Evaluation of State Emission Trends Analysis 

Technical Support Document 

for the EPA’s 

Proposed Action on the 

New Mexico Regional Haze Five-Year Progress Report State Implementation Plan 

November 2, 2015 
2 

For information in this technical support document, please contact: 

James E. Grady 

Air Planning Section 

U.S. Environmental Protection Agency- Region 6 

1445 Ross Avenue 

Dallas, Texas 75202-2733 

(214) 665-6745 

grady.james@epa.gov 
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Emissions Reductions 

Clean Air Markets Division (CAMD) implements the provisions of 40 CFR § 75, which requires an 

hourly accounting of emissions from sources participating in an emissions cap and trade program 

under the Acid Rain Control Program, the NOX Budget Trading Program, or the Clean Air Interstate 

Rule. Most of the CAMD sources are traditional power plants that sell electricity to the electrical grid. 

There are other types of sources that report to CAMD that are not considered to be EGUs, such as 

petroleum refineries and cement kilns. However, in New Mexico, the CAMD data represents EGUs 

only. The annual unit level CAMD NOX and SO2 emissions data from 2001-2014 were downloaded 

by the EPA for use in this progress report review. 

The EPA prepared Table 1 and Figure 1 below to compare to the results that NMED provided in 

Figure 3.6 of the progress report SIP. The EPA showed that SO2 emissions from point sources 

dropped 22,230 tpy to 16,548 tpy from 2008-2012, reflecting a 25.5% reduction. Similarly, NO2

emissions reduced 68,800 tpy to 59,603 tpy, reflecting a 13.4% reduction. These emission reductions 

are slightly lower than what NMED provided in figure 3.6 of the progress report SIP, but show similar 

trends. 

 

 Table 1: New Mexico Emissions from CAMD1

Year SO2 (tpy) NOX (tpy) 

2001 62,198 83,340 

2002 50,818 78,362 

2003 50,841 77,135 

2004 38,361 74,139 

2005 30,527 75,285 

2006 31,153 78,025 

2007 26,659 71,187 

2008 22,230 68,800 

2009 19,283 66,291 

2010 16,556 59,935 

2011 17,810 61,947 

2012 16,548 59,603 

2013 17,722 57,253 

2014 12,030 43,591 

 1 Source: U.S. EPA Clean Air Market Division www.epa.gov/airmarket/ 
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Visibility Progress 

The EPA has provided table 2 below and subsequent glide path charts from the WRAP website2

 to 

provide a visualization of how New Mexico is progressing with their RPGs. The 2018 RPGs in the 

progress report SIP are slightly higher than the uniform rate of progress to meet 2064 natural 

conditions. However, other important issues are considered in developing mandatory Federal Class I 

area progress goals. Other reasonable progress factors in the CAA are as follows: 

 The costs of compliance; 

 The time necessary for compliance; 

 The energy and non-air quality environmental impacts of compliance; and 

 The remaining useful life of any existing source subject to such requirements. 

 

Table 2: New Mexico RPG Comparison 

Class I Area 2018 RPG (dv) 2018 Uniform Rate 

of Progress (dv) 

2064 Natural 

Conditions (dv)

Bandelier National Monument 11.9 10.8 6.3 

Bosque del Apache Wilderness Area 13.59 12.1 6.7 

Gila Wilderness Area 12.99 11.6 6.7 

Carlsbad Caverns National Monument 16.93 14.7 6.7 

Salt Creek Wilderness Area 17.33 15.4 6.8 

San Pedro Parks Wilderness Area 9.8 9.1 5.7 

Wheeler park Wilderness Area 10.23 9.4 6.1 

White Mountain Wilderness Area 13.27 12.1 6.8 

 2 Data from the following WRAP website: http://vista.cira.colostate.edu/TSS/Results/HazePlanning.aspx 

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

20012002200320042005200620072008200920102011201220132014

tpy

Date

Figure 1 New Mexico Emissions from CAMD

SO2 (tpy) NOx (tpy)
5 
6 
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Emissions Progress 

The EPA preferably views the “applicable five-year period” to represent the five years that have 

elapsed since the State submitted its RH SIP. There is room for state discretion in the reports regarding 

the five-year period that is considered to be most practical and useful for meeting this requirement. 

There is an inevitable time delay in developing and reporting inventories and thus trends over the 

most recent five years will not be available.3

 New Mexico did include the latest inventory updates for 

EGUs. 

The progress report SIP included New Mexico’s baseline emissions inventory from 2002 and an 

estimated emissions inventory for a progress period from 2008. The baseline period was represented 

using a 2002 inventory developed by the WRAP for use in the initial WRAP RH SIP strategy 

 3 General Principles for the 5-Year Regional Haze Progress Reports for the Initial Regional Haze State Implementation Plans (Intended to 

Assist States and EPA Regional Offices in Development and Review of the Progress Reports, EPA, April 2013. 
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development. The progress period was represented by a 2008 inventory, which leveraged recent 

WRAP inventory work for the West-wide Jumpstart Air Quality Modeling Study (WestJumpAQMS) 

and the Deterministic & Empirical Assessment of Smoke’s Contribution to Ozone (DEASCO3) 

modeling project efforts. 

 

The pollutants inventoried include SO2, NOX, ammonia (NH3), volatile organic compounds (VOCs), 

primary organic aerosol (POA), elemental carbon (EC); Fine soil reported as the crustal or soil 

components of PM2.5; and coarse mass as the difference between PM10 and PM2.5 mass measurements 

(PMC). The inventories were categorized for all major visibility-impairing pollutants under major 

source groupings either as anthropogenic or natural. The anthropogenic source categorization 

included point and area sources; on and off-road mobile sources; area oil and gas; fugitive and road 

dust; and anthropogenic fire. The natural source categorization included natural fire, wind-blown dust, 

and biogenic sources. 

A comparison of emissions inventory data showed that emissions of the key visibility-impairing 

pollutants SO2 and NOX, dropped. SO2 decreased from 50,667 tpy in 2002 to 27,545 tpy in 2008, 

including a 12,754 reduction in point sources from 2002-2008. NOX decreased from 345,974 tpy to 

228,199 tpy, including a 37,885 tpy reduction in point sources from 2002-2008. 

The largest differences for point source inventories were decreases in SO2, NOX and VOCs. Note that 

this is consistent with the summary of annual EGU emissions as included in Figure 3.21, showing 

decreases in SO2 and NOX emissions. Please note that NOX and SO2 point source emissions for 2008-

2012 are already under the 2018 WRAP projections. New Mexico expects overall SO2, NOX and PM

EGU emissions to continue to decline due to BART implementation. Installation of NOX SNCR 

controls will occur on two of the units at the beginning of 2016 and two other units will retire at the 

end of 2017. Both actions should result in further visibility improvement at Class I areas affected by 

New Mexico sources. 

Area source inventories showed decreases in SO2 and VOCs and increases in NOX and NH3. New 

Mexico mentioned that these changes may be due to a combination of population changes and 

differences in methodologies used to estimate these emissions. 

On-road mobile source inventory comparisons showed decreases in SO2, NH3 and VOCs, but 

increases in most other parameters, including NOX. Off-road mobile source inventories showed 

decreases in NOX, SO2, VOCs, and EC, and slight increases in fine soil and coarse mass. 

For all parameters, especially POAs, VOCs, and EC, natural fire emission inventory estimates 

decreased, and anthropogenic fire inventories increased. Comparisons between VOC inventories 

showed large decreases in biogenic emissions, which was consistent with other contiguous WRAP 

States. Fine soil and coarse mass increased for the windblown dust inventory comparisons and the 

combined fugitive/road dust inventories. Large variability in changes in windblown dust was observed 

for the adjoining WRAP States.