p. 1-4) It further states: 

“After determining the amount of emissions reductions of visibility impairing 

pollutants that may be expected from implementation of other CAA programs, you 

will be ready to identify any additional measures that are reasonable (emphasis 

added). The RHR gives States wide latitude to determine additional control 

requirements, and there are many ways to approach identifying additional reasonable 

measures; however, you must, at a minimum, consider the four statutory factors. 

Based on the contribution from certain source categories and the magnitude of their 

emissions you may determine that little additional analysis is required to determine 

further controls are not warranted for this category.”(p. 4-2) emphasis added

The 2018 RPG identified in Table 6-3 for the 20 percent worst days show an improvement in 

visibility better than the 2018 URP. For this reason, in conjunction with other evidence and 

documentation described below and the fact that Nevada is meeting its share of emissions 

reductions at Class I areas outside of the state (see section 7.9.3.2), Nevada maintains its RPGs 

are reasonable. The following factors support this conclusion: 

1. The 2018 RPG shows better progress than the 2018 URP. As shown in Table 6-3, 

Nevada’s 2018 RPG shows better visibility improvement that the 2018 URP for the worst 

days and ensures no visibility degradation for the least impaired days of 2018. Therefore, 

it is reasonable to defer additional emissions reductions to later planning periods in order 

to maintain a consistent glidepath toward the long-term goal. 

2. Reductions in anthropogenic emissions consistent with 2018 URP are reasonable. 

Meeting the 2018 URP at the Jarbidge WA requires an 8.1 percent reduction in the haze 

index expressed in deciviews. The PRP18a emission inventory shows a 33 percent 

reduction of SOx emissions and a 17 percent reduction of NOx emissions when compared 

to the Plan02d inventory. When the installation of BART controls on Nevada sources is 

taken into account, the reductions increase to 44 percent for SOx and nearly 33 percent 

for NOx from the Plan02d inventory. The WEP emissions projections show a 14.5 

percent reduction for NOx, but a 16.8 percent increase in SOx by 2018. The SOx increase 

is due partly to the siting of a proposed coal-fired EGU in eastern Nevada, as well as the 

significant SOx emissions reductions from mobile and point sources in Idaho, which 

increase the relative contribution of Nevada emissions. This combination of emissions 

reductions from anthropogenic sources consistent with the required reduction in haze 

index supports the demonstration of reasonable progress. 

3. Reductions in anthropogenic emissions are consistent with Nevada’s share of emissions 

reductions to meet RPGs of Class I areas in other states. Analyses of the relationships 

between Nevada’s SOx and NOx emissions, source apportionment modeling, and 

visibility impairment at Class I areas in adjacent states indicates Nevada’s emissions 

reductions by 2018 represent Nevada’s share of the emissions reductions necessary for 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-16 
these Class I areas to achieve reasonable progress. The analyses are presented in section 

7.9.3.2 of Chapter Seven. 

4. Major reductions in mobile source emissions. Mobile sources, both on- and off-road, are 

significant emitters of NOx and to a lesser degree SOx. These source categories show a 

considerable reduction in emissions by 2018, a 63 percent reduction in SOx and 49 

percent reduction in NOx from 2002 levels. Although these reductions are primarily due 

to “on-the-books” federal regulations, the emissions reductions are consistent with and 

support Nevada’s demonstration of reasonable progress. 

5. Offshore marine shipping and international emissions contribute significantly to visibility 

impairment. Source apportionment modeling (section 4.3 of Chapter Four) identifies the 

significant contribution of international and off-shore marine emissions (e.g., source 

categories Outside Domain, Canada, Mexico, and Pacific Offshore) to visibility 

impairment at the Jarbidge WA. These source categories are major contributors to SO4

and NO3 extinction as shown by the source apportionment modeling results with outside 

domain, Mexican, and Canadian emissions representing 51 percent of the SO4 visibility 

impact and 30 percent of the NO3 impact at JARB1. Control of international and offshore sources will likely account for greater improvement in the SO4 and NO3 extinction 

contribution at the Jarbidge WA. Although USEPA has recently addressed off-shore 

emissions by the Marine Diesel Engine Rule (see section 7.9.2.3 of Chapter Seven), no 

United States regulatory body has authority to control international emissions. 

6. Natural sources contribute significantly to visibility impairment. Nevada’s analyses of 

the monitoring, emissions and modeling data (Chapters Two, Three, and Four) strongly 

support the finding that the contribution of natural and uncontrollable emissions sources, 

such as natural fire and windblown dust, and the pollutants associated with these sources 

(OMC, EC, PMC and PMF), contribute significantly to visibility impairment. The 2018 

emission inventory shows increased emissions of these pollutants, except EC, while the 

emissions of SOx and NOx decrease significantly. The role of natural fire is discussed 

below. 

7. Consideration of the costs of compliance, time necessary for compliance, the energy and 

non-air quality environmental impacts of compliance, and remaining useful life of 

existing sources that contribute to visibility impairment. In light of the 6 factors listed 

above, it is Nevada’s position that the costs of any additional control measures beyond 

those documented in this chapter and Chapter Seven are unreasonable at this time and 

would impose unnecessary burdens on the health and vitality of industries within our 

state. Since the costs of compliance are unreasonable, no further analysis of these four 

factors was conducted. 

6.7.1 The Role of Natural Fire in Nevada 

The role of natural fire contributions to visibility impairment at the Jarbidge WA is undeniable as 

shown in Figure 6-6, which displays time lines for each visibility impairing species from 1988 to 

2006 for all IMPROVE sample days. As noted previously, annual visibility impairment due to 

OMC emissions from natural fires are highly variable from year to year. Some of the monitored 

visibility impairment is due to local natural fires, but regional transport of smoke is common, as 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-17 
2002 demonstrates when large timber fires in Arizona, Colorado and Oregon contributed to 

elevated OMC extinction at the Jarbidge WA. 

The natural fire data presented in Table 6-4 show significant burned acreage in proximity to the 

Jarbidge WA for 1999, 2006 and 2007. These data were downloaded from the National 

Interagency Fire Center (http://www.nifc.gov/fire_info/fire_stats.htm) list of 1997-2007 fires 

greater than 100,000 acres and year-to-date fires for 2008. Only data for fires in northeastern 

Nevada and southern Idaho within approximately 100 miles of the Jarbidge WA were compiled. 

Comparison of Figure 6-6 and Table 6-4 demonstrates the correlation of large fires and visibility 

impairment at the Jarbidge WA for 1999 and 2006. No fires in excess of 100,000 acres were 

recorded in Nevada from 2000 to 2005. 

FIGURE 6-6 

SPECIES TIME SERIES EXTINCTION FOR PERIOD OF RECORD 

AT THE JARBIDGE WILDERNESS AREA

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-18 
TABLE 6-4

LARGE NATURAL FIRES NEAR THE JARBIDGE WILDERNESS AREA 1999 - 2008

Year Fire Name State Acreage 

1999 Dun Glen Complex Nevada 288,220 

1999 Sadler Complex Nevada 224,509 

1999 Battle Mountain Complex Nevada 169,608

1999 Jungo Complex Nevada 169,220

1999 Acreage 851,557 

2006 Winters Nevada 238,458

2006 Charleston Complex Nevada 190,421

2006 Sheep Nevada 150,270

2006 Acreage 579,149 

2007 Murphy Complex Idaho 652,016

2007 Acreage 652,016 

2008 East Slide Rock Ridge Nevada 54,549 

2008 Acreage 54,549 

Figures 6-7 through 6-9, show MODIS fire detections for 2006, 2007 and 2008 in California and 

Nevada and their proximity to the Jarbidge WA. The yellow depicts areas burned since January 

1st of each year. These maps were downloaded from the MODIS Active Fire Mapping Program

website at http://activefiremaps.fs.fed.us/activefiremaps.php?op=maps&rCode=cgb . 

Figure 6-7 shows the 2006 Winters, Charleston Complex and Sheep fire detections in 

northeastern Nevada. The Jarbidge WA is located in the northeast corner of Nevada, between 

the eastern-most large fire shown in Figure 6-7 and the Idaho border. The IMPROVE monitor 

JARB1 location is depicted in black. Recall that 2006 has a large OMC extinction component 

that may in part be due to these fires. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-19 
FIGURE 6-7 

2006 MODIS FIRE DETECTIONS IN CALIFORNIA AND NEVADA

Figure 6-8 shows the Jarbidge WA surrounded by the 2007 Murphy Complex Fire detections on 

the west, north, and east where nearly two thirds of a million acres burned in this one fire 

complex. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-20 
FIGURE 6-8 

2007 MODIS FIRE DETECTIONS IN CALIFORNIA AND NEVADA

Figure 6-9 shows the 2008 East Slide Rock Ridge fire partially within the Jarbidge WA and 

burning out of the wilderness area to the east. This long-lived fire started as a lighting strike 

within the wilderness area and was allowed to burn as wildland fire use fire until it crossed out of 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-21 
the wilderness area and was partially suppressed. The listed acreage does not represent full 

containment of this fire, as of early October 2008 and the acreage will likely increase. 

FIGURE 6-9 

2008 MODIS FIRE DETECTIONS IN CALIFORNIA AND NEVADA

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-22 
Monitor data is not yet available for 2007 to assess the impact of the Murphy Complex fire on 

visibility at the Jarbidge WA, nor is data for 2008 to assess the impacts of the East Slide Rock 

Ridge fire and the effects of the prolonged regional transport of smoke from the 2008 northern 

California fires. Nevada suspects the visibility impacts from natural fires are not limited to OMC 

and EC emissions, but include CM and SOIL emissions due to windblown transport from the 

denuded burn areas which may persist for years after a fire. Rehabilitation efforts on the Murphy 

Complex have been hampered by low soil moisture conditions likely resulting in significant local 

transport of particulates due to windblown dust. It is clear from Figure 6-6 that the relative 

extinction contribution of both OMC and CM increased significantly in 2006. The relative 

contribution of EC and SOIL also increased, although less markedly than OMC and CM. The 

extinction increases for these species are likely a result of the large acreages burned in northern 

Nevada during 2006. 

The 2006 monitoring data, presented in Figure 6-6, show the visibility impairment resulting from

natural sources such as natural fire and windblown dust overwhelms the effects of emissions 

reductions resulting from additional control of Nevada’s anthropogenic emissions. Nevada 

anticipates a similar result for 2007 and possibly 2008 based on the active fire season in these 

years. 

NEVADA REGIONAL HAZE STATE IMPLEMENTATION PLAN, October 2009 6-23 
6.8 REFERENCES

U.S. EPA 2007. Guidance for Setting Reasonable Progress Goals under the Regional Haze Rule. 

U.S. Environmental Protection Agency, Office of Air Quality and Standards, Research Triangle 

Park, North Carolina. June 1, 2007 rev. 

U.S. EPA 2001. Guidance for Demonstrating Attainment of Air Quality Goals for PM2.5 and 

Regional Haze, Draft Report. U.S. Environmental Protection Agency, Research Triangle Park, 

North Carolina. January 2, 2001. 

U.S. EPA 2007. Guidance on the Use of Models and Other Analyses for Demonstrating 

Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze-Draft 3.2. U.S. 

Environmental Protection Agency, Office of Air Quality and Standards, Research Triangle Park, 

North Carolina. April, 2007. 

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