*Draft* 

New Mexico State Implementation Plan 

Regional Haze 

Section 308 

New Mexico Environment Department 

Air Quality Bureau 

June 21, 2010
New Mexico Section 308 Regional Haze SIP ii

TABLE OF CONTENTS 

CHAPTER 1: INTRODUCTION..........................................................................................................1

1.1 Overview of Visibility and Regional Haze..................................................................................1

1.2 New Mexico Class I Areas ..........................................................................................................2

1.3 Summary of the Regional Haze Rule ..........................................................................................4

1.4 Background on the Regional Haze Rule......................................................................................4

1.4.1 The 1977 Clean Air Act Amendments....................................................................................4

1.4.2 Phase I Visibility Rules – The New Mexico Visibility Protection Plan..................................5

1.4.3 The 1990 Clean Air Act Amendments....................................................................................5

1.4.4 Submittal of the New Mexico 309 SIP....................................................................................7

1.5 Purpose of this Document............................................................................................................7

1.5.1 Basic Plan Elements................................................................................................................7

CHAPTER 2: NEW MEXICO REGIONAL HAZE SIP DEVELOPMENT PROCESS....................11

2.1 Federal Land Manager Consultation .........................................................................................11

2.2 State Consultation......................................................................................................................12

2.3 Tribal Consultation....................................................................................................................14

2.4 Public and Stakeholder Outreach ..............................................................................................14

CHAPTER 3: NEW MEXICO CLASS I AREAS ..............................................................................15

3.1 Bandelier Wilderness Area........................................................................................................15

3.2 Bosque del Apache National Wildlife Refuge...........................................................................15

3.3 Carlsbad Caverns National Park................................................................................................16

3.4 Gila Wilderness .........................................................................................................................17

3.5 Pecos Wilderness.......................................................................................................................18

3.6 Salt Creek Wilderness ...............................................................................................................19

3.7 San Pedro Parks Wilderness......................................................................................................20

3.8 Wheeler Peak Wilderness..........................................................................................................21

3.9 White Mountain Wilderness......................................................................................................22

CHAPTER 4: REGIONAL HAZE MONITORING NETWORK ......................................................24

4.1 Overview of IMPROVE Network .............................................................................................24

4.2 New Mexico IMPROVE Monitoring Network .........................................................................26

4.2.1 Bandelier Wilderness ............................................................................................................27

4.2.2 Bosque del Apache National Wildlife Refuge ......................................................................28

4.2.3 Carlsbad Caverns National Park ...........................................................................................28

4.2.4 Gila Wilderness.....................................................................................................................30

4.2.5 Pecos Wilderness ..................................................................................................................30

4.2.6 Salt Creek Wilderness ...........................................................................................................31

4.2.7 San Pedro Parks Wilderness..................................................................................................32

4.2.8 Wheeler Peak Wilderness......................................................................................................33

4.2.9 White Mountain Wilderness..................................................................................................34

4.3 New Mexico Regional Haze Monitoring Commitments ...........................................................35

CHAPTER 5: TECHNICAL INFORMATION AND DATA.............................................................37

5.1 WRAP and Technical Support ..................................................................................................37

5.1.1 WRAP Committees and Workgroups ...................................................................................37

5.1.2 WRAP Technical Support System .......................................................................................39

CHAPTER 6: NEW MEXICO CLASS ONE AREA BASELINE, NATURAL CONDITIONS, AND 

UNIFORM RATE OF PROGRESS ...........................................................................................................40

6.1 Baseline and Current Visibility Conditions...............................................................................40

6.3 Monitoring Data ........................................................................................................................41

6.4 Natural Visibility Conditions.....................................................................................................41

6.5 Uniform Progress.......................................................................................................................42
New Mexico Section 308 Regional Haze SIP iii

CHAPTER 7: VISIBILITY IMPAIRMENT AT NEW MEXICO CLASS I AREAS ........................44

7.1 Bandelier Wilderness.................................................................................................................45

7.2 Bosque del Apache National Wildlife Refuge...........................................................................47

7.3 Carlsbad Caverns National Park................................................................................................48

7.4 Gila Wilderness .........................................................................................................................50

7.5 Pecos Wilderness, Wheeler Peak Wilderness............................................................................51

7.6 Salt Creek Wilderness ...............................................................................................................53

7.7 San Pedro Parks Wilderness......................................................................................................54

7.8 White Mountain Wilderness......................................................................................................56

CHAPTER 8: SOURCES OF VISIBILITY IMPAIRMENT..............................................................58

8.1 Anthropogenic Sources..............................................................................................................58

8.2 Natural Sources .........................................................................................................................58

8.3 Overview of Emission Inventory System – WRAP Technical Support System .......................58

8.4 New Mexico Emissions Data ....................................................................................................59

CHAPTER 9: VISIBILITY MODELING AND SOURCE APPORTIONMENT..............................64

9.1 Modeling Overview...................................................................................................................64

9.2 Summary of Modeling Results for CMAQ ...............................................................................66

9.2.1 CMAQ Modeling by Pollutant..............................................................................................66

9.3 Summary of PSAT Modeling Results .......................................................................................74

9.3.1 Bandelier Wilderness ............................................................................................................75

9.3.2 Bosque del Apache National Wildlife Refuge ......................................................................77

9.3.3 Carlsbad Caverns National Park ...........................................................................................79

9.3.4 Gila Wilderness.....................................................................................................................81

9.3.5 Pecos Wilderness, Wheeler Peak Wilderness .......................................................................83

9.3.6 Salt Creek Wilderness ...........................................................................................................85

9.3.7 San Pedro Parks Wilderness..................................................................................................87

9.3.8 White Mountain Wilderness..................................................................................................89

9.4 Summary of WEP Results .........................................................................................................91

9.4.1 Bandelier Wilderness ............................................................................................................91

9.4.2 Bosque del Apache National Wildlife Refuge ......................................................................95

9.4.3 Carlsbad Caverns National Park ...........................................................................................98

9.4.4 Gila Wilderness...................................................................................................................102

9.4.5 Pecos Wilderness, Wheeler Peak Wilderness .....................................................................105

9.4.6 Salt Creek Wilderness .........................................................................................................108

9.4.7 San Pedro Parks Wilderness................................................................................................112

9.4.8 White Mountain Wilderness................................................................................................115

CHAPTER 10: BEST AVAILABLE RETROFIT TECHNOLOGY (BART) EVALUATION.........119

10.1 Introduction .............................................................................................................................119

10.2 SO2: Regional SO2 Milestone and Backstop Trading Program...............................................119

10.3 Summary of BART Modeling Results (Visibility Impact Analysis).......................................120

10.3.1 New Mexico Process ......................................................................................................120

10.3.2 Subject-to-BART Determination....................................................................................125

10.3.3 Determining BART.........................................................................................................125

Step 1 – Identify All Available Retrofit Control Technologies ................................................................125

Step 4 – Evaluate Impacts and Document the Results..............................................................................125

10.4 Summary of BART Control Analysis for PNM San Juan.......................................................126

10.5 Visibility Improvement Resulting from BART Evaluation in New Mexico..........................127

CHAPTER 11: REASONABLE PROGRESS GOAL DEMONSTRATION .....................................128

11.1 Reasonable Progress Requirements.........................................................................................128

11.2 Four Factor Analysis Performed for New Mexico Sources.....................................................129

11.2.1 Detailed Description of the Four Factors........................................................................130
New Mexico Section 308 Regional Haze SIP iv

11.2.2 Source Selection Process for Four Factor Analysis........................................................130

11.2.3 Four Factor Analyses for New Mexico...........................................................................131

11.3 Setting Reasonable Progress Goals .........................................................................................138

11.3.1 Bandelier Wilderness Area .............................................................................................139

11.3.2 Bosque del Apache National Wildlife Refuge................................................................139

11.3.3 Carlsbad Caverns National Park .....................................................................................140

11.3.4 Gila Wilderness...............................................................................................................141

11.3.5 Pecos / Wheeler Peak Wilderness Areas ........................................................................142

11.3.6 Salt Creek Wilderness Area............................................................................................143

11.3.7 San Pedro Parks Wilderness Area...................................................................................144

11.3.8 White Mountain Wilderness Area ..................................................................................145

11.4 Conclusions for State-Wide Reasonable Progress...................................................................146

CHAPTER 12: LONG-TERM STRATEGY (LTS)............................................................................149

12.1 Overview .................................................................................................................................149

12.2 Other States’ Class I Areas Affected by New Mexico Emissions...........................................149

12.2.1 Nitrate Contributions from New Mexico on Surrounding States' Class I Areas.............149

12.2.2 Sulfate Contributions from New Mexico on Surrounding State's Class I Areas ............153

12.3 New Mexico Class I Areas Affected by Other States, Nations and Areas of the World.........157

12.3.1 Nitrate Emissions............................................................................................................157

12.3.2 Sulfate Emissions............................................................................................................158

12.4 Summary of Interstate Consultation ........................................................................................159

12.5 Estimated Contributions from CENRAP and Eastern U.S......................................................159

12.6 Estimated International Contribution to New Mexico's Class I Areas ....................................159

12.7 Required Factors for the Long-Term Strategy.........................................................................160

12.7.1 Emission Reductions Due to Ongoing Air Pollution Control Programs.........................160

12.7.2 New Source Review Program.........................................................................................160

12.7.3 Prevention of Significant Deterioration (PSD) Program ................................................160

12.7.4 Minor Source BACT Program........................................................................................161

12.7.5 Title V Operating Permit Program..................................................................................161

12.7.6 New Source Performance Standards (NSPS)..................................................................161

12.7.7 National Emission Standards for Hazardous Air Pollutants ...........................................162

12.7.8 New Mexico Reasonably Attributable Visibility Impairment Rules ..............................162

12.7.9 Ongoing Implementation of Federal Mobile Source Regulations ..................................162

12.7.10 Ongoing Implementation of State Mobile Source Regulations ......................................163

12.7.11 Ongoing Implementation of Programs to Meet PM10 NAAQS ......................................163

12.7.12 Measures to Mitigate the Impacts of Construction Activities.........................................164

12.7.13 Emission Limitations and Schedules of Compliance......................................................164

12.7.14 Source Retirement and Replacement Schedules.............................................................165

12.7.15 Agricultural and Forestry Smoke Management Techniques...........................................165

12.7.16 Enforceability of New Mexico’s Measures ....................................................................166

12.8 Additional Measures in the Long-Term Strategy ....................................................................166

12.8.1 Future Federal Mobile Programs ....................................................................................166

12.8.2 Efforts to Address Offshore Shipping.............................................................................167

12.8.3 Long-Term Control Strategies for BART Facilities .......................................................168

12.8.4 Evaluation of Control Strategies for Sources Identified in the Reasonable Progress - FourFactor Analysis .................................................................................................................................168

12.8.5 Oil and Gas .....................................................................................................................168

12.9 Projection of the Net Effect on Visibility................................................................................169

CHAPTER 13: OTHER SIP REQUIREMENTS AND COMMITMENTS........................................179

13.1 Enforceability of Emission Limitations and Control Measures...............................................179

13.2 Commitment to Future 308 SIP Revisions ..............................................................................179
New Mexico Section 308 Regional Haze SIP v

13.3 Commitment to Periodic Progress Reports..............................................................................180

13.4 Determination of Plan Adequacy ............................................................................................180

APPENDICES AND TECHNICAL SUPPORT DOCUMENTATION...................................................181

LIST OF TABLES 

Table 1-1: New Mexico Class I Areas ..........................................................................................................3

Table 4-1: IMPROVE Monitors in New Mexico........................................................................................26

Table 6-1: Baseline Conditions for 20% Worst Days.................................................................................40

Table 6-2: Baseline Conditions for 20% Best Days ...................................................................................41

Table 6-3: 2064 Natural Conditions Goal for 20% Worst Days.................................................................42

Table 6-4: Summary of Best and Worst Visibility Days for New Mexico Class I Areas...........................43

Table 7-1: IMPROVE Monitor Aerosol Composition................................................................................44

Table 8-1: New Mexico SO2 Emission Inventory – 2002 & 2018..............................................................60

Table 8-2: New Mexico NOX Emission Inventory – 2002 & 2018 ............................................................60

Table 8-3: New Mexico VOC Emission Inventory – 2002 & 2018 ...........................................................61

Table 8-4: New Mexico Primary Organic Aerosol (POA) Emission Inventory – 2002 & 2018................61

Table 8-5: New Mexico Elemental Carbon (EC) Emission Inventory – 2002 & 2018 ..............................62

Table 8-6: New Mexico Soil (PM Fine/PM2.5) Emission Inventory – 2002 & 2018..................................62

Table 8-7: New Mexico Coarse Mass (PM Coarse) Emission Inventory – 2002 & 2018..........................62

Table 8-8: New Mexico Ammonia (NH3) Emission Inventory – 2002 & 2018 .........................................63

Table 9-1: Summary of CMAQ Modeling Progress Towards 2018 ...........................................................66

Table 9-2: Pollutant Breakdown on 20% Worst Days for Bandelier Wilderness.......................................67

Table 9-3: Pollutant Breakdown on 20% Worst Days for Bosque del Apache NWR ................................68

Table 9-4: Pollutant Breakdown on 20% Worst Days for Carlsbad Caverns NP .......................................69

Table 9-5: Pollutant Breakdown on 20% Worst Days for Gila Wilderness................................................70

Table 9-6: Pollutant Breakdown on 20% Worst Days for Pecos Wilderness, Wheeler Peak Wilderness..71

Table 9-7: Pollutant Breakdown on 20% Worst Days for Salt Creek Wilderness......................................72

Table 9-8: Pollutant Breakdown on 20% Worst Days for San Pedro Parks Wilderness ............................73

Table 9-9: Pollutant Breakdown on 20% Worst Days for White Mountain Wilderness ............................74

Table 10-1 Regional Sulfur Dioxide Emissions and Milestone Report Summary ...................................120

Table 10-2: Visibility Impact Analysis of PNM's San Juan Generating Station ......................................122

Table 11-1: 20% Best and Worst Days Baseline, Natural Conditions, and Uniform Rate of Progress Goal 

for New Mexico Class I Areas..................................................................................................................129

Table 11-2: Estimated Costs of Potential Emission Control Devices for FCCU #1 at Navajo Refining Co., 

Artesia Refinery........................................................................................................................................132

Table 11-3: Estimated Energy and Non-Air Environmental Impacts of Potential Emission Control 

Devices for FCCU #1 at Navajo Refining Co...........................................................................................133

Table 11-4: Estimated Costs of Potential Emission Control Devices for FCCU at Western Refining 

Southwest, Bloomfield Refinery...............................................................................................................134

Table 11-5: Estimated Energy and Non-Air Environmental Impacts of Potential Emission Control 

Devices for FCCU #1 at Western Refining Southwest, Bloomfield Refinery..........................................135

Table 11-6: Estimated Costs of Potential Emission Control Devices for CO Boiler at Western Refining 

Southwest, Gallup Refinery ......................................................................................................................137

Table 11-7: Estimated Energy and Non-Air Environmental Impacts of Potential Emission Control 

Devices for CO Boiler at Western Refining Southwest, Gallup Refinery ................................................137

Table 11-8: Reasonable Progress Goals for 20% Worst Days and 20% Best Days for New Mexico Class I 

Areas .........................................................................................................................................................138

Table 12-1: Nitrate Contribution to Haze in Baseline Years for Worst 20% Days ..................................150

Table 12-2: Sulfate Contribution to Haze in Baseline Years for Worst 20% Days ..................................153
New Mexico Section 308 Regional Haze SIP vi

Table 12-3: Nitrate Contribution to New Mexico Haze in Baseline Years for 20% Worst Days.............157

Table 12-4: WRAP Nitrate Contribution to New Mexico Haze Baseline Years for Worst 20% Days ....158

Table 12-5: Sulfate Contribution to New Mexico Haze in Baseline Years for Worst 20% Days ............158

Table 12-6: WRAP Sulfate Contribution to New Mexico Haze Baseline Years for Worst 20% Days....159

Table 12-7: Class I Area Visibility Summary for BAND1 on 20% Worst Days......................................171

Table 12-8: Class I Area Visibility Summary for BOAP1 on 20% Worst Days ......................................172

Table 12-9: Class I Area Visibility Summary for GUMO1 on 20% Worst Days.....................................173

Table 12-10: Class I Area Visibility Summary for GILA1 on 20% Worst Days .....................................174

Table 12-11: Class I Area Visibility Summary for SACR1 on 20% Worst Days ....................................175

Table 12-12: Class I Area Visibility Summary for SAPE1 on 20% Worst Days .....................................176

Table 12-13: Class I Area Visibility Summary for WHIT1 on 20% Worst Days ....................................177

Table 12-14: Class I Area Visibility Summary for WHPE1 on 20% Worst Days....................................178

LIST OF FIGURES

Figure 1-1: Federal Class I Areas within the United States..........................................................................1

Figure 1-2: Class I Areas in the Western Region..........................................................................................2

Figure 1-3: Map of New Mexico Class I Areas ............................................................................................3

Figure 1-4: Illustration of Uniform Rate of Progress....................................................................................9

Figure 3-1: Bandelier Wilderness ...............................................................................................................15

Figure 3-2: Bosque del Apache National Wildlife Refuge .........................................................................16

Figure 3-3: Carlsbad Caverns National Park ..............................................................................................17

Figure 3-4: Gila Wilderness........................................................................................................................18

Figure 3-5: Pecos Wilderness .....................................................................................................................19

Figure 3-6: Salt Creek Wilderness..............................................................................................................20

Figure 3-7: San Pedro Parks Wilderness.....................................................................................................21

Figure 3-8: Wheeler Peak Wilderness ........................................................................................................22

Figure 3-9: White Mountain Wilderness ....................................................................................................23

Figure 4-1: IMPROVE Monitor at Salt Creek Wilderness .........................................................................24

Figure 4-2: Four Modules Used for Regional Haze Sampling ...................................................................24

Figure 4-3: Map of New Mexico IMPROVE Sites.....................................................................................27

Figure 4-4: Bandelier National Monument.................................................................................................27

Figure 4-5: Bosque del Apache National Wildlife Refuge .........................................................................28

Figure 4-6: Map of Carlsbad Caverns National Park..................................................................................29

Figure 4-7: Guadalupe Mountains National Park .......................................................................................29

Figure 4-8: Gila Wilderness........................................................................................................................30

Figure 4-9: Pecos Wilderness .....................................................................................................................31

Figure 4-10: Salt Creek Wilderness............................................................................................................32

Figure 4-11: San Pedro Parks Wilderness...................................................................................................33

Figure 4-12: Wheeler Peak Wilderness ......................................................................................................34

Figure 4-13: White Mountain Wilderness ..................................................................................................35

Figure 7-1: Reconstructed Aerosol Components for 20% Worst Days (2000-2004) .................................44

Figure 7-2: Reconstructed Aerosol Components for 20% Best Days (2000-2004)....................................45

Figure 7-3: Average Species Contribution to 20% Best and Worst Days Baseline....................................45

Figure 7-4: Monthly Average Species Variation for All Sampled Days During the Baseline Period ........46

Figure 7-5: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected Visibility 

and 2064 Natural Conditions Goal..............................................................................................................46

Figure 7-6: Average Species Contribution to 20% Best and Worst Days Baseline....................................47

Figure 7-7: Monthly Average Species Variation for All Sampled Days during the Baseline Period.........47
New Mexico Section 308 Regional Haze SIP vii

Figure 7-8: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected Visibility 

and 2064 Natural Conditions Goal..............................................................................................................48

Figure 7-9: Average Species Contribution to 20% Best and Worst Days Baseline....................................48

Figure 7-10: Monthly Average Species Variation for All Sampled Days during the Baseline Period.......49

Figure 7-11: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal .............................................................................................49

Figure 7-12: Average Species Contribution to 20% Best and Worst Days Baseline..................................50

Figure 7-13: Monthly Average Species Variation for All Sampled Days during the Baseline Period.......50

Figure 7-14: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal .............................................................................................51

Figure 7-15: Average Species Contribution to 20% Best and Worst Days Baseline..................................51

Figure 7-16: Monthly Average Species Variation for All Sampled Days during the Baseline Period.......52

Figure 7-17: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal .............................................................................................52

Figure 7-18: Average Species Contribution to 20% Best and Worst Days Baseline..................................53

Figure 7-19: Monthly Average Species Variation for All Sampled Days during the Baseline Period.......53

Figure 7-20: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal .............................................................................................54

Figure 7-21: Average Species Contribution to 20% Best and Worst Days Baseline..................................54

Figure 7-22: Monthly Average Species Variation for All Sampled Days during the Baseline Period.......55

Figure 7-23: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal .............................................................................................55

Figure 7-24: Average Species Contribution to 20% Best and Worst Days Baseline..................................56

Figure 7-25: Monthly Average Species Variation for All Sampled Days during the Baseline Period.......56

Figure 7-26: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal .............................................................................................57

Figure 9-1: URP by Pollutant on 20% Worst Days for Bandelier Wilderness ...........................................67

Figure 9-2: URP by Pollutant on 20% Worst Days for Bosque del Apache NWR ....................................68

Figure 9-3: URP by Pollutant on 20% Worst Days for Carlsbad Caverns NP ...........................................69

Figure 9-4: URP by Pollutant on 20% Worst Days for Gila Wilderness....................................................70

Figure 9-5: URP by Pollutant on 20% Worst Days for Pecos Wilderness, Wheeler Peak Wilderness ......71

Figure 9-6: URP by Pollutant on 20% Worst Days for Salt Creek Wilderness..........................................72

Figure 9-7: URP by Pollutant on 20% Worst Days for San Pedro Parks Wilderness.................................73

Figure 9-8: URP by Pollutant on 20% Worst Days for White Mountain Wilderness ................................74

Figure 9-9: PSAT for Sulfate on 20% - Regional Contributions ................................................................75

Figure 9-10: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions .................76

Figure 9-11: PSAT for Nitrate on 20% Worst Days – Regional Contributions..........................................76

Figure 9-12: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions..................77

Figure 9-13: PSAT for Sulfate on 20% Worst Days – Regional Contributions .........................................77

Figure 9-14: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions .................78

Figure 9-15: PSAT for Nitrate on 20% Worst Days – Regional Contributions..........................................78

Figure 9-16: PSAT for Nitrate on 20% Worst Days – WRAP States and Regional Contributions............79

Figure 9-17: PSAT for Sulfate on 20% Worst Days – Regional Contributions .........................................79

Figure 9-18: PSAT for Sulfate on 20% Worst Days – WRAP States and Regional Contributions............80

Figure 9-19: PSAT Nitrate on 20% Worst Days – Regional Contributions ...............................................80

Figure 9-20: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions..................81

Figure 9-21: PSAT Sulfate on 20% Worst Days – Regional Contributions ...............................................81

Figure 9-22: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions .................82

Figure 9-23: PSAT Nitrate on 20% Worst Days – Regional Contributions ...............................................82

Figure 9-24: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions..................83

Figure 9-25: PSAT Sulfate on 20% Worst Days – Regional Contributions ...............................................83
New Mexico Section 308 Regional Haze SIP viii

Figure 9-26: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions .................84

Figure 9-27: PSAT Nitrate on 20% Worst Days – Regional Contributions ...............................................84

Figure 9-28: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions..................85

Figure 9-29: PSAT Sulfate on 20% Worst Days – Regional Contributions ...............................................85

Figure 9-30: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions .................86

Figure 9-31: PSAT Nitrate on 20% Worst Days – Regional Contributions ...............................................86

Figure 9-32: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions..................87

Figure 9-33: PSAT for Sulfate on 20% - Regional Contributions ..............................................................87

Figure 9-34: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions .................88

Figure 9-35: PSAT for Nitrate on 20% Worst Days – Regional Contributions..........................................88

Figure 9-36: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions..................89

Figure 9-37: PSAT Sulfate on 20% Worst Days – Regional Contributions ...............................................89

Figure 9-38: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions .................90

Figure 9-39: PSAT Nitrate on 20% Worst Days – Regional Contributions ...............................................90

Figure 9-40: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions..................91

Figure 9-41: Weighted Emissions Potential – Nitrogen Oxides .................................................................92

Figure 9-42: Weighted Emissions Potential – Sulfur Oxides .....................................................................92

Figure 9-43: Weighted Emissions Potential – Organic Carbon ..................................................................93

Figure 9-44: Weighted Emissions Potential – Elemental Carbon...............................................................93

Figure 9-45: Weighted Emissions Potential – Fine Particulate Matter.......................................................94

Figure 9-46: Weighted Emissions Potential – Coarse Particulate Matter...................................................94

Figure 9-47: Weighted Emissions Potential – Nitrogen Oxides .................................................................95

Figure 9-48: Weighted Emissions Potential – Sulfur Oxides .....................................................................96

Figure 9-49: Weighted Emissions Potential – Organic Carbon ..................................................................96

Figure 9-50: Weighted Emissions Potential – Elemental Carbon...............................................................97

Figure 9-51: Weighted Emissions Potential – Fine Particulate Matter.......................................................97

Figure 9-52: Weighted Emissions Potential – Coarse Particulate Matter...................................................98

Figure 9-53: Weighted Emissions Potential – Nitrogen Oxides .................................................................98

Figure 9-54: Weighted Emissions Potential – Sulfur Oxides .....................................................................99

Figure 9-55: Weighted Emissions Potential – Organic Carbon ................................................................100

Figure 9-56: Weighted Emissions Potential – Elemental Carbon.............................................................100

Figure 9-57: Weighted Emissions Potential – Fine Particulate Matter.....................................................101

Figure 9-58: Weighted Emissions Potential – Coarse Particulate Matter.................................................101

Figure 9-59: Weighted Emissions Potential – Nitrogen Oxides ...............................................................102

Figure 9-60: Weighted Emissions Potential – Sulfur Oxides ...................................................................103

Figure 9-61: Weighted Emissions Potential – Organic Carbon ................................................................103

Figure 9-62: Weighted Emissions Potential – Elemental Carbon.............................................................104

Figure 9-63: Weighted Emissions Potential – Fine Particulate Matter.....................................................104

Figure 9-64: Weighted Emissions Potential – Coarse Particulate Matter.................................................105

Figure 9-65: Weighted Emissions Potential – Nitrogen Oxides ...............................................................105

Figure 9-66: Weighted Emissions Potential – Sulfur Oxides ...................................................................106

Figure 9-67: Weighted Emissions Potential – Organic Carbon ................................................................106

Figure 9-68: Weighted Emissions Potential – Elemental Carbon.............................................................107

Figure 9-69: Weighted Emissions Potential – Fine Particulate Matter.....................................................107

Figure 9-70: Weighted Emissions Potential – Coarse Particulate Matter.................................................108

Figure 9-71: Weighted Emissions Potential – Nitrogen Oxides ...............................................................109

Figure 9-72: Weighted Emissions Potential – Sulfur Oxides ...................................................................109

Figure 9-73: Weighted Emissions Potential – Organic Carbon ................................................................110

Figure 9-74: Weighted Emissions Potential – Elemental Carbon.............................................................110

Figure 9-75: Weighted Emissions Potential – Fine Particulate Matter.....................................................111

Figure 9-76: Weighted Emissions Potential – Coarse Particulate Matter.................................................111
New Mexico Section 308 Regional Haze SIP ix

Figure 9-77: Weighted Emissions Potential – Nitrogen Oxides ...............................................................112

Figure 9-78: Weighted Emissions Potential – Sulfur Oxides ...................................................................113

Figure 9-79: Weighted Emissions Potential – Organic Carbon ................................................................113

Figure 9-80: Weighted Emissions Potential – Elemental Carbon.............................................................114

Figure 9-81: Weighted Emissions Potential – Fine Particulate Matter.....................................................114

Figure 9-82: Weighted Emissions Potential – Coarse Particulate Matter.................................................115

Figure 9-83: Weighted Emissions Potential – Nitrogen Oxides ...............................................................115

Figure 9-84: Weighted Emissions Potential – Sulfur Oxides ...................................................................116

Figure 9-85: Weighted Emissions Potential – Organic Carbon ................................................................116

Figure 9-86: Weighted Emissions Potential – Elemental Carbon.............................................................117

Figure 9-87: Weighted Emissions Potential – Fine Particulate Matter.....................................................117

Figure 9-88: Weighted Emissions Potential – Coarse Particulate Matter.................................................118

Figure 10-1: Visibility Improvement from BART Controls at San Juan Generating Station...................127

Figure 11-1: Uniform Rate of Progress Comparison to Reasonable Progress Goals for Bandelier .........139

Figure 11-2: Uniform Rate of Progress Comparison to Reasonable Progress Goals for Bosque del Apache

..................................................................................................................................................................140

Figure 11-3: Uniform Rate of Progress Comparison to Reasonable Progress Goals for Carlsbad Caverns

..................................................................................................................................................................141

Figure 11-4: Uniform Rate of Progress Comparison to Reasonable Progress Goals for Gila ..................142

Figure 11-5: Uniform Rate of Progress Comparison to Reasonable Progress Goals for Wheeler Peak...143

Figure 11-6: Uniform Rate of Progress Comparison to Reasonable Progress Goals for Salt Creek ........144

Figure 11-7: Uniform Rate of Progress Comparison to Reasonable Progress Goals for San Pedro Parks

..................................................................................................................................................................145

Figure 11-8: Uniform Rate of Progress Comparison to Reasonable Progress Goals for White Mountain

..................................................................................................................................................................146

Figure 11-9: OMC and EC Emissions Affecting New Mexico's Class I Areas........................................147

Figure 11-10: Impacts from Sources Outside of WRAP on New Mexico................................................148

Figure 12-1: Nitrate Contributions from New Mexico on Arizona Class I Areas ....................................150

Figure 12-2: Nitrate Contributions from New Mexico on Colorado Class I Areas ..................................151

Figure 12-3: Nitrate Contributions from New Mexico on Nevada Class I Areas.....................................151

Figure 12-4: Nitrate Contributions from New Mexico on Utah Class I Areas .........................................152

Figure 12-5: Nitrate Contributions from New Mexico on Texas Class I Areas .......................................152

Figure 12-6: Nitrate Contributions from New Mexico on Wyoming Class I Areas .................................153

Figure 12-7: Sulfate Contributions from New Mexico on Arizona Class I Areas....................................154

Figure 12-8: Sulfate Contributions from New Mexico on Colorado Class I Areas..................................154

Figure 12-9: Sulfate Contributions from New Mexico on Nevada Class I Areas.....................................155

Figure 12-10: Sulfate Contributions from New Mexico on Utah Class I Areas .......................................155

Figure 12-11: Sulfate Contributions from New Mexico on Texas Class I Areas .....................................156

Figure 12-12: Sulfate Contributions from New Mexico on Wyoming Class I Areas...............................156
New Mexico Section 308 Regional Haze SIP 1

CHAPTER 1: INTRODUCTION 

1.1 Overview of Visibility and Regional Haze 

Good visibility is important to the enjoyment of national parks and scenic areas. Across the country, 

regional haze has decreased the visual range from 140 miles to 35-90 miles in the West, and from 90 

miles to 15 -25 miles in the East. Regional haze is air pollution that is transported long distances, causing 

reduced visibility in national parks and wilderness areas. This haze is composed of small particles that 

absorb and scatter light, affecting the clarity and color of what we see. The pollutants that create this haze 

are sulfates, nitrates, organic carbon, elemental carbon and soil dust. Human-caused (anthropogenic) 

sources include industry, motor vehicles, agricultural and forestry burning, and windblown dust from 

roads and farming practices. 

There are 156 national parks and wilderness areas that have been designated by Congress as "mandatory 

federal Class I areas" (referred to herein as Class I areas) (Figure 1-1 and Figure 1-2). The Clean Air Act 

contains a national goal of reducing man-made visibility impairment in all Class I areas. To meet this 

goal, the U.S. Environmental Protection Agency (EPA) adopted the Regional Haze Rules in July 1999. 

These rules complement and are in addition to "Phase I" visibility rules adopted by EPA in 1980. 

Figure 1-1: Federal Class I Areas within the United States 
New Mexico Section 308 Regional Haze SIP 2

Figure 1-2: Class I Areas in the Western Region 

1.2 New Mexico Class I Areas 

New Mexico has nine (9) Class I areas: Bosque del Apache National Wildlife Refuge, Carlsbad Caverns 

National Park, and the Bandelier, Gila, Pecos, Salt Creek, San Pedro Parks, Wheeler Peak, and White 

Mountain Wilderness Areas. To protect visibility, Congress designated in 1977 all wilderness areas over 

5,000 acres and all national parks over 6,000 acres as mandatory federal Class I areas and subject to the 

visibility protection requirements in the Clean Air Act. Table 1-1 lists the Class 1 areas in New Mexico 

along with their acreages. Figure 1-1 shows the locations of Class I areas within, and within 100 

kilometers of, New Mexico. 
New Mexico Section 308 Regional Haze SIP 3

Table 1-1: New Mexico Class I Areas 

Class I Area Acreage 

Bosque del Apache National Wildlife Refuge 80,850 

Carlsbad Caverns National Park 46,435 

Bandelier Wilderness 23,267 

Gila Wilderness 433,690 

Pecos Wilderness 167,416 

Salt Creek Wilderness 8,500 

San Pedro Parks Wilderness 41,132 

Wheeler Peak Wilderness 6,027 

White Mountain Wilderness 31,171 

Figure 1-3: Map of New Mexico Class I Areas 
New Mexico Section 308 Regional Haze SIP 4

1.3 Summary of the Regional Haze Rule 

The goal of the Regional Haze Rule is to eliminate human-caused visibility impairment in Class I areas 

across the country. It contains strategies to improve visibility over the next 60 years, and requires states to 

adopt implementation plans. 

The Regional Haze Rule provides two paths for developing and adopting regional haze implementation 

plans. One is "Section 308" (40 CFR 51.308), and requires most states to develop long-term strategies out 

to the year 2064. These strategies must be shown to make "reasonable progress" in improving visibility in 

Class I areas inside the state and in neighboring jurisdictions. The other is "Section 309" (40 CFR 

51.309), and is an option for nine western states and one city – Arizona, California, Colorado, Idaho, 

Nevada, New Mexico, Oregon Utah, Wyoming, and the City of Albuquerque. These states (and the City 

of Albuquerque) can choose to follow Section 309 and adopt regional haze strategies for the period of 

2003 to 2018. The regional haze strategies are based on recommendations from the Grand Canyon 

Visibility Transport Commission (GCVTC) for protection the 16 Class I areas in the Colorado Plateau 

area. 

1.4 Background on the Regional Haze Rule 

1.4.1 The 1977 Clean Air Act Amendments 

National Visibility Goal 

In 1977, Congress amended the Clean Air Act to include provisions to protect the scenic vistas of the 

nation's national parks and wilderness areas. In these amendments, Congress declared as a national 

visibility goal: 

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. (Section 169A) 

To address this goal, the EPA developed regulations to reduce the impact of large industrial sources on 

nearby Class I areas. It was recognized at the time that regional haze, which comes from a wide variety of 

sources that may be located far from a Class I areas, was also a part of the visibility problems. However, 

monitoring networks and visibility models were not yet developed to the degree necessary to understand 

the causes of regional haze. 

Prevention of Significant Deterioration

The 1977 Clean Air Act Amendments established Prevention of Significant deterioration (PSD) 

requirements, which included protecting visibility in national parks, national wilderness areas, national 

monuments, and national seashores. The PSD program includes area specific (Class I, II, and III) 

increments or limits on the maximum allowable increasing air pollutants (particulate matter or sulfur 

dioxide) and a preconstruction permit review process for new or modifying major sources that allows for 

careful consideration of control technology, consultation with FLMs on visibility impacts and public 

participation in permitting decisions. 

Best Available Retrofit Technology

Under Section 169A(b), Congress established new requirements on major stationary sources in operation 

within a 15-year period prior to enactment of the 1977 amendments that can be reasonably attributed to 

cause visibility impairment in a mandatory Class I federal area. Such sources must install best available 

retrofit technology (BART) as determined by the State. In determining BART, the State must take into 

consideration the costs of compliance, the energy and non-air quality environmental impacts of 
New Mexico Section 308 Regional Haze SIP 5

compliance, any existing pollution control technology in use at the source, the remaining useful life of the 

source, and the degree of improvement in visibility which may reasonably be anticipated to result from 

the use of such technology. 

1.4.2 Phase I Visibility Rules – The New Mexico Visibility Protection Plan 

In 1980, EPA adopted regulations to address "reasonably attributable visibility impairment" (RAVI), or 

visibility impairment caused by one or a small group of man-made sources generally located in close 

proximity to a specific Class I area. These became known as EPA's "Phase I" visibility rules. At that time, 

EPA deferred writing rules to address regional haze, because they lacked the monitoring, modeling, and 

scientific information needed to understand the nature of long-range transport and formation of regional 

haze. EPA adopted "Phase II" rules on regional haze in July 1999. EPA approved New Mexico's Phase I 

(RAVI) visibility SIP on January 27, 2006. 

1.4.3 The 1990 Clean Air Act Amendments 

Although the 1980 regulation addressed reasonably attributable visibility impairment from specific 

sources, it did not adequately address visibility impairment from large collections of sources whose 

emissions are mixed and transported over long distances. In the 1990 amendments to the Clean Air Act, 

Congress established the requirements to address regional haze. They gave EPA the authority to establish 

visibility transport commissions and promulgate regulations to address regional haze. The 1990 

amendments also established a visibility transport commission to investigate and report on regional haze 

visibility impairment in the Grand Canyon National Park and nearby Class I areas. 

Grand Canyon Visibility Transport Commission Finding and Recommendations

The 1990 Clean Air Act Amendments created the Grand Canyon Visibility Transport Commission 

(GCVTC). The GCVTC was given the charge to assess the currently available scientific information 

pertaining to adverse impacts on visibility from potential growth in the region, identify clean air corridors, 

and recommend long-range strategies for addressing regional haze for Class I areas on the Colorado 

Plateau. The GCVTC completed significant technical analyses and developed recommendations to 

improve visibility in the 16 mandatory federal Class I areas on the Colorado Plateau. These 16 Class I 

areas are as follows: Arches National Park, Black Canyon of the Gunnison Wilderness, Bryce Canyon 

National Park, Canyonlands National Park, Capital Reef National Park, Flat Tops Wilderness, Grand 

Canyon National Park, Maroon Bells Wilderness, Mesa Verde National Park, Mount Baldy Wilderness, 

Petrified Forest National Park, San Pedro Parks Wilderness, Sycamore Canyon Wilderness, Weminuche 

Wilderness, West Elk Wilderness, and Zion National Park. 

The GCVTC found that visibility impairment on the Colorado Plateau was caused by a wide variety of 

sources and pollutants. A comprehensive strategy was needed to address all of the causes of regional 

haze. The GCVTC submitted these recommendations to EPA in a report dated June 1996 for 

consideration in rule development. These recommendations were: 

Air Pollution Prevention. Air pollution prevention and reduction of per capita pollution was a high 

priority for the Commission. The Commission recommended policies based on energy conservation, 

increased energy efficiency and promotion of the use of renewable resources for energy production. 

Clean Air Corridors. Clean air corridors are geographic areas that provide a source of clean air to the 16 

Class I areas of the Colorado Plateau. For these areas, the Commission primarily recommended careful 

tracking of emissions growth that may affect air quality in these corridors, and ultimately the 16 Class I 

areas. 
New Mexico Section 308 Regional Haze SIP 6

Stationary Sources. For stationary sources, the Commission recommended closely monitoring the impacts 

of current requirements under the Clean Air Act and ongoing studies. It also recommended regional 

targets for sulfur dioxide (SO2) emissions from stationary sources, starting in 2000. If these targets are 

exceeded, a regional cap and market-based emission trading program should be implements. 

Areas In and Near Parks. The Commission's research and modeling showed that a host of sources 

adjacent to parks and wilderness areas, including large urban areas, have significant visibility impacts. 

However, the Commission lacked sufficient data regarding the visibility impacts of emissions from some 

areas in and near parks and wilderness areas. In general, the models used by the Commission were not 

readily applicable to such areas. Pending further studies of these areas, the Commission recommended 

that local, state, tribal, federal, and private parties cooperatively develop strategies, expand data 

collection, and improve modeling for reducing or preventing visibility impairment in areas within and 

adjacent to parks and wilderness areas. 

Mobile Sources. The Commission recognized that mobile source emissions are projected to decrease 

through about 2005 due to improved control technologies. The Commission recommended capping 

emissions at the lowest level achieved and establishing a regional emissions budget, and also endorsed 

national strategies aimed at further reducing tailpipe emissions, including the so-called 49-state low 

emission vehicle, or 49-state LEV. 

Road Dust. The Commission's technical assessment indicated that road dust is a large contributor to 

visibility impairment on the Colorado Plateau. As such, it requires urgent attention. However, due to 

considerable skepticism regarding the modeled contribution of road dust to visibility impairment, the 

Commission recommended further study in order to resolve the uncertainties regarding both near-field 

and distant effects of road dust, prior to taking remedial action. Since this emission source is potentially 

such a significant contributor, the Commission felt that it deserved high priority attention and, if 

warranted, additional emissions management actions. 

Emissions from Mexico. Mexican sources are also shown to be significant contributors, particularly of 

SO2 emissions. However, data gaps and jurisdictional issues made this a difficult issue for the 

Commission to address directly. The Commission recommendations called for continued bi-national 

collaboration to work on this problem, as well as additional efforts to complete emissions inventories and 

increase monitoring capacities. These matters should receive high priority for regional and national 

action. 

Fire. The Commission recognized that fire plays a significant role in visibility on the Plateau. In fact, land 

managers propose aggressive prescribed fire programs aimed at correcting the buildup of biomass due to 

decades of fire suppression. Therefore, prescribed fire and wildfire levels are projected to increase 

significantly during the studied period. The Commission recommended the implementation of programs 

to minimize emissions and visibility impacts from prescribed fire, as well as to educate the public. 

Future Regional Coordinating Entity. Finally, the Commission believed there was a need for an entity 

like the Commission to oversee, promote, and support many of the recommendations in their report. To 

support that entity, the commission developed a set of recommendations addressing the future 

administrative, technical and funding needs of the Commission or a new regional entity. The Commission 

strongly urged the EPA and Congress to provide funding for these vital functions and give them a priority 

reflective of the national importance of the Class I areas on the Colorado Plateau. 

The Western Regional Air Partnership

The GCVTC recognized the need for a long-term organization to address the policy and technical studies 

needed to address regional haze. The Western Regional Air Partnership (WRAP) was formed in 
New Mexico Section 308 Regional Haze SIP 7

September 1997 as the successor organization to the GCVTC. The WRAP is made up of western states, 

tribes and federal agencies. The states are Alaska, Arizona, California, Colorado, Idaho, Montana, New 

Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming. The WRAP established 

stakeholder-based technical and policy oversight committees to assist in managing the development of 

regional haze work products. Stakeholder-based working groups and forums were established to focus 

attention on the policy and technical work products the states and tribes need to develop their 

implementation plans. Additional information about the WRAP can be found on the WRAP web site at 

http://www.wrapair.org. 

1.4.4 Submittal of the New Mexico 309 SIP 

In December 2003, the New Mexico Environmental Improvement Board adopted and the New Mexico 

Environment Department submitted to EPA the New Mexico Section 309 Regional Haze SIP. EPA did 

not act on this SIP. On January 15, 2009, EPA issued a Finding of Failure to Submit a State 

Implementation Plan in compliance with 40 CFR Part 51. Since New Mexico submitted a Regional Haze 

SIP in 2003, EPA found New Mexico failed to submit under 40 CFR 51.309(g) and 40 CFR 51.309(d)(4). 

1.5 Purpose of this Document 

This Regional Haze SIP has been prepared to meet the requirements of the Federal Regional Haze Rule, 

Section 40 CFR, Part 51, Section 308. It contains strategies and elements related to each requirement of 

this federal rule. The appendices provide additional information related to the strategies, including 

citations of new rules associated with this SIP, technical analysis, and reports prepared by WRAP. 

Relation to the WRAP's Regional Technical Support System 

The WRAP's Technical Support System (TSS) was the source for the majority of key technical 

information and data used in this SIP. The TSS includes the emissions information, modeling, 

methodology, and other information that was utilized to develop the reasonable progress goals and longterm strategies within this plan. The WRAP TSS can be found at http://vista.cira.colostate.edu/tss/. 

Mandatory Federal Class I Areas Addressed in this SIP 

The Regional Haze Rule under 40 CFR 51.308 requires states to address visibility protection for regional 

haze in New Mexico's Class I areas. These areas are listed in Section 1.2 and shown in Figure 1-3. 

1.5.1 Basic Plan Elements 

Natural Sources of Visibility Impairment 

Natural sources of visibility impairment include anything not directly attributed to human-caused 

(anthropogenic) emissions of visibility-impairing pollutants. Natural events (e.g. windblown dust, 

wildfire, biogenic emissions) also introduce pollutants that contribute to haze. Specific natural events can 

lead to high short-term concentrations of visibility-impairing particulate matter and its precursors. 

Therefore, natural visibility conditions, for the purpose of New Mexico's Regional Haze Program, are 

represented by a long-term average of conditions expected to occur in the absence of emissions normally 

attributed to human activities. Natural visibility conditions reflect contemporary vegetated landscape, 

land-use patterns, and meteorological/climatic conditions. 

Natural sources, particularly wildfire and windblown dust, can be major contributors to visibility 

impairment. However, these emissions cannot be realistically controlled or prevented by the States, and 

therefore the focus of the regional haze strategies in this document are on human-caused (anthropogenic) 

sources. While current methods of analysis of monitoring data do not provide a clear distinction between 

natural and anthropogenic emissions, certain pollutant species, such as SO2 and nitrogen oxides (NOx) are 
New Mexico Section 308 Regional Haze SIP 8

more representative of anthropogenic sources, while organic carbon (OC) and coarse particulate matter 

(CM or PM10) are more representative of natural sources such as wildfire and dust, respectively. 

Human-Caused (Anthropogenic) Sources of Visibility Impairment 

Anthropogenic sources of visibility impairment include anything directly attributable to human activities 

that produce emissions of visibility-impairing pollutants. Examples include industry, energy, 

transportation, construction, mining, agricultural activities, home heating, and outdoor burning. 

Anthropogenic sources can be local, regional, or international. Efforts to regulate anthropogenic 

emissions are mostly limited to inside the United States. Emissions from Mexico, Canada, and off-shore 

marine shipping emissions in the Pacific Ocean are examples of anthropogenic sources that have the 

potential contribute to visibility impairment in New Mexico, but are beyond the jurisdiction of the New 

Mexico Environment Department. 

Deciview Measurement

The Interagency Monitoring for Protected Visual Environments (IMPROVE) network provides States 

with a mechanism to monitor and collect data regarding the emissions of haze-impairing pollutants. Each 

IMPROVE monitor collects particulate concentration data which are converted into reconstructed light 

extinction through a complex calculation using the IMPROVE equation. Reconstructed light extinction 

(referred to as bext) is expressed in units of inverse megameters (1/Mm or Mm-1). The Regional Haze Rule 

requires the tracking of visibility conditions in terms of the Haze Index (HI) metric expressed in the 

deciview (dv) unit (40 CFR 51.308(d)(2)). Generally, a one deciview change in the haze index is 

considered a humanly perceptible change under ideal conditions, regardless of background visibility 

conditions. The relationship between extinction (Mm-1), haze index (dv) and visual range (mi) are 

indicated by the following scale: 

Baseline and Current Conditions

The Regional Haze Rule requires the calculation of baseline conditions for each Class I area. Baseline 

conditions are defined as the five year average (annual values for 2000 - 2004) of IMPROVE monitoring 

data (expressed in deciviews) for the most-impaired (20% worst) days and the least-impaired (20% best) 

days. For this regional haze plan submittal, the baseline conditions are the reference point against which 

visibility improvement is tracked. For future plan progress reports and updates, baseline conditions are 

used to calculate progress from the beginning of the regional haze program. Current conditions for the 

best and worst days are calculated from a multiyear average, based on the most recent 5-years of 

monitored data available. This value will be revised at the time of each periodic plan revision, and will be 

used to illustrate the amount of progress made since the last plan revision, and the amount of progress 

made from the baseline period of the program. 

Natural Conditions

The visibility that would exist under natural conditions (absent any anthropogenic impairment) would 

vary based on the contribution of natural sources and meteorological conditions on a given day. For that 

reason, natural conditions, as defined in this document, consist of a level of visibility (in deciviews) for 

both the most-impaired (20% worst) days and the least-impaired (20% best) days. Since no visibility 

monitoring data exists from the pre-anthropogenic impairment period, these estimates of natural 
New Mexico Section 308 Regional Haze SIP 9

conditions are based on EPA guidance on how to estimate natural conditions (EPA Document: Guidance 

for Estimating Natural Visibility Conditions Under the Regional Haze Rule, EPA-454/B-03-005, 

September 2003). 

Reasonable Progress Goals

For each Class I area the State must establish goals (measured in deciviews) that provide for reasonable 

progress towards achieving natural visibility conditions. The reasonable progress goals (RPG) are interim 

goals that represent incremental visibility improvement over time for the most-impaired (20% worst) days 

and no degradation in visibility for the least-impaired (20% best) days. The first regional haze plan that 

States must submit to EPA needs to include RPGs for the year 2018, also known as the "2018 milestone 

year". The State has flexibility in establishing different RPGs for each Class I area. In establishing the 

RPG, the State must consider four factors: 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 

potentially affected sources. States must demonstrate how these factors were taken into consideration in 

selecting the goal for each Class I area. 

Uniform Rate of Progress

The uniform rate of progress (URP) is the calculation of the slope of the line between baseline visibility 

conditions and natural visibility conditions over the 60-year period (Figure 1-4). For the first regional 

haze plan, the first benchmark is the deciview level that should be achieved in 2018. This is the 2018 

Milestone, and applies to both the 20% worst days and the 20% best days. 

Figure 1-4: Illustration of Uniform Rate of Progress

The URP calculation is as follows: 

• Compare baseline conditions to natural conditions. The difference between these two different 

conditions represents the amount of progress needed to reach natural visibility conditions. In this 

example, the State has determined that the baseline for the 20% worst days for the Class I area is 

10.2 dv and estimated that natural background is 5.7 dv, a difference of 4.5 dv. 

• Calculate the annual average visibility improvement needed to reach natural conditions by 2064 

by dividing the total amount of improvement needed by 60 years (the period between 2004 and 

2064). In this example, this value is 0.075 dv/yr. 
New Mexico Section 308 Regional Haze SIP 10

• Multiply the annual average visibility improvement needed by the number of years in the first 

planning period (the period from 2004 until 2018). In this example, this value is 1.05 dv. This is 

the uniform rate of progress that would be needed during the first planning period to attain natural 

visibility conditions by 2064. 

The URP is not a presumptive target. When establishing RPGs, the State may determine RPGs at greater, 

lesser or equivalent visibility improvement than the URP. In cases where the RPG results in less 

improvement in 2018 than the URP, the State must demonstrate why the URP is not achievable, and why 

the RPGs are "reasonable". 

Long-Term Strategy

The Regional Haze Rule also requires States to submit a long-term strategy (LTS) that includes 

enforceable measures to achieve RPGs. The LTS must identify all anthropogenic sources inside the State 

that affect Class I areas both inside and outside the State. The first long-term strategy will cover 10 to 15 

years, with reassessment and revision of those goals and strategies in 2018 and every 10 years thereafter. 

At a minimum, the following factors must be considered in developing the long-term strategy: 

• Measures to mitigate the impact of construction activities; 

• Emission limitations and schedules for compliance to achieve the RPG; 

• Source retirement and replacement schedules; 

• Smoke management techniques for agricultural and forestry burning, including plans to reduce 

smoke impacts; 

• Enforceability of emission limitations and control measures; and 

• The anticipated net affect on visibility due to projected changes in point, area, and mobile source 

emissions over the period addressed in the long term strategy. 

Best Available Retrofit Technology (BART)

Best Available Retrofit Technology (BART) requirements apply to certain older industrial facilities that 

began operating before national rules were adopted in 1977 to prevent new facilities from causing 

visibility impairment. BART applies to facilities built between 1962 and 1977, which have potential 

emissions greater than 250 tons per year, and which fall into one of 26 specific source categories. These 

facilities must be evaluated to see how much they contribute to regional haze and if retrofitting with 

controls is feasible and cost effective. 

The BART process consists of three-steps: (1) determining BART-eligibility; (2) determining if a source 

is "subject to BART" by conducting modeling of Class I visibility impacts; and (3) conducting an analysis 

of BART controls (retrofitting) for those sources subject to BART that contribute to regional haze. 

In determining BART controls, the State must take into account several factors, including the existing 

control technology in place at the source, the costs of compliance, energy and non-air environmental 

impacts of compliance, remaining useful life of the source, and the degree of visibility improvement that 

is reasonably anticipated from the use of such technology. 
New Mexico Section 308 Regional Haze SIP 11

CHAPTER 2: NEW MEXICO REGIONAL HAZE SIP DEVELOPMENT PROCESS 

The Regional Haze Rule contains requirements for state, federal, and tribal consultation. The New 

Mexico Regional Haze State Implementation Plan (SIP) was developed through a process of consultation 

with other States, Tribes, the Environmental Protection Agency (EPA), state and federal natural resource 

agencies, other stakeholders, and the public. This chapter contains a description of the requirements from 

the Regional Haze Rule. For additional details regarding individual consultation, see Chapter 11 (LongTerm Strategy). 

2.1 Federal Land Manager Consultation 

40 CFR Section 51.308(i) of the Regional Haze Rule requires coordination between states and the Federal 

Land Managers (FLMs). New Mexico has provided agency contacts to the FLMs as required under 

51.308(i)(1). During the development of this Plan, the FLMs were consulted in accordance with the 

provisions of 51.308(i)(2). 

Numerous opportunities were provided by the Western Regional Air Partnership for FLMs to participate 

fully in the development of technical documents developed by the WRAP and included in this Plan. This 

included the ability to review and comment on these analyses, reports, and policies. A summary of 

WRAP-sponsored meetings and conference calls is provided on the WRAP website at: 

http://www.wrapair.org/cal/calendar.php. 

The State of New Mexico has provided an opportunity for consultation, in person and at least 60 days 

prior to holding any public hearing on the SIP. As required by 40 CFR Section 51.308(i)(3), the FLM 

comments and State responses, as well as email exchanges from the FLM community to NMED 

explaining their review preferences of the SIP, will be submitted to EPA along with this Plan. 

40 CFR Sections 51.308(f)-(h) establish requirements and timeframes for states to submit periodic SIP 

revisions and reports that evaluate progress toward the reasonable progress goal for each Class I area. As 

required by 40 CFR Section 51.308(i)(4), New Mexico will continue to coordinate and consult with the 

FLMs during the development of these future progress reports and Plan revisions, as well as during the 

implementation of programs having the potential to contribute to visibility impairment in mandatory 

Class I areas. The progress and Plan reviews are to occur at five-year intervals, with a progress report 

between each required Plan revision. This consultation process shall provide on-going and timely 

opportunities to address the status of the control programs identified in this SIP, the development of 

future assessments of sources and impacts, and the development of additional control programs. The 

consultation will include the status of the following specific implementation items: 

1. Implementation of emissions strategies identified in the SIP as contributing to achieving 

improvement in the worst-day visibility. 

2. Summary of major new permits issued. 

3. Status of State actions to meet commitments for completing any future assessments or 

rulemakings on sources identified as likely contributors to visibility impairment, but not directly 

addressed in the most recent SIP revision. 

4. Any changes to the monitoring strategy or monitoring stations status that may affect tracking of 

reasonable progress. 
New Mexico Section 308 Regional Haze SIP 12

5. Work underway for preparing the 5-year review and/or 10-year revision. 

6. Items for FLMs to consider or provide support for in preparation for any visibility protection SIP 

revisions (based on a 5-year review or the 10-year revision schedule under EPA’s RHR). 

7. Summary of topics discussion (meetings, emails, other records) covered in ongoing 

communications between the State and FLMs regarding implementation of the visibility program. 

The consultation will be coordinated with the designated visibility protection program coordinators for 

the National Park Service, U.S. Fish and Wildlife Service, Bureau of Land Management, and the U.S. 

Forest Service. At a minimum, the State of New Mexico will meet with the Federal Land Managers on an 

annual basis through the Western Regional Air Partnership or an alternative Regional Planning 

Organization. 

2.2 State Consultation 

Pursuant to 40 CFR Section 51.308(d)(iv), the State of New Mexico consulted with other states through a 

regional planning organization, the Western Regional Air Partnership (WRAP), in developing reasonable 

progress goals. The WRAP is a collaborative effort of tribal governments, State governments and various 

Federal agencies to implement the Grand Canyon Visibility Transport Commission's recommendations 

and to develop the technical and policy tools needed by western states and tribes to comply with the U.S. 

EPA’s regional haze regulations. WRAP activities are conducted by a network of committees and forums 

composed of WRAP members and stakeholders who represent a wide range of viewpoints. The WRAP 

recognizes that residents have the most to gain from improved visibility and that many solutions are best 

implemented at the local, state, tribal or regional level with public participation. The following western 

states agreed to work together to address regional haze: Alaska, Arizona, California, Colorado, Idaho, 

Montana, Nevada, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming. 

The goals, objectives, management and decision making structure used by the WRAP during the 

development of data and policies incorporated into this plan are described in Work Plans and a Strategic 

Plan provided in Chapter 5, Technical Information and Data. 

This consultation effort began with all states in the WRAP region contributing information to a Technical 

Support System (TSS) which allows all states to better understand the causes of haze and the levels of 

contribution from all sources to each Class I area. This project involved many hours of consultation 

between states on regional emission inventories, monitoring and modeling to determine the causes of 

visibility impairment in each mandatory Class I Federal area in the regional planning area. WRAP forums 

involved in the technical consultation between states were as follows: 

Air Pollution Prevention Forum Mobile Sources Forum 

Dust Emissions Forum Sources In and Near Class I Areas Forum 

Economic Analysis Forum Stationary Sources Joint Forum 

Emissions Forum Technical Analysis Forum 

Fire Emissions Joint Forum 

The next step in state consultation in the development of reasonable progress goals was through the 

Implementation Work Group (IWG) of the WRAP. The State of New Mexico participated in the IWG 

which took the products of the technical consultation process discussed above and developed a process 

for establishing reasonable progress goals in the Western Class I areas. A description of that process and 

the determination of reasonable progress goals for each of the Class I areas in the State of New Mexico is 

described in Chapter 11. The following states agreed to work together through the IWG in the 
New Mexico Section 308 Regional Haze SIP 13

development of reasonable progress goals: Alaska, Arizona, California, Colorado, Hawaii, Idaho, 

Montana, Nevada, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming. 

Opportunities for consultation on development of reasonable progress goals provided through the WRAP 

Implementation Work Group have been documented in calls listed on the Implementation Work Group 

section of the WRAP website at: http://www.wrapair.org/forums/iwg/meetings.html. 

Pursuant to 40 CFR Section 51.308(d)(iv), the State of New Mexico also gave opportunity for 

neighboring states to comment on the State of New Mexico's reasonable progress goals for each Class I 

area located within the state. Opportunity for comment from other states was offered through a public 

hearing on the 2003 Section 309 SIP, held in accordance with 40 CFR Section 51.102. The following 

states in the WRAP region were notified of the SIP public hearing: Alaska, Arizona, California, Colorado, 

Idaho, Montana, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, Nevada, and 

Hawaii. The following states in the neighboring Central States Regional Planning Organization 

(CENRAP) were notified of the SIP public hearing: Iowa, Kansas, Minnesota, Missouri, Nebraska, 

Oklahoma, and Texas. 

Pursuant to 40 CFR 51.308(d)(3)(i), the State of New Mexico has participated in regional planning and 

coordination with other states in developing emission management strategies if emissions from within the 

state contribute to visibility impairment in a mandatory Class I Federal area outside the state, or if 

emissions from another state, regional planning organization, country, tribal area, or offshore location 

contribute to visibility impairment in any Class I Federal area within the state. This participation was 

through the WRAP. A more detailed description of the goals, objectives, management, and decisionmaking structure of the WRAP has been included in Chapter 5. The following WRAP forums have 

provided consultation opportunities between states on emission management strategies: 

Air Pollution Prevention Forum Mobile Sources Forum 

Dust Emissions Forum Sources In and Near Class I Areas Forum 

Economic Analysis Forum Stationary Sources Joint Forum 

Emissions Forum Technical Analysis Forum 

Fire Emissions Joint Forum 

Opportunities for consultation on emission strategies provided through the WRAP have been documented 

in calls and meetings on the WRAP website at: http://www.wrapair.org/cal/calendar.php. 

A description of the selected emission management strategies for the State of New Mexico is described in 

Chapter 12 of this Plan. The State of New Mexico views the development of coordinated emission 

management strategies to be a long-term commitment, and therefore, the State of New Mexico agrees to 

continue to participate in the WRAP or an alternative Regional Planning Organization in developing 

coordinated emission management strategies for SIP revisions in 2013 and 2018. 

Pursuant to 40 CFR 51.308(h)(2), the State of New Mexico has determined this first State Implementation 

Plan is adequate to ensure reasonable progress for the first planning period of the regional haze long-term 

planning effort which extends out to the year 2064. While emissions from sources outside of the State of 

New Mexico have resulted in a slower rate of improvement in visibility than the rate that would be 

needed to attain natural conditions by 2064, most of these emissions are beyond the control of any state in 

the regional planning area of the WRAP. The emission sources include: emissions from outside the 

WRAP domain; emissions from Mexico; emissions from wildfires and windblown dust; and emissions 

from CENWRAP and the Eastern U.S. A more detailed description and quantification of these 

uncontrolled emissions is included in the Source Apportionment and Regional Haze Modeling chapter of 
New Mexico Section 308 Regional Haze SIP 14

this SIP. Additional strategies to address emissions beyond the control of any state in the WRAP under 

the jurisdiction of EPA are discussed in the Long-Term Strategy chapter of this SIP. 

Through the WRAP consultation process the State of New Mexico has reviewed and analyzed the 

contributions from other states that reasonably may cause or contribute to visibility impairment in New 

Mexico's Class I areas. New Mexico acknowledges that the long-term strategies adopted by Colorado, 

Arizona, Colorado, and Texas in their SIPs and approved by EPA will include emission reductions from a 

variety of sources that will reduce visibility impairment in New Mexico’s Class I areas. 

2.3 Tribal Consultation 

Although tribal consultation is not required under the Regional Haze Rule, NMED views this as an 

important part of the consultation process, and actively pursued this during the development of the 

Regional Haze Plan. 

2.4 Public and Stakeholder Outreach 

New Mexico participated in numerous stakeholder meetings during the WRAP process and continues to 

meet with stakeholders. Additional stakeholder meetings will be held during the public comment period 

of this SIP proposal. 
New Mexico Section 308 Regional Haze SIP 15

CHAPTER 3: NEW MEXICO CLASS I AREAS 

This chapter provides an overview of New Mexico's nine Class I areas included in this document. 

3.1 Bandelier Wilderness Area 

Bandelier Wilderness Area encompasses approximately 90 percent of the Bandelier National Monument. 

Bandelier National Monument sits at the southern end of the Pajarito Plateau. The plateau was formed by 

two eruptions 1.6 and 1.4 million years ago. Bandelier ranges from 5,340 ft at the Rio Grande to the south 

and 10,199 ft at the summit of Cerro Grande to the north, almost a mile of elevation change in just under 

12 miles. This elevation gradient creates a unique diversity of habitats specific to Northern New Mexico. 

The diversity of habitats and quick access to water supported a relatively large population of Ancestral 

Pueblo people. Currently, piñon-juniper woodlands dominate in the southern parts of the park 

transitioning through ponderosa pine savannahs and forests finally reaching mixed conifer forests at the 

highest elevation. Scattered throughout the park are desert grasslands, montane meadows, and riparian 

areas in the canyon bottoms. Bandelier is home to a wide variety of wildlife. The backcountry trails at 

Bandelier climb in and out of deep canyons and cross large flat mesas, showcasing the entire spectrum of 

volcanic geology. 

Figure 3-1: Bandelier Wilderness 

Photograph courtesy of wilderness.net, no photographer identified 

3.2 Bosque del Apache National Wildlife Refuge 

The Bosque del Apache National Wildlife Refuge (NWR) is located along the Rio Grande near Socorro, 

New Mexico. The Refuge is located at the northern edge of the Chihuahuan desert, and straddles the Rio 

Grande. The heart of the Refuge is about 12,900 acres of moist bottomlands – 3,800 acres are active 

floodplain of the Rio Grande and 9,100 acres are areas where water is diverted to create extensive 

wetlands, farmlands, and riparian forests. The rest of Bosque del Apache NWR is made up of arid 

foothills and mesas, which rise to the Chupadera Mountains on the west and the San Pascual Mountains 

on the east. Most of these desert lands are preserved as wilderness areas. 

Managed by the U.S. Fish and Wildlife Service, Bosque del Apache NWR is an important link in the 

more than 500 refuges in North America. The goal of refuge management is to provide habitat and 
New Mexico Section 308 Regional Haze SIP 16

protection for migratory birds and endangered species and provide the public with a high quality wildlife 

and educational experience 

Figure 3-2: Bosque del Apache National Wildlife Refuge 

Photograph by Rita Bates 

3.3 Carlsbad Caverns National Park 

Carlsbad Caverns National Park is located in the Guadalupe Mountains, a mountain range that runs from 

west Texas into southeastern New Mexico. Elevations within the park rise from 3,595 feet in the lowlands 

to 6,520 feet atop the escarpment. Though there are scattered woodlands in the higher elevations, the park 

is primarily a variety of grassland and desert shrubland habitats. 

The park supports a diverse ecosystem, including habitat for many plants and animals that are at the 

geographic limits of their ranges. For example, the ponderosa pine reaches its extreme eastern limit here 

and several species of reptiles are at the edges of their distributions. 

The most famous of all the geologic features in the park are the caves. Carlsbad Caverns National Park 

contains more than 110 limestone caves, the most famous of which is Carlsbad Cavern. Carlsbad Cavern 

receives more than 300,000 visitors each year and offers a rare glimpse of the underground worlds 

preserved under the desert above. 
New Mexico Section 308 Regional Haze SIP 17

Figure 3-3: Carlsbad Caverns National Park 

Photograph courtesy of wilderness.net, photograph by Renee West 

3.4 Gila Wilderness 

Many different types of terrain are found in the Gila Wilderness. The northeastern and far eastern sections 

of the wilderness tend to consist of high mesas and rolling hills, ranging in elevation from approximately 

5,000 to 8,000 feet and cut by the deep canyons of the Gila River. The vegetation there consists primarily 

of mixed junipers and piñon pines, grasses, and at the higher elevations and on northern slopes, ponderosa 

pines. Vast stands of ponderosas cover the central part of the wilderness in this area. 

The river canyons offer spectacular cliffs, with mixed hardwoods and ponderosa pine growing along the 

riparian bottoms. The far western and southwestern sections of the Gila Wilderness consist of high 

mountains, particularly the Mogollon Range, with the highest elevation reaching 10,895 feet. Steep side 

canyons are common, and vegetation includes Douglas fir, ponderosa pine, aspens and a variety of ferns. 

The area includes the drainage basins of both Mogollon Creek and Turkey Creek. 
New Mexico Section 308 Regional Haze SIP 18

Figure 3-4: Gila Wilderness 

Photograph courtesy of wilderness.net, photograph by Steve Boutcher 

3.5 Pecos Wilderness 

The Pecos Wilderness extends through two Ranger Districts in the Santa Fe National Forest and into the 

Carson National Forest to the north. Within the boundaries of this expansive area are several landmarks 

including Truchas Peak which tops of at 13,103 feet, and the southern stretch of the Rocky Mountains. 

The terrain varies from open meadows in the Pecos River Valley to the steep canyons of the Sangre de 

Cristo mountain range. Wildlife ranges from deer and elk to big horn sheep, turkeys and grouse. It is not 

uncommon to run into cattle in the wilderness either, as some ranchers are permitted to graze their cattle 

in areas of the wilderness. There are 15 lakes, and eight major streams to sustain both plant and animal 

habitat, including the native Rio Grande Cutthroat Trout. 
New Mexico Section 308 Regional Haze SIP 19

Figure 3-5: Pecos Wilderness 

Photograph by Rita Bates 

3.6 Salt Creek Wilderness 

Salt Creek Wilderness Area is part of the Bitter Lake National Wildlife Refuge (NWR). Salt Creek 

Wilderness Area consists of river bottomlands, grasslands, sand dunes, and mixed shrub communities. 

Salt Creek Wilderness is made up of the watershed of Salt Creek which empties into the Pecos River in 

southeastern New Mexico. The refuge, Bitter Lake, is located near Roswell, NM, immediately west of the 

Pecos River. Virtually no waterfowl or waterbirds use the wilderness area of Salt Creek because it is 

devoid of wetlands other than the river and a dozen sinkholes. Two or three of the sinkholes contain rare 

fish – Pecos gambusia, which is endangered and the Pecos pupfish, a species of concern. Part of the 

reason Salt Creek was established as wilderness was to protect the scenic red bluffs on the north side of 

Salt Creek. 
New Mexico Section 308 Regional Haze SIP 20

Figure 3-6: Salt Creek Wilderness 

Photograph courtesy of wilderness.net, photograph by Jeff Howland 

3.7 San Pedro Parks Wilderness 

San Pedro Parks Wilderness began as a Primitive Area, established by the Chief of the Forest Service in 

1931. In 1941 the Secretary of Agriculture classified it as a Wild Area and set its acreage at 41,132 acres. 

It became the San Pedro Parks Wilderness as part of the original Wilderness Act in July 1964. 

Although the elevation averages 10,000 feet above sea level, San Pedro Parks Wilderness is known for 

high, moist, rolling mountaintops with numerous meadows and large grassy "parks." Dense stands of 

Engelmann spruce and mixed conifers compete for space with small stands of aspen. Clear streams 

wander through the forest openings and are usually abundant with trout. Frequent afternoon rainfall in 

July and August enables the meadows to flourish with bluegrass, oat grass, sedge, rush, and Rocky 

Mountain iris, only to be covered with snow come November. The Continental Divide National Scenic 

Trail crosses through the Wilderness from Cuba, New Mexico to the Carson National Forest. Its route 

follows along Los Pinos, Vacas, Penas Negras and Rio Capulin trails. 
New Mexico Section 308 Regional Haze SIP 21

Figure 3-7: San Pedro Parks Wilderness 

Photograph courtesy of Rita Bates 

3.8 Wheeler Peak Wilderness 

Lying along the top of the Sangre De Cristo mountain range, Wheeler Peak Wilderness is characterized 

by high rugged terrain. Elevations range from a low of 7,650 feet to a high of 13,161 feet at Wheeler 

Peak, the highest point in the State of New Mexico. Marmots, pikas, elk, mule deer, and golden eagles are 

found in the Wheeler Peak Wilderness. Above Taos Ski Valley, the Rio Hondo has a natural population 

of cutthroat trout as does Sawmill Creek. From the cottonwoods along the Rio Hondo to the Bristlecone 

pines guarding the peaks, Wheeler Peak Wilderness has almost all of the trees native to Northern New 

Mexico. Englemann spruce and sub-alpine fir are the predominant tree species. Because Wheeler Peak is 

so high, it is one of the only places in the State to see a true alpine "mat" as opposed to grasses that grow 

in other high alpine locales. The "mat" produces beautiful brilliantly colored flowers. The average annual 

precipitation is 34-40 inches, with about half the total from summer rains and half from winter snows. 

Average annual temperatures range between 80 degrees in the summer to 20 degrees below zero in the 

winter. 
New Mexico Section 308 Regional Haze SIP 22

Figure 3-8: Wheeler Peak Wilderness 

Photograph courtesy of wilderness.net, photograph by Steve Boutcher 

3.9 White Mountain Wilderness 

The White Mountain Wilderness lies entirely within the Smokey Bear Ranger District of the Lincoln 

National Forest. The Wilderness is 12.5 miles long and ranges from 4 to 12 miles wide. The Wilderness 

consists mainly of a long, northerly running ridge and its branches. The west side of the ridge is steep and 

extremely rugged with many extensive rock outcroppings, while the eastern side is more gentle with 

broader, forested canyons and a few tiny streams. Elevations range from a low of 6,400 feet at Three 

River Campground on the west side to a high of 11,580 feet near Lookout Mountain on the south. From 

Three Rivers to the crest there are four different life zones: piñon-juniper, ponderosa pine, mixed conifer, 

and sub-alpine forest. Abrupt changes in elevation, escarpments, rock outcrops, and avalanche chutes 

make for striking contrast and scenery. Interspersed along the crest are several meadows as well as some 

grass-oak savannahs, which are the result of fires. 

The weather too, is directly related to elevation. Springtime is usually dry and windy throughout the 

wilderness. July and August are the rainy months with frequent afternoon showers. In summer, while the 

desert is sweltering, the high country will likely be cool. Autumn is a beautiful time of year with oaks, 

maples, and aspens adding splashes of color to the hillsides. The days are usually cool and sunny with 

little wind. Winter in the wilderness brings a time of quiet beauty. Snowfall usually begins during the mid 

to latter part of November and can continue on through June. During the winter months, the higher 

elevations may be under six or more feet of snow while it is comfortably warm at the 6,000 feet level. 
New Mexico Section 308 Regional Haze SIP 23

Figure 3-9: White Mountain Wilderness 

Photograph courtesy of wilderness.net, photograph by Deidre St. Louis 
New Mexico Section 308 Regional Haze SIP 24

CHAPTER 4: REGIONAL HAZE MONITORING NETWORK

4.1 Overview of IMPROVE Network 

The Interagency Monitoring of Protected Visual Environments (IMPROVE) program is a cooperative 

measurement effort governed by a steering committee composed of representatives from Federal and 

regional-state organizations. The IMPROVE monitoring program was established in 1985 to aid the 

creation of Federal and State Implementation Plans for the protection of visibility in Class I areas (156 

national parks and wilderness areas) as stipulated in the 1977 amendments to the Clean Air Act. 

The objectives of IMPROVE are: (1) to establish current visibility and aerosol conditions in mandatory 

Class I areas; (2) to identify chemical species and emission sources responsible for existing man-made 

visibility impairment; (3) to document long-term trends for assessing progress towards the national 

visibility goal; (4) and with the enactment of the Regional Haze Rule, to provide regional haze monitoring 

representing all visibility-protected Federal Class I areas where practical. IMPROVE has also been a key 

participant in visibility-related research, including the advancement of monitoring instrumentation, 

analysis techniques, visibility modeling, policy formulation and source attribution field studies. 

Figure 4-1 shows a typical IMPROVE site, and Figure 4-2 shows the four separate modules used for 

sampling the different pollutant species. 

Figure 4-1: IMPROVE Monitor at Salt Creek Wilderness 

Picture from: U.S. Fish & Wildlife Service, 

http://www.fws.gov/refuges/AirQuality/ARIS/SWAN/monitoring.html 

Figure 4-2: Four Modules Used for Regional Haze Sampling 
New Mexico Section 308 Regional Haze SIP 25

The IMPROVE monitoring network consists of aerosol and optical samplers. The network began 

operating in 1988 with 20 monitoring sites in Class I areas. By 1999 the network expanded to 30 

monitoring sites in Class I areas and 40 sites using IMPROVE site and sampling protocols operated by 

Federal and State agencies. With the enactment of the Regional Haze Rules the IMPROVE network has 

been expanded by 80 new sites. 

Formula for Reconstructed Light Extinction 

The IMPROVE program has developed methods for estimating light extinction from speciated aerosol 

and relative humidity data. The three most common metrics used to describe visibility impairment are: 

• Extinction (bext) - Extinction is a measure of the fraction of light lost per unit length along a sight 

path due to scattering and absorption by gases and particles, expressed in inverse Megameters (Mm1). This metric is useful for representing the contribution of each aerosol species to visibility 

impairment and can be practically thought of as the units of light lost in a million meter distance. 

• Visual Range (VR) - Visual range is the greatest distance a large black object can be seen on the 

horizon, expressed in kilometers (km) or miles (mi). 

• Deciview (dv) - This is the metric used for tracking regional haze in the Regional Haze Rule. The 

deciview index was designed to be linear with respect to human perception of visibility. A one 

deciview change is approximately equivalent to a 10% change in extinction, whether visibility is good 

or poor. A one deciview change in visibility is generally considered to be the minimum change the 

average person can detect with the naked eye. 

The IMPROVE network estimates light extinction based upon the measured mass of various contributing 

aerosol species. EPA’s 2003 guidance for calculating light extinction is based on the original protocol 

defined by the IMPROVE program in 1988. (For further information, see 

http://vista.cira.colostate.edu/improve/Publications/GuidanceDocs/guidancedocs.htm.) In December 

2005, the IMPROVE Steering Committee voted to adopt a revised algorithm for use by IMPROVE as an 

alternative to the original approach. 

The revised algorithm for estimating light extinction is calculated as recommended for use by the 

IMPROVE steering committee using the following equations: 

bext ≈ 2.2 x fs(RH) x [Small Amm. Sulfate] + 4.8 x fL(RH) x [Large Amm. Sulfate] 

+ 2.4 x fs(RH) x [Small Amm. Nitrate] + 5.1 x fL(RH) x [Large Amm. Nitrate] 

+ 2.8 x [Small POM] + 6.1 x [Large POM] 

+ 10 x [EC] 

+ 1 x [Soil] 

+ 1.7 x fss(RH) x [Sea Salt] 

+ 0.6 x [CM] 

+ 0.33 x [NO2(ppb)] 

+ Rayleigh Scattering (Site Specific) 

The revised algorithm splits ammonium sulfate, ammonium nitrate, and POM concentrations into small 

and large size fractions as follows: 
New Mexico Section 308 Regional Haze SIP 26

4.2 New Mexico IMPROVE Monitoring Network 

In New Mexico, there are seven IMPROVE monitors listed in Table 4-1, that collect data for regional 

haze monitoring. There are nine Class I areas in New Mexico. The IMPROVE monitor for Carlsbad 

Caverns is located in Texas at Guadalupe Mountains National Park. The IMPROVE monitor for the 

Wheeler Peak Wilderness Area is used to represent visibility conditions at the nearby Pecos Wilderness. 

Although it is desirable to have one monitor for each Class I area, in most cases one monitor is 

“representative” of haze conditions in nearby Class I areas. Figure 4-3 shows the locations of the 

IMPROVE monitors in New Mexico. 

Table 4-1: IMPROVE Monitors in New Mexico 

Site Name Site Code Class I Area Sponsor Elevation 

MSL (ft) Start Date 

Bandelier NM BAND1 Bandelier Wilderness NPS 6,523 3/2/1988 

Bosque del Apache BOAP1 Bosque del Apache NWR FWS 4,560 4/5/2000 

Gila Wilderness GICL1 Gila Wilderness USFS 5,825 4/15/1994 

Guadalupe Mountains 

National Park (TX) GUMO1 Carlsbad Caverns NP NPS 5,338 3/2/1988 

Salt Creek SACR1 Salt Creek Wilderness FWS 3,518 4/6/2000 

San Pedro Parks SAPE1 San Pedro Parks Wilderness USFS 9,629 8/15/2000 

Wheeler Peak WHPE1 Wheeler Peak Wilderness, 

Pecos Wilderness USFS 11,043 8/15/2000 

White Mountain WHIT1 White Mountain Wilderness USFS 6,770 1/15/2002 
New Mexico Section 308 Regional Haze SIP 27

Figure 4-3: Map of New Mexico IMPROVE Sites 

4.2.1 Bandelier Wilderness 

The IMPROVE monitoring site representing the Bandelier Wilderness is BAND1, located near a fire 

tower on a ridge crest just outside of the eastern Wilderness boundary at an elevation of 6,517 feet. The 

BAND1 IMPROVE site is in an exposed location at an elevation near the middle of the range of 

Wilderness elevations and about 1,000 feet above the Rio Grande at the bottom of the canyon. Highest 

Wilderness elevations are typically about 1,000 feet above the monitoring site. BAND1 should be very 

representative of Wilderness locations, although lower Wilderness canyon bottom elevations, that 

comprise a very small part of the Wilderness area, may at times be within a lower surface inversion. 

Figure 4-4: Bandelier National Monument 
New Mexico Section 308 Regional Haze SIP 28

4.2.2 Bosque del Apache National Wildlife Refuge 

The IMPROVE monitoring site representing the Bosque del Apache is BOAP1, at the northern boundary 

near the Rio Grande, at an elevation of 1,383 m (4,536 ft). Given the narrow range of elevations in the 

Bosque del Apache, the BOAP1 IMPROVE should be very representative of aerosol concentration and 

composition within the class I area. 

Figure 4-5: Bosque del Apache National Wildlife Refuge 

4.2.3 Carlsbad Caverns National Park 

The IMPROVE monitoring site representing Carlsbad Caverns National Park is GUMO1 (Guadalupe 

Mountains), located about 25 km (15 mi) southwest in mountainous terrain near the crest of the Delaware 

Mountain Range at an elevation of 1,674 m (5,492 ft). It has good exposure to regional scale winds and 

may be influenced by wind blown dust from the dry lake (bare ground) in western Texas, as well as from 

the Mexican dry/barren region to the southwest. Near the monitoring site ground cover is desert 

vegetation (shrub land and grassland, etc). 

Aerosol data collected at the GUMO1 IMPROVE site should be very representative of aerosol 

characteristics within Carlsbad Caverns NP, especially at higher elevations. 
New Mexico Section 308 Regional Haze SIP 29

Figure 4-6: Map of Carlsbad Caverns National Park 

Figure 4-7: Guadalupe Mountains National Park 
New Mexico Section 308 Regional Haze SIP 30

4.2.4 Gila Wilderness 

The IMPROVE monitoring site representing the Gila Wilderness is GICL1, located on a bank just 

overlooking the Gila River in the east central part of the Wilderness, elevation 1,776 m (5,825 ft). The 

location of the Gila Wilderness IMPROVE site, GICL1, near the center of the Wilderness should make it 

representative of Wilderness locations when the atmosphere is well mixed. Its elevation is at the lower 

end of Wilderness elevations so that there may be times when it is isolated within shallow surface-based 

inversions that do not extend vertically to higher Wilderness elevations. 

Figure 4-8: Gila Wilderness 

4.2.5 Pecos Wilderness 

The IMPROVE monitoring site representing the Pecos Wilderness is WHPE1 (Wheeler Peak), located 

about 60 km (~ 40 mi) to the north near the Wheeler Peak Wilderness at an elevation of 3,372 m (11,060 

ft). The WHPE1 IMPROVE site is at a high elevation and should be very representative of Wilderness 

vistas at high elevations of the Sangre de Cristos, including the Pecos Wilderness. At this high elevation it 

may occasionally be above regional haze, and may also at times be isolated from lower valley bottom 

Wilderness locations contained within valley inversions. 
New Mexico Section 308 Regional Haze SIP 31

Figure 4-9: Pecos Wilderness

4.2.6 Salt Creek Wilderness 

The IMPROVE monitoring site representing the Salt Creek Wilderness is SACR1, located about 10 km (6 

mi) south of the Wilderness at an elevation of 1,077 m (3,533 ft). The SACR1 IMPROVE should be very 

representative of aerosol concentration and composition in the Salt Creek Wilderness since it is at the 

same elevation with no intervening terrain. 
New Mexico Section 308 Regional Haze SIP 32

Figure 4-10: Salt Creek Wilderness 

4.2.7 San Pedro Parks Wilderness 

The IMPROVE monitoring site representing the San Pedro Parks Wilderness is SAPE1, located just 

outside of the southern Wilderness boundary at an elevation of 2,919 m (9,574 ft). The SAPE1 

IMPROVE site, with elevation approximating Wilderness elevations, should be very representative of 

aerosol composition and concentration at most Wilderness locations, especially higher elevation locations 

in the main central part of the Wilderness. 
New Mexico Section 308 Regional Haze SIP 33

Figure 4-11: San Pedro Parks Wilderness 

4.2.8 Wheeler Peak Wilderness 

The IMPROVE monitoring site representing the Wheeler Peak Wilderness is WHPE1, located at a high 

point just outside the northern Wilderness boundary at an elevation of 3,372 m (11,060 ft). The WHPE1 

IMPROVE site is at a high elevation and should be very representative of Wilderness vistas. At this high 

elevation it may occasionally be above regional haze, and may also at times be isolated from lower valley 

bottom Wilderness locations contained within valley inversions. 
New Mexico Section 308 Regional Haze SIP 34

Figure 4-12: Wheeler Peak Wilderness 

4.2.9 White Mountain Wilderness 

The IMPROVE monitoring site representing the White Mountain Wilderness is WHIT1, located on a low 

ridge between Rio Bonito and Little Creek, near the Sierra Blanca regional airport about 15 km east of the 

Wilderness at an elevation of 2,050 m (6,724 ft). The WHIT1 IMPROVE site is on a well-exposed low 

ridge at an elevation near lower Wilderness elevations. It should be representative of Wilderness 

locations, especially during downslope flow conditions that bring Wilderness air towards the monitor via 

the Rio Bonito and Little Creek drainages. 
New Mexico Section 308 Regional Haze SIP 35

Figure 4-13: White Mountain Wilderness 

4.3 New Mexico Regional Haze Monitoring Commitments 

The State of New Mexico will rely upon a Regional Planning Organization’s provision of adequate 

technical support to meet its commitment to conduct the analyses necessary to meet the requirements of 

51.308(d)(4). 

The State of New Mexico will depend on the Inter-Agency Monitoring of PROtected Visual 

Environments (IMPROVE) monitoring program to collect and report aerosol monitoring data for longterm reasonable progress tracking as specified in 40 CFR 51.308(d)(4) of the Regional Haze Rule (RHR). 

Because the RHR is a long-term tracking program with an implementation period nominally set for 60 

years, NMED expects that the IMPROVE program will provide data based on the following goals: 

1. Maintain a stable configuration of the individual monitors and sampling sites, and stability in 

network operations for the purpose of continuity in tracking reasonable progress trends; 

2. Assure sufficient data capture at each site of all visibility-impairing species; 

3. Comply with EPA quality control and assurance requirements; and 

4. Prepare and disseminate periodic reports on IMPROVE program operations. 

The State of New Mexico is relying on the IMPROVE program to meet these monitoring operation and 

data collection goals, with the fundamental assumption that network data collection operations will not 

change, or if changed, will remain directly comparable to those operated by the IMPROVE program 

during the 2000-2004 RHR baseline period. Technical analyses and reasonable progress goals in this 

Implementation Plan for Regional Haze are based on data from these sites. As such, the State will ask that 

the IMPROVE program identify potential issues affecting RHR implementation trends and/or notify the 

State before changes in the IMPROVE program affecting a RHR tracking site are made. 
New Mexico Section 308 Regional Haze SIP 36

Further, the State of New Mexico notes that the human resources to operate these monitors are provided 

by Federal Land Management agencies. Beyond that in-kind contribution, resources for operation and 

sample analysis of a complete and representative monitoring network of these long-term reasonable 

progress tracking sites by the IMPROVE program are a collaborative responsibility of EPA, states, tribes, 

and FLMs and the IMPROVE program steering committee. The State of New Mexico will collaborate 

with the EPA, FLMs, other states, tribes, and the IMPROVE committee to assure adequate and 

representative data collection and reporting by the IMPROVE program. 
New Mexico Section 308 Regional Haze SIP 37

CHAPTER 5: TECHNICAL INFORMATION AND DATA 

This chapter describes the information relied upon in developing this plan. It describes the Western 

Regional Air Partnership (WRAP), committees and workgroups of the WRAP, and work products 

developed by WRAP that were used to develop this plan. 

5.1 WRAP and Technical Support 

The WRAP is a voluntary organization of western States, Tribes and federal agencies. It was formed in 

1997 as the successor to the Grand Canyon Visibility Transport Commission (GCVTC). It is a regional 

planning organization that provides assistance to western States to aid in the preparation of regional haze 

plans. The WRAP also implements regional planning processes to improve visibility in all Western Class 

I areas by providing the technical and policy tools needed by States and Tribes to implement the federal 

regional haze rule. 

The States that have been involved with WRAP include: Alaska, Arizona, California, Colorado, Idaho, 

Montana, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming. Tribal 

board members included Campo Band of Kumeyaay Indians, Confederated Salish and Kootenai Tribes, 

Cortina Indian Rancheria, Hopi Tribe, Hualapai Nation of the Grand Canyon, Native Village of 

Shungnak, Nez Perce Tribe, Northern Cheyenne Tribe, Pueblo of Acoma, Pueblo of San Felipe, and 

Shoshone-Bannock Tribes of Fort Hall. Representatives of other tribes participate on WRAP forums and 

committees. Participation is encouraged throughout the Western states and tribes. Federal participants are 

the Department of the Interior (National Park Service and Fish & Wildlife Service,) the Department of 

Agriculture (Forest Service), and the Environmental Protection Agency (EPA). 

5.1.1 WRAP Committees and Workgroups 

The following is a description of WRAP Committees and Workgroups that were operational during the 

development of the tools and information used in this SIP: 

Initiatives Oversight Committee 

The Initiatives Oversight Committee (IOC) is responsible for establishing and overseeing the work of 

forums that develop policies and programs to improve and protect our air quality. IOC forums are: 

The Air Pollution Prevention Forum 

The Air Pollution Prevention Forum is tasked with developing energy conservation initiatives and 

programs to expand the use of renewable energy sources, and encourage use of energy sources that 

minimize air pollution. 

The Economic Analysis Forum 

This Forum assisted with studies to evaluate the economic effects of air quality programs developed by 

the WRAP to diminish haze throughout the West. 

The Forum on Emissions In/Near Class 1 Areas 

This Forum looked at pollution sources in and near federally mandated Class 1 areas to determine their 

impact on visibility in those areas, and at mitigation and outreach options. 
New Mexico Section 308 Regional Haze SIP 38

The Mobile Sources Forum 

This Forum addressed the impact of motor vehicles and other mobile sources of pollution. For example, 

the Forum developed a plan presented to the WRAP that suggested a revision of U.S. Environmental 

Protection Agency rules regarding the production of low-sulfur fuel by small refineries. The Forum also 

recommended reforms for off-road emissions and diesel fuel. 

Technical Oversight Committee 

The Technical Oversight Committee's (TOC's) tasks are to identify and manage technical issues and to 

establish and oversee the work of forums and work groups that are developing and analyzing, scientific 

information related to air quality planning in the West. TOC forums and work groups include: 

The Air Quality Modeling Forum 

This Forum identifies, evaluates the performance of, and applies mathematical air quality models, which 

can be used to quantify the benefits of various air quality programs for reducing haze in the western 

United States. 

The Ambient Monitoring and Reporting Forum 

This Forum oversees the collection, use, and reporting of ambient air quality and meteorological 

monitoring data as needed to further the WRAP's overall goals. 

The Emissions Forum 

 This Forum is developing the first comprehensive inventory of haze-causing air emissions in the West, 

including a comprehensive emissions tracking and forecasting system. The forum also monitors trends in 

actual emissions and forecasts emissions reductions anticipated from current regulations and alternative 

control strategies. 

Attribution of Haze Work Group 

This Work Group is preparing guidance for States and tribes regarding both the types of pollution emitters 

and the regions in which pollutants contribute to visibility impairment in national parks and other Class 1 

areas. Three state and three tribal representatives form the work group along with all members of the 

Technical Oversight Committee and one representative each from the Initiatives Oversight Committee, 

the technical and joint forums and the Tribal Data Development Work Group. 

The Tribal Data Development Work Group 

This Work Group is identifying gaps in air quality data for tribal lands and working with tribes to collect 

that data. While some tribes have adequate staff and equipment for such an undertaking, many lack the 

manpower and technical resources to accomplish the work on their own. This Work Group is providing 

help by both enhancing the tribes' ability to collect the necessary data and establishing an organized way 

to standardize and catalogue the information for subsequent analysis. 

WRAP Working Committees and Forums

Implementation Work Group 

The purpose of this work group is to bring together State and tribal staff involved in the development of 

regional haze plans, to meet the requirements of the Regional Haze Rule. This work group discusses the 

major strategies associated with State and tribal regional haze plans, issues associated with plan 

development and rule interpretation, and coordination and consultation between states, tribes, EPA, and 

the FLMs on these topics. State representatives on this work group are the primary regional haze plan 

writers. 

Joint Technical and Policy Forums 

Joint Forums address both technical issues and policy. Both the TOC and the IOC have oversight. 
New Mexico Section 308 Regional Haze SIP 39

The Dust Emissions Joint Forum 

This Dust Emissions Joint Forum (DEJF) seeks to improve the methods for estimating dust emissions and 

their inputs into air quality models. The Forum also is examining the extent of dust impacts and strategies 

to reduce dust emissions. 

The Fire Emissions Joint Forum (FEJF) 

The Grand Canyon Commission confirmed that forest fires contribute significantly to visibility problems 

and that the use of prescribed fire is expected to increase as a forest management tool. The FEJF is 

developing measures to reduce the effects of emissions from prescribed fires and is examining emissions 

from all kinds of fire, whether ignited naturally or by humans. The Forum is considering public health and 

nuisance effects as well as visibility impacts. It will develop a tracking system for fire emissions and 

management techniques to minimize emissions. This Forum is working to coordinate with and gain the 

full cooperation of federal, tribal, State, and local agencies as well as private landowners, forest managers, 

and the agriculture community. 

The Stationary Sources Joint Forum 

The Stationary Sources Joint Forum (SSJF), formerly the Market Trading Forum, developed the details of 

an emissions trading program to achieve cost-effective reductions from industrial sources of sulfur 

dioxide. The Forum first set emission milestones for sulfur dioxide between now and 2018 and then 

designed a trading program to be triggered if these emission targets are exceeded. The Forum is now 

examining other industrial source emissions, such as oxides of nitrogen and particulate matter, and is 

assisting WRAP members in compliance with the stationary source provisions of the regional haze rule. 

5.1.2 WRAP Technical Support System 

The primary purpose of the WRAP TSS is to provide key summary analytical results and methods 

documentation for the required technical elements of the Regional Haze Rule, to support the preparation, 

completion, evaluation, and implementation of the Regional Haze Implementation Plans to improve 

visibility in Class I areas. The TSS provides technical results prepared using a regional approach, to 

include summaries and analysis of the comprehensive datasets used to identify the sources and regions 

contributing to regional haze in the WRAP region. 

The secondary purpose of the TSS is to be the one-stop-shop for access, visualization, analysis, and 

retrieval of the technical data and regional analytical results prepared by WRAP Forums and Workgroups 

in support of regional haze planning in the West. The TSS specifically summarizes results and 

consolidates information about air quality monitoring, meteorological and receptor modeling data 

analyses, emissions inventories and models, and gridded air quality/visibility regional modeling 

simulations. These copious and diverse data are integrated for application to air quality planning purposes 

by prioritizing and refining key information and results into explanatory tools. The WRAP TSS can be 

found at http://vista.cira.colostate.edu/tss/. 
New Mexico Section 308 Regional Haze SIP 40

CHAPTER 6: NEW MEXICO CLASS ONE AREA BASELINE, NATURAL CONDITIONS, 

AND UNIFORM RATE OF PROGRESS 

6.1 Baseline and Current Visibility Conditions 

EPA requires the calculation of baseline conditions [40 CFR 51.308(d)(2)(i) and (ii)]. The baseline 

condition for each New Mexico Class I area is defined as the five year average (annual values for 2000-

2004) of IMPROVE monitoring data (expressed in deciviews) for the most impaired (20% worst) days 

and the least impaired (20% best) days. For this regional haze SIP submittal, the baseline conditions are 

the reference point against which visibility improvement is tracked. For subsequent regional haze SIP 

updates (in the year 2018 and every 10 years thereafter), baseline conditions are used to calculate progress 

from the beginning of the regional haze program. 

Current conditions for the best and worst days are calculated from a multiyear average, based on the most 

recent five-year of monitored data available [40 CFR 51.308(f)(1)]. This value will be revised at the time 

of each periodic SIP revision and will be used to illustrate the following: 1) the amount of progress made 

since the last SIP revision, and 2) the amount of progress made from the baseline period of the program. 

New Mexico has established baseline visibility for the best and worst visibility days for each Class I area 

using on-site data from the IMPROVE monitoring sites. A five-year average (2000-2004) was calculated 

for each value (both best and worst). The calculations were made in accordance with 40 CFR 

51.308(d)(2) and EPA's Guidance for Tracking Progress Under the Regional Haze Rule (EPA-454/B-03-

004, September 2003). The IMPROVE II algorithm as described in Section 4.1 has been utilized for the 

calculation of Uniform Rate of Progress (URP) glide slopes for all Class I areas. Table 6-1 shows the 

baseline conditions for each IMPROVE monitor site in New Mexico. 

Table 6-1: Baseline Conditions for 20% Worst Days 

Mandatory Federal Class I Area IMPROVE 

Monitor 

Baseline Conditions 

for 20% Worst 

Visibility Days (dv) 

Bandelier Wilderness BAND1 12.22 

Bosque del Apache NWR BOAP1 13.8 

Carlsbad Caverns NP GUMO1 17.19 

Gila Wilderness GICL1 13.11 

Pecos Wilderness, Wheeler Peak Wilderness WHPE1 10.41 

Salt Creek Wilderness SACR1 18.03 

San Pedro Parks Wilderness SAPE1 10.17 

White Mountain Wilderness WHIT1 13.7 
New Mexico Section 308 Regional Haze SIP 41

Table 6-2: Baseline Conditions for 20% Best Days 

Mandatory Federal Class I Area IMPROVE 

Monitor 

Baseline Conditions 

for 20% Best 

Visibility Days (dv) 

Bandelier Wilderness BAND1 4.95 

Bosque del Apache NWR BOAP1 6.28 

Carlsbad Caverns NP GUMO1 5.95 

Gila Wilderness GICL1 3.31 

Pecos Wilderness, Wheeler Peak Wilderness WHPE1 1.22 

Salt Creek Wilderness SACR1 7.84 

San Pedro Parks Wilderness SAPE1 1.45 

White Mountain Wilderness WHIT1 3.55 

6.3 Monitoring Data 

Visibility impairing pollutants both reflect and absorb light in the atmosphere, thereby affecting the 

clarity of objects viewed at a distance by the human eye. Each haze pollutant has a different light 

extinction capability. In addition, relative humidity changes the effective light extinction of both nitrates 

and sulfates. Since haze pollutants can be present in varying amounts at different locations throughout the 

year, aerosol measurements of each visibility impairing pollutant are made every three days at the 

IMPROVE monitors located in or near each Class I area. 

In addition to extinction, the Regional Haze Rule requires another metric for analyzing visibility 

impairment, known as the "Haze Index", which is based on the smallest unit of uniform visibility changes 

that can be perceived by the human eye. The unit of measure of the deciview (dv). 

The haze pollutants reported by the IMPROVE monitoring program are sulfates, nitrates, organic carbon, 

elemental carbon, fine soil, and coarse mass. Summary data in Chapter 12 are provided for the worst and 

best days for baseline conditions from the eight IMPROVE monitors for the six haze pollutants. 

6.4 Natural Visibility Conditions 

The natural condition for each Class I area represents the visibility goal expressed in deciviews for the 

20% worst visibility days and the 20% best visibility days that would exist if there were no naturally or 

anthropogenic impairment. The 20% worst days natural conditions correspond to the visibility goals for 

each Class I area to be reached by 2064 [40 CFR 51.308(d)(iii)]. 

Table 6-3 provides the 2064 natural conditions goal in deciviews for each New Mexico Class I area. The 

natural conditions estimates were calculated consistent with EPA's Guidance for Estimating Natural 

Visibility Conditions Under the Regional Haze Rule (EPA-454/B-03-005, September 2003). The natural 

conditions goal can be adjusted as new visibility information becomes available. 
New Mexico Section 308 Regional Haze SIP 42

Table 6-3: 2064 Natural Conditions Goal for 20% Worst Days 

Mandatory Federal Class I Area IMPROVE 

Monitor 

2064 Natural Conditions for 

20% Worst Visibility Days (dv) 

Bandelier Wilderness BAND1 6.26 

Bosque del Apache NWR BOAP1 6.73 

Carlsbad Caverns NP GUMO1 6.65 

Gila Wilderness GICL1 6.66 

Pecos Wilderness, Wheeler Peak Wilderness WHPE1 6.08 

Salt Creek Wilderness SACR1 6.81 

San Pedro Parks Wilderness SAPE1 5.72 

White Mountain Wilderness WHIT1 6.8 

6.5 Uniform Progress 

For the 20% worst days, uniform progress for each Class I area is the calculation of a URP goal per year 

to achieve natural conditions in 60 years [40 CFR 51.308(d)(1)(i)(B)]. In this SIP submittal, the first 

benchmark is the 2018 deciview level based on the uniform rate of progress (URP) applied to the first 

fourteen years of the program. This is also shown in Table 6-3 in the column titled "2018 URP Goal". 

For the 20% worst days, the uniform rate of progress (URP) in deciviews per year (i.e., slope of the glide 

path) is determined by the following equation: 

URP = [Baseline Condition – Natural Condition]/60 years 

Multiplying the URP by the number of years in the first planning period calculates the uniform progress 

needed by 2018 in order to be on the glidepath towards achieving the 2064 natural conditions goal. 

2018 UPG = [URP] x [14 years] 

The first planning period spans 14 years, which includes the four years between the end of the baseline 

period and the SIP submittal plus the standard 10 year planning period for the subsequent SIP revisions. 

More detailed information on the 20% worst visibility days along with the glide slope associated with 

each Class I area can be found in Chapter 9. The calculations are consistent with EPA's Guidance for 

Setting Reasonable Progress Goals Under the Regional Haze Rule (June 1, 2007). 

For the 20% best visibility days at each Class I area, the State must ensure no degradation in visibility for 

the least impaired days over the same period. 

Table 6-4 shows the 2018 URP for the 20% worst days and the baseline that must not be exceeded over 

the years in order to maintain the best days. As with natural conditions, the URP can be adjusted as new 

visibility information becomes available. 
New Mexico Section 308 Regional Haze SIP 43

Table 6-4: Summary of Best and Worst Visibility Days for New Mexico Class I Areas 

20% Worst Days Visibility 20% Best Days Visibility 

New Mexico Class I Area Worst 

Days 

Baseline 

(dv) 

2018 

URP 

Goal 

(dv) 

2018 

Projected 

Visibility 

(dv) 

Best Days 

Baseline 

(dv) 

2018 

Projected 

Visibility 

(dv) 

2018 

Projection 

less than 

Baseline? 

Bandelier W 12.22 10.83 11.9 4.95 4.89 Y 

Bosque del Apache NWR 18.03 15.41 17.33 7.84 7.43 Y 

Carlsbad Caverns NP 17.19 14.73 16.93 5.95 6.14 N 

Gila W 13.11 11.61 15.17 3.31 3.45 N 

Pecos W, Wheeler Peak W 10.41 9.40 10.23 1.22 1.13 Y 

Salt Creek W 18.03 15.41 17.33 7.84 7.43 Y 

San Pedro Parks W 10.17 9.13 9.94 1.45 1.24 Y 

White Mountain W 13.7 12.09 13.27 3.55 3.42 Y 
New Mexico Section 308 Regional Haze SIP 44

CHAPTER 7: VISIBILITY IMPAIRMENT AT NEW MEXICO CLASS I AREAS 

This chapter provides a summary of visibility impairment at the Class I areas covered in this plan. Data 

was gathered from the IMPROVE monitoring sites for each Class I area. Each section includes a 

summary of the pollutants causing visibility impairment and a summary of the visibility improvement 

needed from baseline (2000-2004) to the 2018 URP goal, and to the 2064 natural condition goal. 

The visibility impairing pollutants described in this section include: ammonium nitrate, ammonium 

sulfate, elemental carbon, organic mass carbon, coarse mass, fine soil, and sea salt. Table 7-1 lists the 

pollutants, their abbreviations, and associated colors. Figure 7-1 and Figure 7-2 show, for the worst days 

and best days respectively, the impairment at each of the Class 1 areas during the baseline period due 

toeach visibility impairing pollutant. 

Table 7-1: IMPROVE Monitor Aerosol Composition 

Color Pollutant IMPROVE 

Abbreviation 

 Ammonium Nitrate (NO3) ammno3f_bext 

 Ammonium Sulfate (SO4) ammso4f_bext 

 EC (Elemental Carbon) ecf_bext 

 OMC (Organic Mass Carbon) omcf_bext 

 CM (Coarse Mass) cm_bext 

 Soil (Fine Soil) soilf_bext 

 Sea Salt seasalt_bext 

Figure 7-1: Reconstructed Aerosol Components for 20% Worst Days (2000-2004) 

Average Extinction for 20% Worst Days 

During Baseline Period (2000-2004)

0

10

20

30

40

50

60

BAND BOAP GICL GUMO SACR SAPE WHIT WHPE

Extinction 1/Mm

SeaSalt 

CM 

Soil 

EC 

OMC 

NO3 

SO4 
New Mexico Section 308 Regional Haze SIP 45

Figure 7-2: Reconstructed Aerosol Components for 20% Best Days (2000-2004) 

Average Extinction for 20% Best Days 

During Baseline Period (2000-2004)

0

2

4

6

8

10

12

14

BAND BOAP GICL GUMO SACR SAPE WHPE WHIT

Extinction 1/Mm

SeaSalt 

CM 

Soil 

EC

OMC 

NO3 

SO4 

7.1 Bandelier Wilderness 

The pollutants affecting visibility on the worst days at Bandelier Wilderness (as represented by BAND1 

IMPROVE monitor) are primarily sulfate, organic carbon, elemental carbon and coarse mass. Best days 

are dominated by sulfates, followed by organic carbon then coarse mass and elemental carbon. The 

average contributions are shown in Figure 7-3 for baseline conditions. 

Figure 7-3: Average Species Contribution to 20% Best and Worst Days Baseline 

Figure 7-4 shows the light extinction for all haze-impairing pollutants over the baseline period. Extinction 

due to sulfate varies seasonally, increasing during the summer months. A spike in organic carbon 

occurred in May of 2000, which correlates with the Cerro Grande Fire which started in the Bandelier 
New Mexico Section 308 Regional Haze SIP 46

Wilderness. Sources of coarse mass vary throughout the year while nitrate appear to increase in the winter 

months (November through February). 

Figure 7-4: Monthly Average Species Variation for All Sampled Days During the Baseline Period

Figure 7-5 shows the light extinction for the baseline, the URP, the 2018 projected visibility, and natural 

conditions for all aerosol pollutants. The projected visibility condition, based on modeling, does not meet 

the 2018 URP. 

Figure 7-5: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal 

Aerosol Composition Bandelier Class I Area

0

5

10

15

20

25

30

35

Base Conditions

(2000-2004)

2018 Uniform Rate

of Progress

2018 Projected

Visibility

2064 Visibility

Goal

Extinction 1/Mm

SeaSalt

CM 

Soil 

EC 

OMC 

NO3 

SO4 
New Mexico Section 308 Regional Haze SIP 47

7.2 Bosque del Apache National Wildlife Refuge 

Figure 7-6 shows that over the baseline period for best and worst days, the primary contributors to 

impairment are sulfate, organic carbon, and coarse mass. The visibility on best days has more impairment 

due to sulfate, whereas on worst days, organic carbon is the primary pollutant. 

Figure 7-6: Average Species Contribution to 20% Best and Worst Days Baseline 

Figure 7-7 shows the species variation for all IMPROVE sampled days over the baseline period. Light 

extinction due to sulfate and organic carbon varies seasonally, increasing during the summer. There is a 

spike in organic carbon extinction (6/2002), which may be due to fire. The Rodeo/Chediski Fire in 

Arizona started on June 18, 2002, and the Ponil Fire in New Mexico started on June 2, 2002. Nitrate 

extinction appears to increase during winter months. 

Figure 7-7: Monthly Average Species Variation for All Sampled Days during the Baseline Period 

Figure 7-8 shows the light extinction for the baseline, the URP, the 2018 projected visibility, and natural 

conditions for all aerosol pollutants. The projected visibility condition, based on modeling, does not meet 

the 2018 URP. 
New Mexico Section 308 Regional Haze SIP 48

Figure 7-8: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal 

Aerosol Composition Bosque Del Apache Class I Area

0

5

10

15

20

25

30

35

Base Conditions

(2000-2004)

2018 Uniform Rate

of Progress

2018 Projected

Visibility

2064 Visibility

Goal

Extinction 1/Mm

SeaSalt

CM 

Soil 

EC 

OMC 

NO3 

SO4 

7.3 Carlsbad Caverns National Park 

For the 20% best and worst days over the baseline period the primary contributors are sulfate, coarse 

mass, and organic carbon. Figure 7.9 shows that worst days are dominated by sulfate and coarse mass 

with a lesser contribution from organic carbon. The percentage contribution changes slightly on best days 

where the light extinction due to coarse mass is reduced, but sulfate and elemental carbon have a higher 

percentage. 

Figure 7-9: Average Species Contribution to 20% Best and Worst Days Baseline 
New Mexico Section 308 Regional Haze SIP 49

Figure 7-10 shows that sulfate and coarse mass increase during the summer. Extinction due to nitrates 

increased during the winter. 

Figure 7-10: Monthly Average Species Variation for All Sampled Days during the Baseline Period 

Figure 7-11 shows the light extinction for the baseline, the URP, the 2018 projected visibility, and natural 

conditions for all aerosol pollutants. The projected visibility condition, based on modeling, does not meet 

the 2018 URP. 

Figure 7-11: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal 

Aerosol Composition Carlsbad Caverns Class I Area

0

10

20

30

40

50

60

Base Conditions

(2000-2004)

2018 Uniform

Rate of Progress

2018 Projected

Visibility

2064 Visibility

Goal

Extinction 1/Mm

SeaSalt

CM 

Soil 

EC 

OMC 

NO3 

SO4 
New Mexico Section 308 Regional Haze SIP 50

7.4 Gila Wilderness 

Figure 7-12 shows that over the baseline period for best and worst days, the primary contributors to 

impairment are sulfate, organic carbon, and elemental carbon. The visibility on best days has more 

impairment due to sulfate, whereas on worst days, organic carbon is the primary pollutant. 

Figure 7-12: Average Species Contribution to 20% Best and Worst Days Baseline 

The average species variation for all sampled days over the baseline period is shown in Figure 7-13. 

Sulfates increase during the summer months, while nitrates increase during the winter. There are a couple 

of spikes in light extinction due to nitrates during December 2000 and January 2001. Organic carbon and 

coarse mass show a slight increase in light extinction during the summer. Elemental carbon shows a 

different pattern, increasing in the late fall and early winter. There is a spike in organic carbon extinction 

(6/2002), which may be due to fire. [must verify] 

Figure 7-13: Monthly Average Species Variation for All Sampled Days during the Baseline Period 

Figure 7-14 shows the light extinction for the baseline, the URP, the 2018 projected visibility, and natural 

conditions for all aerosol pollutants. The projected visibility condition, based on modeling, does not meet 

the 2018 URP. 
New Mexico Section 308 Regional Haze SIP 51

Figure 7-14: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal 

Aerosol Composition Gila Class I Area

0

5

10

15

20

25

30

35

40

45

Base Conditions

(2000-2004)

2018 Uniform Rate

of Progress

2018 Projected

Visibility

2064 Visibility

Goal

Extinction 1/Mm

SeaSalt

CM 

Soil 

EC 

OMC 

NO3 

SO4 

7.5 Pecos Wilderness, Wheeler Peak Wilderness 

Figure 7-15 shows that over one-third of the light extinction at the Wheeler Peak IMPROVE monitor is 

due to organic carbon on worst days. Sulfates are also a large contributor on worst days. Best days on 

dominated by sulfate, with organic carbon and coarse mass also contributing large percentages. 

Figure 7-15: Average Species Contribution to 20% Best and Worst Days Baseline 
New Mexico Section 308 Regional Haze SIP 52

For all IMPROVE sampled days sulfate, organic carbon, and coarse mass increase during the summer. 

Organic carbon showed a spike in July 2002. Extinction due to elemental carbon is relatively consistent 

throughout the year; however there are slight increases during the winter. Fires, especially the RodeoChediski Fire in Arizona, contributed a large spike in extinction in June 2002. 

Figure 7-16: Monthly Average Species Variation for All Sampled Days during the Baseline Period 

Figure 7-17 shows the light extinction for the baseline, the URP, the 2018 projected visibility, and natural 

conditions for all aerosol pollutants. The projected visibility condition, based on modeling, does not meet 

the 2018 URP. 

Figure 7-17: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal 

Aerosol Composition Wheeler Peak Class I Area

0

5

10

15

20

25

Base Conditions

(2000-2004)

2018 Uniform

Rate of Progress

2018 Projected

Visibility

2064 Visibility

Goal

Extinction 1/Mm

SeaSalt 

CM 

Soil

EC 

OMC 

NO3 

SO4 
New Mexico Section 308 Regional Haze SIP 53

7.6 Salt Creek Wilderness 

Figure 7-18 shows that light extinction at the Salt Creek Wilderness is due to a mix of sulfate, nitrate, and 

coarse mass. Organic carbon is also a large contributor on worst days. Best days on dominated by sulfate, 

with organic carbon and coarse mass also contributing large percentages. 

Figure 7-18: Average Species Contribution to 20% Best and Worst Days Baseline 

For all IMPROVE sampled days sulfate, organic carbon, and coarse mass increase during the summer. 

Extinction due to elemental carbon is relatively consistent throughout the year; however there are slight 

increases during the winter. 

Figure 7-19: Monthly Average Species Variation for All Sampled Days during the Baseline Period 

Figure 7-20 shows the light extinction for the baseline, the URP, the 2018 projected visibility, and natural 

conditions for all aerosol pollutants. The projected visibility condition, based on modeling, does not meet 

the 2018 URP. 
New Mexico Section 308 Regional Haze SIP 54

Figure 7-20: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal 

Aerosol Composition Salt Creek Class I Area

0

10

20

30

40

50

60

Base Conditions

(2000-2004)

2018 Uniform Rate

of Progress

2018 Projected

Visibility

2064 Visibility Goal

Extinction 1/Mm

SeaSalt

CM 

Soil 

EC 

OMC 

NO3 

SO4 

7.7 San Pedro Parks Wilderness 

Figure 7-21 shows that over the baseline period for best and worst days, the primary contributors to 

impairment are sulfate and organic carbon. The visibility on best days has more impairment due to 

sulfate, whereas on worst days, organic carbon is the primary pollutant. 

Figure 7-21: Average Species Contribution to 20% Best and Worst Days Baseline 

Figure 7-22 shows the species variation for all IMPROVE sampled days over the baseline period. Light 

extinction due to sulfate and organic carbon varies seasonally, increasing during the summer. There is a 

spike in organic carbon extinction (6/2002), which may be due to fire. The Rodeo/Chediski Fire in 
New Mexico Section 308 Regional Haze SIP 55

Arizona started on June 18, 2002, and the Ponil Fire in New Mexico started on June 2, 2002. Extinction 

due to sulfates appears to be decreasing over time. 

Figure 7-22: Monthly Average Species Variation for All Sampled Days during the Baseline Period 

Figure 7-23 shows the light extinction for the baseline, the URP, the 2018 projected visibility, and natural 

conditions for all aerosol pollutants. The projected visibility condition, based on modeling, does not meet 

the 2018 URP. 

Figure 7-23: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal 

Aerosol Compostion San Pedro Parks Class I Area

0

5

10

15

20

25

Base Conditions

(2000-2004)

2018 Uniform Rate

of Progress

2018 Projected

Visibility

2064 Visibility Goal

Extinction 1/Mm

SeaSalt

CM 

Soil 

EC 

OMC 

NO3 

SO4 
New Mexico Section 308 Regional Haze SIP 56

7.8 White Mountain Wilderness 

Figure 7-24 shows that about one-third of the light extinction at the White Mountain Wilderness is due to 

sulfate on worst days. Organic carbon and coarse mass are also large contributors on worst days. Best 

days are dominated by sulfate, with organic carbon and coarse mass also contributing large percentages. 

Figure 7-24: Average Species Contribution to 20% Best and Worst Days Baseline 

For all IMPROVE sampled days sulfate, organic carbon, and coarse mass increase during the summer. 

Organic carbon showed a spike in July 2002. Extinction due to elemental carbon is relatively consistent 

throughout the year; however there are slight increases during the winter. Fires, especially the RodeoChediski Fire in Arizona, contributed a large spike in extinction in June 2002. 

Figure 7-25: Monthly Average Species Variation for All Sampled Days during the Baseline Period 

Figure 7-26 shows the light extinction for the baseline, the URP, the 2018 projected visibility, and natural 

conditions for all aerosol pollutants. The projected visibility condition, based on modeling, does not meet 

the 2018 URP. 
New Mexico Section 308 Regional Haze SIP 57

Figure 7-26: Baseline Worst Day Aerosol Composition Compared to 2018 URP, 2018 Projected 

Visibility and 2064 Natural Conditions Goal 

Aerosol Composition White Mountain Class I Area

0

5

10

15

20

25

30

35

Base Conditions

(2000-2004)

2018 Uniform

Rate of Progress

2018 Projected

Visibility

2064 Visibility

Goal

Extinction 1/Mm

SeaSalt

CM 

Soil 

EC 

OMC 

NO3 

SO4 
New Mexico Section 308 Regional Haze SIP 58

CHAPTER 8: SOURCES OF VISIBILITY IMPAIRMENT 

8.1 Anthropogenic Sources 

Anthropogenic (human caused) sources of visibility impairment include anything directly attributable to 

human caused activities that produce emissions of visibility impairing pollutants. Some examples include 

transportation, agricultural activities, mining operations, and fuel combustion. Anthropogenic visibility 

conditions are not constant; they vary with changing human activities throughout the years. For purposes 

of this SIP anthropogenic emissions include those emissions originating within the boundaries of the U.S. 

but also include international anthropogenic emissions that originate outside of U.S. boundaries and are 

transported into the country. These include, but are not necessarily limited to, emissions from Canada, 

Mexico, and maritime shipping emissions from Pacific offshore sources. 

Although anthropogenic sources contribute to visibility impairment, international emissions cannot be 

regulated, controlled, or prevented by the states and are therefore beyond the scope of this planning 

document. Any reductions in international emission would likely fall under the purview of the U.S. EPA. 

8.2 Natural Sources 

Natural sources of visibility impairment include anything not directly attributed to human-caused 

emissions of visibility impairing pollutants. Natural events (e.g. windblown dust, wildfire, volcanic 

activity, biogenic emissions) also introduce pollutants that contribute to haze in the atmosphere. Natural 

visibility conditions are not constant; they vary with changing natural processes throughout the year. 

Specific natural events can lead to high short-term concentrations of visibility impairing particulate matter 

and its precursors. For purposes of this planning document, natural visibility conditions are represented 

by a long-term average of conditions expected to occur in the absence of emissions normally attributed to 

human activities. Natural visibility conditions reflect contemporary vegetated landscape, land-use 

patterns, and meteorological/climatic conditions. The 2064 visibility goal is the natural visibility 

conditions for the 20% worst natural conditions days. 

Natural sources contribute to visibility impairment but natural emissions cannot be realistically controlled 

or prevented by the states and therefore are beyond the scope of this planning document. Current methods 

of analysis of IMPROVE data do not provide a distinction between natural and anthropogenic emissions. 

8.3 Overview of Emission Inventory System – WRAP Technical Support System 

The WRAP developed the Technical Support System (TSS) as an internet access portal to all the data and 

analysis associated with the development of the technical foundations of regional haze plans for Western 

States. The TSS provides state, county, and grid cell level emissions information for typical criteria 

pollutants such as SO2, NOX, and other secondary particulate forming pollutants such as VOC and NH3. 

Eleven different emission inventories were developed comprising the following source categories: point, 

area, on-road mobile, off-road mobile, oil and gas, anthropogenic fire, natural fire, biogenic, road dust, 

fugitive dust, and windblown dust. More detailed information on the emission inventory information can 

be found on the WRAP TSS website at the following link: 

http://vista.cira.colostate.edu/TSS/Results/Emissions.aspx

Additional emission information, including regional emissions, can be found on the WRAP Regional 

Modeling Center website at the following link: http://pah.cert.ucr.edu/aqm/308/
New Mexico Section 308 Regional Haze SIP 59

During the WRAP process Western states and EPA agreed that the tremendous amount of data collected, 

analyzed, and maintained by the WRAP would be impracticable and nearly infeasible to include in 

individual technical support documents for individual states. For purposes of administrative efficiency, 

WRAP data and analyses that the member states are utilizing to develop their Regional Haze SIPs are 

available through the WRAP and the TSS website. 

8.4 New Mexico Emissions Data 

CFR 40.51.308(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. The pollutants 

inventoried by the WRAP that New Mexico will use include sulfur dioxide (SO2), volatile organic 

compounds (VOC), primary organic aerosol (POA), elemental carbon (EC), fine particulate matter (SoilPM2.5), coarse particulate matter (PM2.5 to PM10), and ammonia (NH3). An inventory was developed for 

the baseline year 2002 and projections of future emissions have been made for 2018. New Mexico will 

provide updates to WRAP on this inventory on a periodic basis. A summary of the inventory results 

follows. 

Emission inventories are developed for all of the species or pollutants known to directly or indirectly 

impact visibility. Inventories are used with air quality models to predict concentrations of pollutants at 

future dates. WRAP developed emission inventories with input and data provided by Western states and 

stakeholders. A description of the development and content of the emission inventories can be found on 

the WRAP TSS website at the following link: http://vista.cira.colostate.edu/TSS/Results/Emissions.aspx

Dispersion modeling predicts daily atmospheric concentrations of pollutants for the baseline year and 

these modeled results are compared to monitored data taken from the IMPROVE network. A second 

inventory is created to predict emission in 2018 based on expected controls, growth, or other factors. 

Additional inventories are created for future years to simulate the impact of different control strategies. 

The process for inventorying sources is similar for all species of interest. The number and types of 

sources is identified by various methods. For example, major stationary sources report actual annual 

emission rates to the EPA national emission database. New Mexico collects annual emission data from 

both major sources. This information is used as input into the emissions inventory. In other cases, such as 

mobile sources, an EPA mobile source emissions model is used to develop emission projections. 

Population, employment, and household data are used in other parts of the emission modeling to 

characterize emissions from area sources such as home heating. Thus, for each source type, emissions are 

calculated based on an emission rate and the amount of time the source is operating. Emission rates can 

be based on actual measurements from the source, or EPA emission factors based on data from tests of 

similar types of emission sources. In essence all sources go through the same process. The number of 

sources is identified, emission rates are determined by measurements of those types of sources and the 

time of operation is determined. By multiplying the emission rate times the hours of operation in a day, a 

daily emission rate can be calculated. 

The following tables represent New Mexico emissions posted on the TSS. “Plan02d” means baseline 

emissions for the years 2000-2004. “Prp18b” means the projected emissions for 2018. 
New Mexico Section 308 Regional Haze SIP 60

Table 8-1: New Mexico SO2 Emission Inventory – 2002 & 2018 

New Mexico Planning and Baseline Emission Inventories 

Source Category New Mexico SOx 

Plan02d (tpy) Prp18b (tpy) Net Change (%) 

Point 36,736 29,640 -19 

Anthro Fire 94 72 -24 

Natural Fire 2,727 2,727 0 

Area 2,383 3,983 67 

Wrap Area O&G 250 12 -95 

On-Road Mobile 1,643 252 -85 

Off-Road Mobile 3,540 228 -94 

Road Dust 4 5 34 

Fugitive Dust 5 6 21 

Total 47,381 36,924 -22 

Table 8-2: New Mexico NOX Emission Inventory – 2002 & 2018 

New Mexico Planning and Baseline Emission Inventories 

Source Category New Mexico NOx 

Plan02d (tpy) Prp18b (tpy) Net Change (%) 

Point 98,115 69,996 -29 

Anthro Fire 395 263 -34 

Natural Fire 8,608 8,607 0 

Biogenic 41,950 41,950 0 

Area 13,023 16,781 29 

Wrap Area O&G 56,196 74,648 33 

On-Road Mobile 51,623 15,360 -70 

Off-Road Mobile 42,277 26,606 -37 

Road Dust 1 1 0 

Fugitive Dust 5 6 0 

Total 312,193 254,218 -19 
New Mexico Section 308 Regional Haze SIP 61

Table 8-3: New Mexico VOC Emission Inventory – 2002 & 2018 

New Mexico Planning and Baseline Emission Inventories 

Source Category New Mexico VOC 

Plan02d (tpy) Prp18b (tpy) Net Change (%) 

Point 17,277 25,871 50 

Anthro Fire 607 387 -36 

Natural Fire 18,834 18,833 0 

Biogenic 1,007,457 1,007,457 0 

Area 37,106 53,163 43 

Wrap Area O&G 224,156 267,846 0 

On-Road Mobile 28,897 11,679 -60 

Off-Road Mobile 10,462 6,765 -35 

Total 1,344,795 1,392,002 4 

Table 8-4: New Mexico Primary Organic Aerosol (POA) Emission Inventory – 2002 & 2018 

New Mexico Planning and Baseline Emission Inventories 

Source Category New Mexico Primary Organic Aerosol 

Plan02d (tpy) Prp18b (tpy) Net Change (%) 

Point 968 240 -75 

Anthro Fire 681 441 -35 

Natural Fire 16,257 16,256 0 

Area 2,023 2,279 13 

On-Road Mobile 497 508 2 

Off-Road Mobile 471 281 -40 

Road Dust 102 136 34 

Fugitive Dust 268 275 2 

Total 21,268 20,417 -4 
New Mexico Section 308 Regional Haze SIP 62

Table 8-5: New Mexico Elemental Carbon (EC) Emission Inventory – 2002 & 2018 

New Mexico Planning and Baseline Emission Inventories 

Source Category New Mexico Elemental Carbon 

Plan02d (tpy) Prp18b (tpy) Net Change (%) 

Point 12 13 4 

Anthro Fire 123 85 -31 

Natural Fire 3,291 3,291 0 

Area 244 287 17 

On-Road Mobile 586 160 -73 

Off-Road Mobile 1,355 662 -51 

Road Dust 8 11 34 

Fugitive Dust 18 19 2 

Total 5,638 4,526 -20 

Table 8-6: New Mexico Soil (PM Fine/PM2.5) Emission Inventory – 2002 & 2018 

New Mexico Planning and Baseline Emission Inventories 

Source Category New Mexico Fine PM 

Plan02d (tpy) Prp18b (tpy) Net Change (%) 

Point 1,160 1,126 -3 

Anthro Fire 87 44 -49 

Natural Fire 1,220 1,220 0 

Area 2,318 2,973 28 

Road Dust 1,192 1,591 33 

Fugitive Dust 5,158 5,446 6 

WB Dust 16,305 16,305 0 

Total 27,440 28,705 5 

Table 8-7: New Mexico Coarse Mass (PM Coarse) Emission Inventory – 2002 & 2018 

New Mexico Planning and Baseline Emission Inventories 

Source Category New Mexico Coarse PM 

Plan02d (tpy) Prp18b (tpy) Net Change (%) 

Point 1,953 1,731 -11 

Anthro Fire 105 63 -41 

Natural Fire 5,398 5,398 0 

Area 534 723 36 

On-Road Mobile 306 357 0 

Road Dust 10,206 13,618 33 

Fugitive Dust 36,306 41,429 14 

WB Dust 146,747 146,747 0 

Total 201,555 210,066 4 
New Mexico Section 308 Regional Haze SIP 63

Table 8-8: New Mexico Ammonia (NH3) Emission Inventory – 2002 & 2018 

New Mexico Planning and Baseline Emission Inventories 

Source Category New Mexico Ammonia 

Plan02d (tpy) Prp18b (tpy) Net Change (%) 

Point 51 66 30 

Anthro Fire 75 42 -44 

Natural Fire 1,873 1,873 0 

Area 29,112 29,343 1 

On-Road Mobile 1,605 2,139 33 

Off-Road Mobile 23 32 38 

Total 32,740 33,495 2 
New Mexico Section 308 Regional Haze SIP 64

CHAPTER 9: VISIBILITY MODELING AND SOURCE APPORTIONMENT 

9.1 Modeling Overview 

CMAQ 

The Regional Modeling Center (RMC) Air Quality Modeling Group is responsible for regional haze 

modeling for the WRAP. The RMC is located at the University of California – Riverside in the College of 

Engineering Center for Environmental Research and Technology. 

The RMC modeling analysis is based on a model domain comprising the continental U.S. using the 

Community Multi-Scale Air Quality (CMAQ) model. The EPA developed the CMAQ modeling system 

in the late 1990s. CMAQ was designed as a "one atmosphere" modeling system to encompass modeling 

of multiple pollutants and issues, including ozone, PM, visibility, and air toxics. This is in contrast to 

many earlier air quality models that focused on single-pollutant issues (e.g., ozone modeling by the Urban 

Airshed Model). CMAQ is an Eulerian Model; it is a grid-based model is which the frame of reference is 

a fixed, three-dimensional (3-D) grid with uniformly sized horizontal grid cells and variable vertical layer 

thicknesses. The key science processes included in CMAQ are emissions, advection and dispersion, 

photochemical transformation, aerosol. Thermodynamics and phase transfer, aqueous chemistry, and wet 

and dry deposition of trace species. 

The RMC developed air quality modeling inputs including annual meteorology and emissions inventories 

for a 2002 actual emissions base case (Base02), a planning case to represent the 2000 – 2004 baseline 

period (Plan02), and a 2018 base case (Base 18) of projected emissions using factors known at the end of 

2005. All emission inventories were developed during the Sparse Matrix Operator Kernel Emission 

(SMOKE) modeling system. These inventories were revised during the development process. The 

development of these emission scenarios is documented under the emissions inventory sections of the 

TSS. 

The 2018 visibility projections (PRP18b) were developed using the Plan02d and Base 18b CMAQ 36-km 

modeling results. Projections were made using relative response factors (RRFs), which are defined as the 

ratio of the future-year modeling results to the current year modeling results. The calculated RRFs are 

applied to the baseline observed visibility conditions to project future year observed visibility. 

The CMAQ modeling for PRP18b included emissions after reductions from the following programs and 

regulations: 

• Smoke Management Program accounted for using Emissions Reduction Techniques (ERTs) 

applied to the 2000-2004 average fire emissions. 

• New permits and State/EPA consent agreements since 2002 reviewed with each State through 

2007. 

• Ozone and PM10 SIPs in place within the WRAP region 

• State Oil and Gas emission control programs. 

• Mobile sources: 

o Heavy Duty Diesel (2007) Engine Standard 

o Tier 2 Tailpipe 

o Large Spark Ignition and Recreational Vehicle rule 

o Nonroad Diesel Rule 

• Combustion Turbine and Industrial Boiler/Process Heater/RICE MACT 

• Known BART control in the WRAP region. 

• Presumptive SO2 BART for EGUs in the WRAP region. 
New Mexico Section 308 Regional Haze SIP 65

Generally, emission inputs were prepared by individual States and Tribes for point, area, and most dust 

emissions categories. The following WRAP Forums were relied upon to summarize this data and provide 

it to the RMC. 

• Point Source emissions were obtained from a project commissioned by the Stationary Source 

Joint Forum and the Emission Forum. 

• Area Source emissions were obtained from a project commissioned by the Stationary Source 

Joint Forum and the Emission Forum. 

• Mobile Source emissions were from a project commissioned by the Emissions Forum. 

• Fire (natural and anthropogenic) emissions were from projects commissioned by the Fire 

Emissions Joint Forum 

• Ammonia, Dust, & Biogenic emissions were from projects commissioned by the Dust Emissions 

Joint Forum and the Modeling Forum. 

• Emissions from Pacific Offshore shipping were from a project conducted by the RMC. 

• Other emissions from North America were from projects commissioned by the Emission Forum 

and the Modeling Forum. The Mexico emission are from 1999 and were held constant for 2018. 

Canada emissions are from 2000 and were held constant for 2018. 

• Boundary conditions reaching North America from the rest of the world were from a project 

commissioned by the VISTAS Regional Planning Organization, on behalf of the five regional 

planning organizations working on regional haze. 

The 2018 Preliminary Reasonable Progress, version B (PRP18b), makes a second revision to the 2018 

emissions inventory projections for point and area sources in the WRAP region to provide a more current 

assessment of the reasonable progress toward visibility goals by the WRAP. The PRP18b addresses 

changes that occurred since January 2007 in the following areas. 

• BART determinations (or expected BART control levels where BART had not been finalized); 

• Projections of "future" fossil-fuel plants needed to achieve 2018 federal electrical generation 

demand forecasts; 

• New rulemaking, permit limits, and consent decrees; and 

• Other outstanding issues that were identified by the federal, state, or local agencies within the 

WRAP domain as needing to be corrected or updated. 

PSAT 

The RMC also developed the Particulate Matter Source Apportionment Technology (PSAT) algorithm in 

the Comprehensive Air Quality Model with extensions (CAMx) model to assess source attribution. The 

PSAT analysis is used to attribute particle species, particularly sulfate and nitrate from a specific location 

within the WRAP modeling domain. The PSAT algorithm applies nitrate-sulfate-ammonia chemistry to a 

system of tracers or "tags" to track the chemical transformations, transport and removal of emissions. 

Each state or region (i.e., Mexico, Canada) is assigned a unique number that is used to tag the emissions 

from each 36-kilometer grid cell within the WRAP modeling domain. Due to time and computational 

limitations, only point, mobile, area and fire emissions were tagged. 

The PSAT algorithm was also used, in a limited application (e.g. no state or regional attribution) due to 

resource constraints, to track natural and anthropogenic species of organic aerosols at each Class 1 Area. 

The organic aerosol tracer tracked both primary and secondary organic aerosols (POA & SOA). 
New Mexico Section 308 Regional Haze SIP 66

Weighted Emissions Potential 

The Weighted Emissions Potential (WEP) is a screening tool that helps to identify source regions that 

have the potential to contribute to haze formation at specific Class I areas. Unlike PSAT, this method 

does not account for chemistry or deposition. The WEP combines emissions inventories, wind patterns, 

and residence time of air mass over each area where emissions occur, to estimate the percent contribution 

of different pollutants. Like PSAT, the WEP tool compares baseline (2000-2004) to 2018, to show the 

improvement expected by the 2018 URP, for sulfate, nitrate, organic carbon, elemental carbon, fine PM, 

and coarse PM. 

9.2 Summary of Modeling Results for CMAQ 

This section provides the visibility projections for New Mexico's Class I areas using the CMAQ model. 

The projections were calculated from modeled results by multiplying a species-specific relative response 

factor (RRF) with the baseline monitored results, and then converting to extinction and deciview. The 

RRF is defined as the ratio of future-to-current modeled mass. The projected visibility conditions are used 

to define the reasonable progress goals found in Chapter 11. 

Table 9-1 provides the 2018 uniform progress for each Class I area and the visibility modeling projection 

for 2018 for both 20% worst and 20% best days. None of New Mexico's Class I areas are projected to 

meet the URP for 2018, although all but one (Gila Wilderness) are projected to be below baseline 

conditions. The following section provides a breakdown of the visibility impairment for each pollutant. 

Modeling shows degradation on best days for two of the IMPROVE monitors. This is addressed in the 

Chapter 12 discussion regarding the Long Term Strategy. 

Table 9-1: Summary of CMAQ Modeling Progress Towards 2018 

20% Worst Days Visibility 20% Best Days Visibility 

New Mexico Class I Area 

2000-

2004 

Baseline 

(dv) 

2018 

URP 

Goal 

(dv) 

2018 

Projected 

Visibility 

(dv) 

2000-2004 

Baseline 

(dv) 

2018 

Projected 

Visibility 

(dv) 

2018 

Projection 

less than 

Baseline? 

Bandelier W 12.22 10.83 11.9 4.95 4.89 Y 

Bosque del Apache NWR 18.03 15.41 17.33 7.84 7.43 Y 

Carlsbad Caverns NP 17.19 14.73 16.93 5.95 6.14 N 

Gila W 13.11 11.61 15.17 3.31 3.45 N 

Pecos W, Wheeler Peak W 10.41 9.40 10.23 1.22 1.13 Y 

Salt Creek W 18.03 15.41 17.33 7.84 7.43 Y 

San Pedro Parks W 10.17 9.13 9.94 1.45 1.24 Y 

White Mountain W 13.7 12.09 13.27 3.55 3.42 Y 

9.2.1 CMAQ Modeling by Pollutant 

The following graphs and tables show the breakdown of visibility impairment for each pollutant on 20% 

worst days. The visibility projections for the individual pollutants at each Class I area shows that most 

pollutants will not meet their respective 2018 goal for worst days. The tables summarize the impairment 

of each pollutant and identify the relative impact from anthropogenic or non-anthropogenic pollutants. 
New Mexico Section 308 Regional Haze SIP 67

The results of the breakdown show that nitrate (anthropogenic) has greater improvement than the other 

pollutants. With the exceptions of organic carbon and fine soil, all other pollutants are below the baseline 

condition. The tables also show that the primary contributors to extinction are organic carbon, sulfate, and 

coarse mass. The sulfate is likely from industrial sources while the organic carbon can be attributed 

mostly to fire and coarse mass from natural sources. 

Figure 9-1: URP by Pollutant on 20% Worst Days for Bandelier Wilderness 

Table 9-2: Pollutant Breakdown on 20% Worst Days for Bandelier Wilderness 

Bandelier Wilderness 

Pollutant 2000-2004 

Baseline 

(Mm-1) 

2018 URP 

Goal 

(Mm-1) 

2018 Projected 

Visibility 

(Mm-1) 

2064 Natural 

Conditions 

(Mm-1) 

2018 under 

URP Goal? 

Sulfate 6.89 5.17 5.99 0.65 No 

Nitrate 2.51 2.09 2.53 0.81 No 

Organic Carbon 14.23 11.32 14 4.01 No 

Elemental Carbon 3.15 2.43 2.65 0.32 No 

Fine Soil 1.12 1.11 1.43 1.07 No 

Coarse Mass 2.93 3.09 NA 3.64 NA 

Sea Salt 0.24 0.24 NA 0.24 NA 

NA - Visibility projections not available due to poor model performance. 
New Mexico Section 308 Regional Haze SIP 68

Figure 9-2: URP by Pollutant on 20% Worst Days for Bosque del Apache NWR 

Table 9-3: Pollutant Breakdown on 20% Worst Days for Bosque del Apache NWR 

Bosque del Apache NWR 

Pollutant 2000-2004 

Baseline 

(Mm-1) 

2018 URP 

Goal 

(Mm-1) 

2018 Projected 

Visibility 

(Mm-1) 

2064 Natural 

Conditions 

(Mm-1) 

2018 under 

URP Goal? 

Sulfate 7.51 5.57 7.27 0.58 No 

Nitrate 3.24 2.68 3.02 1.01 No 

Organic Carbon 8.73 7.24 8.6 3.15 No 

Elemental Carbon 2.6 2.02 2.15 0.29 No 

Fine Soil 1.94 1.73 2.16 1.06 No 

Coarse Mass 6.69 5.90 NA 3.56 NA 

Sea Salt 0.19 0.21 NA 0.25 NA 

NA - Visibility projections not available due to poor model performance. 
New Mexico Section 308 Regional Haze SIP 69

Figure 9-3: URP by Pollutant on 20% Worst Days for Carlsbad Caverns NP 

Table 9-4: Pollutant Breakdown on 20% Worst Days for Carlsbad Caverns NP 

Carlsbad Caverns National Park 

Pollutant 2000-2004 

Baseline 

(Mm-1) 

2018 URP 

Goal 

(Mm-1) 

2018 Projected 

Visibility 

(Mm-1) 

2064 Natural 

Conditions 

(Mm-1) 

2018 under 

URP Goal? 

Sulfate 16.51 11.50 13.92 0.8 No 

Nitrate 3.81 3.06 4.27 0.89 No 

Organic Carbon 6.73 5.81 6.88 3.13 No 

Elemental Carbon 1.34 1.07 1.19 0.23 No 

Fine Soil 4.37 3.57 5.26 1.27 No 

Coarse Mass 16.02 12.66 NA 4.39 NA 

Sea Salt 0.1 0.11 NA 0.14 NA 

NA - Visibility projections not available due to poor model performance. 
New Mexico Section 308 Regional Haze SIP 70

Figure 9-4: URP by Pollutant on 20% Worst Days for Gila Wilderness 

Table 9-5: Pollutant Breakdown on 20% Worst Days for Gila Wilderness 

Gila Wilderness 

Pollutant 2000-2004 

Baseline 

(Mm-1) 

2018 URP 

Goal 

(Mm-1) 

2018 Projected 

Visibility 

(Mm-1) 

2064 Natural 

Conditions 

(Mm-1) 

2018 under 

URP Goal? 

Sulfate 6.87 5.13 7.67 0.58 No 

Nitrate 0.91 0.86 0.49 0.7 No 

Organic Carbon 16 12.67 23.26 4.46 No 

Elemental Carbon 3.17 2.46 5.7 0.41 No 

Fine Soil 1.45 1.40 2.14 1.21 No 

Coarse Mass 2.85 3.00 NA 3.53 NA 

Sea Salt 0.07 0.09 NA 0.16 NA 

NA - Visibility projections not available due to poor model performance. 
New Mexico Section 308 Regional Haze SIP 71

Figure 9-5: URP by Pollutant on 20% Worst Days for Pecos Wilderness, Wheeler Peak Wilderness 

Table 9-6: Pollutant Breakdown on 20% Worst Days for Pecos Wilderness, Wheeler Peak 

Wilderness 

Pecos Wilderness, Wheeler Peak Wilderness 

Pollutant 2000-2004 

Baseline 

(Mm-1) 

2018 URP 

Goal 

(Mm-1) 

2018 Projected 

Visibility 

(Mm-1) 

2064 Natural 

Conditions 

(Mm-1) 

2018 under 

URP Goal? 

Sulfate 5.27 4.07 4.68 0.75 No 

Nitrate 1.64 1.44 1.61 0.84 No 

Organic Carbon 8.37 7.30 8.23 4.2 No 

Elemental Carbon 2.18 1.74 2.1 0.4 No 

Fine Soil 1.75 1.61 2 1.18 No 

Coarse Mass 2.77 2.87 NA 3.21 NA 

Sea Salt 0.47 0.48 NA 0.49 NA 

NA - Visibility projections not available due to poor model performance. 
New Mexico Section 308 Regional Haze SIP 72

Figure 9-6: URP by Pollutant on 20% Worst Days for Salt Creek Wilderness 

Table 9-7: Pollutant Breakdown on 20% Worst Days for Salt Creek Wilderness 

Salt Creek Wilderness 

Pollutant 2000- 2004 

Baseline 

(Mm-1) 

2018 URP 

Goal 

(Mm-1) 

2018 Projected 

Visibility 

(Mm-1) 

2064 Natural 

Conditions 

(Mm-1) 

2018 under 

URP Goal? 

Sulfate 16.75 11.64 13.9 0.78 No 

Nitrate 11.15 8.07 11.11 0.77 No 

Organic Carbon 7.49 6.31 6.64 2.97 No 

Elemental Carbon 2.31 1.79 1.62 0.26 No 

Fine Soil 3.34 2.75 3.44 0.98 No 

Coarse Mass 11.47 9.46 NA 4.09 NA 

Sea Salt 0.2 0.20 NA 0.2 NA 

NA - Visibility projections not available due to poor model performance. 
New Mexico Section 308 Regional Haze SIP 73

Figure 9-7: URP by Pollutant on 20% Worst Days for San Pedro Parks Wilderness 

Table 9-8: Pollutant Breakdown on 20% Worst Days for San Pedro Parks Wilderness 

San Pedro Parks Wilderness 

Pollutant 2000- 2004 

Baseline 

(Mm-1) 

2018 URP 

Goal 

(Mm-1) 

2018 Projected 

Visibility 

(Mm-1) 

2064 Natural 

Conditions 

(Mm-1) 

2018 under 

URP Goal? 

Sulfate 5.78 4.41 5.38 0.7 N 

Nitrate 1.57 1.39 1.48 0.8 N 

Organic Carbon 7.66 6.73 7.6 4.02 N 

Elemental Carbon 1.63 1.31 1.3 0.34 Y 

Fine Soil 1.47 1.40 1.68 1.16 N 

Coarse Mass 2.7 2.77 NA 3.02 NA 

Sea Salt 0.1 0.10 NA 0.12 NA 

NA - Visibility projections not available due to poor model performance. 
New Mexico Section 308 Regional Haze SIP 74

Figure 9-8: URP by Pollutant on 20% Worst Days for White Mountain Wilderness 

Table 9-9: Pollutant Breakdown on 20% Worst Days for White Mountain Wilderness 

White Mountain Wilderness 

Pollutant 2000- 2004 

Baseline 

(Mm-1) 

2018 URP 

Goal 

(Mm-1) 

2018 Projected 

Visibility 

(Mm-1) 

2064 Natural 

Conditions 

(Mm-1) 

2018 under 

URP Goal? 

Sulfate 10.51 7.64 9.33 0.74 No 

Nitrate 3.05 2.53 2.99 0.98 No 

Organic Carbon 8.97 7.59 8.64 3.72 No 

Elemental Carbon 1.82 1.45 1.42 0.31 No 

Fine Soil 1.89 1.72 2.02 1.19 No 

Coarse Mass 6.68 6.10 NA 4.35 NA 

Sea Salt 0.17 0.18 NA 0.22 NA 

NA - Visibility projections not available due to poor model performance. 

9.3 Summary of PSAT Modeling Results 

This section provides a summary of the PSAT modeling results for the baseline and 2018 projections. The 

figures and graphs show the relative contribution of in-state versus out-of-state sources that contribute to 

visibility impairment at New Mexico's Class I areas. Results for both the 20% worst and 20% best days 

are shown. 

The PSAT modeling focuses on sulfate and nitrate contribution only and takes into account chemistry and 

deposition. Modeling shows contribution from all regions including the WRAP States, CENRAP States, 

the eastern US States, Canada, Mexico, Pacific Offshore (shipping), and "Outside Domain" (global 

transport). The WEP analysis does not consider sulfate and nitrate chemistry and deposition, but does 

estimate contributions from Canada, Mexico, and Pacific Offshore regions. Because of these differences, 

the results show PSAT for sulfate and nitrate contributions (the primary anthropogenic pollutants) and 
New Mexico Section 308 Regional Haze SIP 75

WEP results for identifying the contribution from organic carbon, elemental carbon, fine soil, and coarse 

matter (common non-anthropogenic pollutants). 

The following sections contain pie charts and graphs showing the State and regional contributions of 

sulfate and nitrate mass at the IMPROVE monitoring sites for the Class I areas. The pie charts show the 

regional contributions from the WRAP States, Canada, Mexico, Pacific offshore (PO), and outside the 

domain (OD). The WRAP States are indicated by the "break-out" slice of the pie chart. The PSAT bar 

graphs show the breakdown of contribution from the individual WRAP States for organic carbon, 

elemental carbon, fine PM, and coarse PM. The figures compare the baseline conditions with the 

projected concentration in 2018 based on PSAT modeling. 

9.3.1 Bandelier Wilderness 

Sulfate 

Figure 9-9 shows the concentration of sulfate for the 20% worst days. The overall concentration is 

projected to remain the same by 2018. Contributions from WRAP States and outside the domain are 

however, showing increased contributions. CENRAP States and Eastern U.S. States are decreasing. 

Concentrations from Mexico are increasing, mostly from point sources, which is likely to due to 

increasing industrial sources within Mexico. 

Figure 9-9: PSAT for Sulfate on 20% - Regional Contributions 

The breakdown of the contributions from WRAP States and regionally, shows that point sources are the 

primary source of sulfate. Among the primary regional contributors, modeling shows that sulfate 

concentrations are decreasing by 2018, except for sulfate from New Mexico, Arizona and Mexico. 
New Mexico Section 308 Regional Haze SIP 76

Figure 9-10: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions 

Nitrate 

Figure 9-11 shows the concentration of nitrate for the 20% worst days. The overall concentration is 

projected to remain the same by 2018. 

Figure 9-11: PSAT for Nitrate on 20% Worst Days – Regional Contributions 

Figure 9-12 provides the nitrate concentrations from WRAP States in addition to other regional 

contributors. Among the WRAP States, New Mexico contributes the most to nitrate concentrations 

followed by CENRAP in both the baseline period and the 2018 projections. Nitrate concentrations are 

primarily from point and area sources. Area source projections show increases in New Mexico for 2018. 
New Mexico Section 308 Regional Haze SIP 77

Figure 9-12: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions 

9.3.2 Bosque del Apache National Wildlife Refuge 

Sulfate 

Figure 9-13 shows sulfate concentrations from the baseline period and projection in 2018. The States and 

regions contributing to most of the sulfate concentrations include WRAP States, Eastern U.S. states, 

CENRAP states, outside domain, and Mexico. Eastern US contribute at lower percentage for 2018. 

Figure 9-13: PSAT for Sulfate on 20% Worst Days – Regional Contributions 

In Figure 9-14, the breakdown of sulfate contributions indicates that CENRAP, Eastern U.S. and Mexican 

sources are the highest contributor, mostly from point sources. New Mexico contributions to sulfate 

concentrations are mostly from point sources. Area sources in New Mexico are projected to increase in 

2018. 
New Mexico Section 308 Regional Haze SIP 78

Figure 9-14: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions 

Nitrate 

Regional nitrate concentrations are shown in Figure 9-15. Contributions to nitrate concentrations are 

mostly from WRAP States, followed by CENRAP states, both of which are projected to decrease by 

2018. 

Figure 9-15: PSAT for Nitrate on 20% Worst Days – Regional Contributions 

As Figure 9-16 shows New Mexico is the primary contributor to nitrate, followed by CENRAP states and 

Arizona. New Mexico source types contributing to nitrate concentrations include natural mobile, area, and 

point sources. Most of the concentrations are from mobile sources. Area sources are projected to have 

increasing concentrations for 2018. CENRAP point and area sources are also projected to increase. 

However, there is a net decrease from both New Mexico and CENRAP for 2018. Increases are projected 

in 2018 from Mexico and outside the domain. 
New Mexico Section 308 Regional Haze SIP 79

Figure 9-16: PSAT for Nitrate on 20% Worst Days – WRAP States and Regional Contributions 

9.3.3 Carlsbad Caverns National Park 

Sulfate 

Source apportionment shows that the Eastern U.S. contributes almost half and CENRAP states contribute 

approximately one-fourth of the total sulfate concentrations at Carlsbad Caverns National Park for the 

baseline period. The regional contributions from each of these categories are expected to decrease in 

2018, and total concentrations are projected to decrease. 

Figure 9-17: PSAT for Sulfate on 20% Worst Days – Regional Contributions 

The primary regional contributor to sulfate is the Eastern U.S., followed by CENRAP states and Mexico. 

It is evident that point sources account for most of the sulfate concentrations from all contributors. Sulfate 

contributions from Mexico and New Mexico are projected to increase in 2018, with concentrations from 

the CENRAP and Eastern U.S. states decreasing. 
New Mexico Section 308 Regional Haze SIP 80

Figure 9-18: PSAT for Sulfate on 20% Worst Days – WRAP States and Regional Contributions 

Nitrate 

Figure 9-19 shows the regional contribution to nitrate at Carlsbad Caverns National Park. On the 20% 

worst days, the primary contributors are CENRAP and WRAP states. Regional contributions are 

projected to remain the same in 2018. 

Figure 9-19: PSAT Nitrate on 20% Worst Days – Regional Contributions 

Figure 9-20 shows that CENRAP states contribute the most to nitrate followed by outside the domain, 

then New Mexico. Most of the concentrations are from mobile and point sources. Nitrate concentration 

from area sources in New Mexico are projected to increase in 2018. 
New Mexico Section 308 Regional Haze SIP 81

Figure 9-20: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions 

9.3.4 Gila Wilderness 

Sulfate 

Figure 9-21 shows a fairly even distribution of the sulfate concentrations from WRAP States, Mexico, 

Eastern U.S., CENRAP states, and outside domain sources. The overall concentrations of sulfate in 2018 

are projected to decrease. 

Figure 9-21: PSAT Sulfate on 20% Worst Days – Regional Contributions 

The breakdown of sulfate from WRAP States and other regional contributors shows that Mexico is the 

primary contributor followed by CENRAP States, and Eastern U.S. States. Sulfate is predominately from 

point sources, with a small amount from area sources within each regional contributor. Contributions of 

sulfate from Mexico, Arizona and New Mexico are projected to increase from point sources in 2018. 
New Mexico Section 308 Regional Haze SIP 82

Figure 9-22: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions 

Nitrate 

Nitrate concentrations at the East Unit are predominately from WRAP states and outside of the domain. 

Less than one-quarter of the remaining nitrate is from Mexico, CENRAP states, and Pacific Offshore. 

Figure 9-23: PSAT Nitrate on 20% Worst Days – Regional Contributions 

On the 20% worst days, California and Arizona are the greatest contributor to nitrate concentrations at 

Gila Wilderness. The majority of nitrate is from mobile sources, but nitrate from point sources is expected 

to increase by 2018. Nitrate from mobile sources is projected to decrease by 2018. 
New Mexico Section 308 Regional Haze SIP 83

Figure 9-24: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions 

9.3.5 Pecos Wilderness, Wheeler Peak Wilderness 

Sulfate 

On a regional level, Figure 9-25 shows that approximately one-third of sulfate comes from the WRAP 

region in both the baseline period and 2018. Another one-fourth is from the outside domain. The 

remaining emissions are from CENRAP, Mexico, Eastern U.S., and Canada. 

Figure 9-25: PSAT Sulfate on 20% Worst Days – Regional Contributions 

The breakdown for WRAP States and other regional contributors in Figure 9-26 shows that the outside 

domain is the highest contributor to sulfate concentrations. The second highest contributor is Mexico, 

followed by Pacific offshore. Concentrations from Mexico are predominately from point sources, with a 

smaller amount from area sources. Source types from Pacific offshore are mostly area sources. Arizona is 

the third highest contributor to sulfate concentrations. Sulfate contributions from New Mexico, Mexico, 

Pacific offshore, and Arizona are projected to increase in 2018. 
New Mexico Section 308 Regional Haze SIP 84

Figure 9-26: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions 

Nitrate 

Almost two-thirds of emissions contributing to nitrate concentrations in 2018 are from the WRAP region. 

The remaining major contributor is CENRAP. 

Figure 9-27: PSAT Nitrate on 20% Worst Days – Regional Contributions 

Looking at contributors by State/region, the primary contributor to nitrate concentrations is New Mexico, 

followed by CENRAP states. Figure 9-28 shows the primary source types from New Mexico are area, 

point and mobile sources. Sources of nitrate from CENRAP are also mostly mobile and point with smaller 

amounts of nitrate from area sources. 
New Mexico Section 308 Regional Haze SIP 85

Figure 9-28: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions 

9.3.6 Salt Creek Wilderness 

Sulfate 

On a regional level about two-thirds of projected sulfate concentrations are from the Eastern U.S. and 

CENRAP regions. 

Figure 9-29: PSAT Sulfate on 20% Worst Days – Regional Contributions 

Figure 9-30 looks at the contribution of WRAP States and regional sources to sulfate concentrations. The 

highest concentrations are from the Eastern U.S. and CENRAP states, followed by outside domain, 

Mexico, and New Mexico. Sulfates are primarily from point sources. In New Mexico, sulfates from area 

sources are projected to increase in 2018. 
New Mexico Section 308 Regional Haze SIP 86

Figure 9-30: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions 

Nitrate 

Figure 9-31 shows that about three-fourths of the nitrate concentrations at the Salt Creek Wilderness are 

from the WRAP region. The next highest contributor is CENRAP with most of the remaining emissions 

from outside the domain. 

Figure 9-31: PSAT Nitrate on 20% Worst Days – Regional Contributions 

Looking at contributions from WRAP States and other regional sources (Figure 9-32), the three highest 

contributors to nitrates are New Mexico, CENRAP, and outside domain. Point, mobile and area sources 

are the largest source of nitrate emissions. In New Mexico, nitrates are predicted to increase, generally 

from area sources. 
New Mexico Section 308 Regional Haze SIP 87

Figure 9-32: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions 

9.3.7 San Pedro Parks Wilderness 

Sulfate 

Figure 9-33 shows the concentration of sulfate for the 20% worst days. The overall concentration is 

projected to remain the same by 2018. Contributions from WRAP States and outside the domain are 

however, showing increased contributions. CENRAP States and Eastern U.S. States are decreasing. 

Concentrations from Mexico are increasing, mostly from point sources, which is likely to due to 

increasing industrial sources within Mexico. 

Figure 9-33: PSAT for Sulfate on 20% - Regional Contributions 

The breakdown of the contributions from WRAP States and regionally, shows that point sources are the 

primary source of sulfate. Among the primary regional contributors, modeling shows that sulfate 

concentrations are decreasing by 2018, except for sulfate from New Mexico, Arizona and Mexico. 
New Mexico Section 308 Regional Haze SIP 88

Figure 9-34: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions 

Nitrate 

Figure 9-35 shows the concentration of nitrate for the 20% worst days. The overall concentration is 

projected to remain the same by 2018. 

Figure 9-35: PSAT for Nitrate on 20% Worst Days – Regional Contributions 

Figure 9-36 provides the nitrate concentrations from WRAP States in addition to other regional 

contributors. Among the WRAP States, New Mexico contributes the most to nitrate concentrations 

followed by CENRAP in both the baseline period and the 2018 projections. Nitrate concentrations are 

primarily from point and area sources. Area source projections show increases in New Mexico for 2018. 
New Mexico Section 308 Regional Haze SIP 89

Figure 9-36: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions 

9.3.8 White Mountain Wilderness 

Sulfate 

On a regional level about two-thirds of projected sulfate concentrations are from the Eastern U.S. and 

CENRAP regions. 

Figure 9-37: PSAT Sulfate on 20% Worst Days – Regional Contributions 

Figure 9-38 looks at the contribution of WRAP States and regional sources to sulfate concentrations. The 

highest concentrations are from the Eastern U.S. and CENRAP states, followed by outside domain, 

Mexico, and New Mexico. Sulfates are primarily from point sources. In New Mexico, sulfates from area 

sources are projected to increase in 2018. 
New Mexico Section 308 Regional Haze SIP 90

Figure 9-38: PSAT Sulfate on 20% Worst Days – WRAP States and Regional Contributions 

Nitrate 

Figure 9-39 shows that over one-third of the nitrate concentrations at the Salt Creek Wilderness are from 

the WRAP region, with another third from CENRAP. 

Figure 9-39: PSAT Nitrate on 20% Worst Days – Regional Contributions 

Looking at contributions from WRAP States and other regional sources (Figure 9-40), the three highest 

contributors to nitrates are CENRAP, New Mexico, and outside domain. Mobile and point sources are the 

largest source of nitrate emissions. In New Mexico, nitrates are predicted to increase, generally from area 

sources. 
New Mexico Section 308 Regional Haze SIP 91

Figure 9-40: PSAT Nitrate on 20% Worst Days – WRAP States and Regional Contributions 

9.4 Summary of WEP Results 

Nitrogen oxides (NOx), sulfur oxides (SOx), organic carbon (primary organic aerosol), elemental carbon, 

fine soil, and coarse mass were analyzed using the Weighted Emissions Potential (WEP) tool. The WEP 

analysis was developed as a screening tool for states to decide which source regions have the potential to 

contribute to haze formation at specific Class I areas, based on both the baseline and 2018 emissions 

inventories. Unlike the SOx/NOx Tracer analysis, this method does not account for chemistry and 

removal processes. Instead, the WEP analysis relies on an integration of gridded emissions data, 

meteorological back trajectory residence time data, a one-over-distance factor to approximate deposition, 

and a normalization of the final results. Residence time over an area is indicative of general flow patterns, 

but does not necessarily imply the area contributed significantly to haze at a given receptor. Therefore, 

users are cautioned to view the WEP analysis as one piece of a larger, more comprehensive weight of 

evidence analysis. 

The WEP bar charts display normalized (unitless), residence time- and distance-weighted annual 

emissions value, by emissions source region. These WEP results are reminiscent of the SOx/NOx Tracer 

tool results. However, the WEP results are considered less rigorous and should be used only as a 

screening tool to identify regions with the potential to impact Class I areas. The bar chart presents results 

for the Baseline and 2018 PRP(b) emissions scenarios. Note that a reported change in regional percent 

contribution between two scenarios does not necessarily imply a larger or smaller impact on haze 

formation. 

9.4.1 Bandelier Wilderness 

Nitrogen Oxides 

Figure 9-41 shows that New Mexico has the highest potential to contribute to nitrogen oxide emissions. 

Point and on-road mobile sources decrease from the baseline (2000-2004) to 2018, with area and area oil 

and gas sources increasing. Overall, New Mexico's contributions to nitrogen oxides decrease from the 

baseline period to 2018. Contributions from Mexico increase over the planning period. 
New Mexico Section 308 Regional Haze SIP 92

Figure 9-41: Weighted Emissions Potential – Nitrogen Oxides 

Sulfur Oxides 

Figure 9-42 shows that New Mexico has the highest potential to contribute to sulfur oxide emissions. 

Point and on-road mobile sources decrease from the baseline (2000-2004) to 2018, with area sources 

more than doubling in contribution. Overall, New Mexico's contributions to nitrogen oxides increase from 

the baseline period to 2018 because of the increased contribution from area sources. Contribution from 

Mexico also increases over the planning period. 

Figure 9-42: Weighted Emissions Potential – Sulfur Oxides 

Organic Carbon 

Figure 9-43 shows that New Mexico has the highest potential to contribute to organic carbon emissions. 

The source category with the greatest potential to contribute is natural fire. The other categories include 
New Mexico Section 308 Regional Haze SIP 93

area, on-road and off-road mobile, and fugitive dust sources. Total potential for New Mexico sources to 

emit organic carbon is projected to increase in 2018, mostly from area sources. 

Figure 9-43: Weighted Emissions Potential – Organic Carbon 

Elemental Carbon 

As shown in Figure 9-44, New Mexico has the greatest potential to contribute to elemental carbon. The 

primary source is natural fire, followed by on- and off-road mobile sources. Elemental carbon from onand off-road mobile sources is expected to decrease by 2018. 

Figure 9-44: Weighted Emissions Potential – Elemental Carbon 

Fine Particulate Matter 

Sources of fine particulate matter from New Mexico have the greatest potential to contribute on the 20% 

worst days. The potential for fine PM from New Mexico, CENRAP states, Arizona and Mexico is 
New Mexico Section 308 Regional Haze SIP 94

expected to increase in 2018. The source categories in New Mexico with the greatest potential to 

contribute are area and fugitive dust. 

Figure 9-45: Weighted Emissions Potential – Fine Particulate Matter 

Coarse Particulate Matter 

Figure 9-46 shows that fugitive dust from New Mexico has the greatest potential to contribute to coarse 

mass. 

Figure 9-46: Weighted Emissions Potential – Coarse Particulate Matter 
New Mexico Section 308 Regional Haze SIP 95

9.4.2 Bosque del Apache National Wildlife Refuge 

Nitrogen Oxides 

Figure 9-47 shows that New Mexico has the highest potential to contribute to nitrogen oxide emissions. 

Point, on- and off-road mobile sources decrease from the baseline (2000-2004) to 2018, with area and 

area oil and gas sources increasing. Arizona and CENRAP also have a significant, but decreasing, 

contribution. Overall, New Mexico's contributions to nitrogen oxides decrease from the baseline period to 

2018. Contributions from Mexico increase over the planning period. 

Figure 9-47: Weighted Emissions Potential – Nitrogen Oxides 

Sulfur Oxides 

Figure 9-48 shows that Mexico has the highest potential to contribute to sulfur oxide emissions, followed 

by Arizona and CENRAP. Point and on- and off-road mobile sources in New Mexico, Arizona and 

CENRAP decrease from the baseline (2000-2004) to 2018, with area sources in New Mexico more than 

doubling in contribution. Overall, New Mexico, Arizona and CENRAP's contributions to nitrogen oxides 

decrease from the baseline period to 2018. Contribution from Mexico from point sources more than 

triples over the planning period. 
New Mexico Section 308 Regional Haze SIP 96

Figure 9-48: Weighted Emissions Potential – Sulfur Oxides 

Organic Carbon 

Figure 9-49 shows that Arizona and New Mexico have the highest potential to contribute to organic 

carbon emissions. The source category with the greatest potential to contribute is natural fire. Total 

potential for New Mexico sources to emit organic carbon is projected to decrease in 2018, with 

contributions from Arizona sources projected to increase, mostly from area sources. 

Figure 9-49: Weighted Emissions Potential – Organic Carbon 

Elemental Carbon 

As shown in Figure 9-50, New Mexico has the greatest potential to contribute to elemental carbon, with 

Arizona also having a large contribution. The primary source is natural fire, followed by on- and off-road 

mobile sources. Elemental carbon from on- and off-road mobile sources is expected to decrease by 2018. 
New Mexico Section 308 Regional Haze SIP 97

Figure 9-50: Weighted Emissions Potential – Elemental Carbon 

Fine Particulate Matter 

Sources of fine particulate matter from New Mexico have the greatest potential to contribute on the 20% 

worst days. The potential for fine PM from New Mexico, CENRAP states, Arizona and Mexico is 

expected to increase in 2018. The source category in New Mexico with the greatest potential to contribute 

is windblown dust. 

Figure 9-51: Weighted Emissions Potential – Fine Particulate Matter 

Coarse Particulate Matter 

Figure 9-52 shows that fugitive dust from New Mexico has the greatest potential to contribute to coarse 

mass, with the greatest contribution from windblown dust. 
New Mexico Section 308 Regional Haze SIP 98

Figure 9-52: Weighted Emissions Potential – Coarse Particulate Matter 

9.4.3 Carlsbad Caverns National Park 

Nitrogen Oxides 

Figure 9-53 shows that CENRAP states have the highest potential to contribute to nitrogen oxide 

emissions. On- and off-road mobile sources decrease from the baseline (2000-2004) to 2018, with point 

sources increasing. Overall, New Mexico's contributions to nitrogen oxides decrease from the baseline 

period to 2018. Contributions from Mexico increase over the planning period with point sources tripling 

in contribution. 

Figure 9-53: Weighted Emissions Potential – Nitrogen Oxides 
New Mexico Section 308 Regional Haze SIP 99

Sulfur Oxides 

Figure 9-54 shows that Mexico has the highest potential to contribute to sulfur oxide emissions. Point 

sources almost triple in contribution. Overall, New Mexico's contributions to nitrogen oxides decrease 

from the baseline period to 2018. CENRAP states' contribution is also significant, but decreases over the 

planning period. 

Figure 9-54: Weighted Emissions Potential – Sulfur Oxides 

Organic Carbon 

Figure 9-55 shows that New Mexico has the highest potential to contribute to organic carbon emissions. 

The source category with the greatest potential to contribute is natural fire. Contribution from sources in 

the CENRAP region increase over the planning period, with increases in point and area sources. 

Contribution from Arizona and Mexico sources also increase over the planning period, with most of the 

increase coming from area sources. Total potential for New Mexico sources to emit organic carbon is 

projected to decrease in 2018. 
New Mexico Section 308 Regional Haze SIP 100

Figure 9-55: Weighted Emissions Potential – Organic Carbon 

Elemental Carbon 

As shown in Figure 9-56, contribution from CENRAP states is significant for Carlsbad Caverns for 

elemental carbon. The primary source category is area sources, followed by on- and off-road mobile 

sources. Elemental carbon from on- and off-road mobile sources is expected to decrease by 2018. 

Contributions from New Mexico are dominated by fire, and total New Mexico contributions are expected 

to decrease. Mexico source contributions are expected to increase over the planning period. 

Figure 9-56: Weighted Emissions Potential – Elemental Carbon 

Fine Particulate Matter 

Sources of fine particulate matter from the CENRAP region have the greatest potential to contribute on 

the 20% worst days. The potential for fine PM from CENRAP states and Mexico is expected to increase 
New Mexico Section 308 Regional Haze SIP 101

in 2018, with increases in contribution from point sources. The source category in New Mexico with the 

greatest potential to contribute is windblown dust. 

Figure 9-57: Weighted Emissions Potential – Fine Particulate Matter 

Coarse Particulate Matter 

Figure 9-58 shows that windblown dust from the CENRAP region has the greatest potential to contribute 

to coarse mass. There is also a significant contribution of coarse particulate matter from windblown dust 

in Mexico and New Mexico. 

Figure 9-58: Weighted Emissions Potential – Coarse Particulate Matter 
New Mexico Section 308 Regional Haze SIP 102

9.4.4 Gila Wilderness 

Nitrogen Oxides 

Figure 9-59 shows that Arizona, New Mexico and the CENRAP region have the highest potential to 

contribute to nitrogen oxide emissions. Overall, these contributions decrease from the baseline period to 

2018 with the decreases attributable to on- and off-road mobile sources. Contributions from Mexico 

increase over the planning period. 

Figure 9-59: Weighted Emissions Potential – Nitrogen Oxides 

Sulfur Oxides 

Figure 9-60 shows that Mexico has the highest potential to contribute to sulfur oxide emissions in 2018, 

with Arizona being the largest contributor in the baseline period (2000-2004). Mexico's contribution from 

point sources more than doubles from the baseline period to 2018. Overall, Arizona's and New Mexico's 

contributions to nitrogen oxides decrease from the baseline period to 2018. 
New Mexico Section 308 Regional Haze SIP 103

Figure 9-60: Weighted Emissions Potential – Sulfur Oxides 

Organic Carbon 

Figure 9-61 shows that New Mexico has the highest potential to contribute to organic carbon emissions. 

The source category with the greatest potential to contribute is natural fire. The other categories include 

area, on-road and off-road mobile, and fugitive dust sources. Total potential for Arizona sources to emit 

organic carbon is projected to increase in 2018, mostly from area sources. New Mexico sources decrease 

slightly in 2018. 

Figure 9-61: Weighted Emissions Potential – Organic Carbon 

Elemental Carbon 

As shown in Figure 9-62, New Mexico has the greatest potential to contribute to elemental carbon. The 

primary source is natural fire, followed by on- and off-road mobile sources. Arizona sources also have a 

significant contribution. Elemental carbon from on- and off-road mobile sources is expected to decrease 

by 2018. 
New Mexico Section 308 Regional Haze SIP 104

Figure 9-62: Weighted Emissions Potential – Elemental Carbon 

Fine Particulate Matter 

Sources of fine particulate matter from New Mexico have the greatest potential to contribute on the 20% 

worst days. The potential for fine PM from New Mexico, CENRAP states, Arizona and Mexico is 

expected to increase in 2018. The source categories in New Mexico with the greatest potential to 

contribute are natural fire, fugitive dust and windblown dust. Point sources in Mexico are shown to 

double in contribution by 2018. 

Figure 9-63: Weighted Emissions Potential – Fine Particulate Matter 

Coarse Particulate Matter 

Figure 9-64 shows that windblown dust from New Mexico has the greatest potential to contribute to 

coarse mass. Point and road dust contribution is expected to increase over the planning period. Arizona 

and Mexico contributions are also expected to increase over the planning period. The CENRAP region 

contribution is also significant. 
New Mexico Section 308 Regional Haze SIP 105

Figure 9-64: Weighted Emissions Potential – Coarse Particulate Matter 

9.4.5 Pecos Wilderness, Wheeler Peak Wilderness 

Nitrogen Oxides 

Figure 9-65 shows that New Mexico has the highest potential to contribute to nitrogen oxide emissions. 

Point and on-road mobile sources decrease from the baseline (2000-2004) to 2018, with area oil and gas 

sources increasing. Overall, New Mexico's contributions to nitrogen oxides decrease from the baseline 

period to 2018. 

Figure 9-65: Weighted Emissions Potential – Nitrogen Oxides 
New Mexico Section 308 Regional Haze SIP 106

Sulfur Oxides 

Figure 9-66 shows that New Mexico has the highest potential to contribute to sulfur oxide emissions. 

Point and on- and off-road mobile sources decrease from the baseline (2000-2004) to 2018, with area 

sources more than doubling in contribution. Overall, New Mexico's contributions to nitrogen oxides 

decrease from the baseline period to 2018. Contribution from Mexico increases over the planning period. 

Figure 9-66: Weighted Emissions Potential – Sulfur Oxides 

Organic Carbon 

Figure 9-67 shows that New Mexico has the highest potential to contribute to organic carbon emissions. 

The source category with the greatest potential to contribute is natural fire. The other categories include 

area and on- and off-road mobile sources. Total potential for New Mexico sources to emit organic carbon 

is projected to either increase or decrease significantly in 2018. 

Figure 9-67: Weighted Emissions Potential – Organic Carbon 
New Mexico Section 308 Regional Haze SIP 107

Elemental Carbon 

As shown in Figure 9-68, New Mexico has the greatest potential to contribute to elemental carbon. The 

primary source is natural fire, followed by on- and off-road mobile sources. Elemental carbon from onand off-road mobile sources is expected to decrease by 2018. 

Figure 9-68: Weighted Emissions Potential – Elemental Carbon 

Fine Particulate Matter 

Sources of fine particulate matter from New Mexico have the greatest potential to contribute on the 20% 

worst days. The potential for fine PM from New Mexico, CENRAP states, Arizona and Mexico is 

expected to increase in 2018. The source categories in New Mexico with the greatest potential to 

contribute are area and fugitive dust. 

Figure 9-69: Weighted Emissions Potential – Fine Particulate Matter 
New Mexico Section 308 Regional Haze SIP 108

Coarse Particulate Matter 

Figure 9-70 shows that fugitive dust from New Mexico has the greatest potential to contribute to coarse 

mass in 2018. Point source and road dust contributions are also projected to increase. 

Figure 9-70: Weighted Emissions Potential – Coarse Particulate Matter 

9.4.6 Salt Creek Wilderness 

Nitrogen Oxides 

Figure 9-71 shows that New Mexico has the highest potential to contribute to nitrogen oxide emissions. 

The CENRAP region also contributes significantly. Point and on-road mobile sources decrease from the 

baseline (2000-2004) to 2018, with the contribution from area and area oil and gas sources increasing. 

Overall, the CENRAP region's and New Mexico's contributions to nitrogen oxides decrease from the 

baseline period to 2018. Contributions from Mexico increase over the planning period. 
New Mexico Section 308 Regional Haze SIP 109

Figure 9-71: Weighted Emissions Potential – Nitrogen Oxides 

Sulfur Oxides 

Figure 9-72 shows that the CENRAP region has the highest contribution to sulfur oxide emissions. 

Contributions from point and on- and off-road sources decrease from the baseline (2000-2004) to 2018, 

with area sources more than doubling in contribution. Overall, New Mexico's contributions to sulfur 

oxides decrease from the baseline period to 2018. Contribution from Mexico increases over the planning 

period. 

Figure 9-72: Weighted Emissions Potential – Sulfur Oxides 

Organic Carbon 

Figure 9-73 shows that New Mexico has the highest contribution from organic carbon emissions, with the 

CENRAP region also having a significant contribution. The source categories with the greatest 

contribution are natural fire and point sources. The other categories include area and on-road and off-road 
New Mexico Section 308 Regional Haze SIP 110

mobile sources. Total potential for New Mexico sources to emit organic carbon is projected to decrease in 

2018. 

Figure 9-73: Weighted Emissions Potential – Organic Carbon 

Elemental Carbon 

As shown in Figure 9-74, the CENRAP region and New Mexico have the greatest contribution to 

elemental carbon. For CENRAP, the primary source is area, followed by on- and off-road mobile sources. 

Off-road mobile sources in New Mexico are the highest contribution. Elemental carbon from on- and offroad mobile sources is expected to decrease by 2018. 

Figure 9-74: Weighted Emissions Potential – Elemental Carbon 
New Mexico Section 308 Regional Haze SIP 111

Fine Particulate Matter 

Sources of fine particulate matter from CENRAP have the greatest contribution on the 20% worst days. 

The contribution of fine PM from CENRAP states and Mexico is expected to increase in 2018. The 

source categories in New Mexico with the greatest potential to contribute are windblown and fugitive 

dust. 

Figure 9-75: Weighted Emissions Potential – Fine Particulate Matter 

Coarse Particulate Matter 

Figure 9-76 shows that windblown dust from the CENRAP region has the greatest potential to contribute 

to coarse mass. 

Figure 9-76: Weighted Emissions Potential – Coarse Particulate Matter 
New Mexico Section 308 Regional Haze SIP 112

9.4.7 San Pedro Parks Wilderness 

Nitrogen Oxides 

Figure 9-77 shows that New Mexico has the highest potential to contribute to nitrogen oxide emissions. 

Point and on-road mobile sources decrease from the baseline (2000-2004) to 2018, with area and area oil 

and gas sources increasing. Overall, New Mexico's contributions to nitrogen oxides decrease from the 

baseline period to 2018. 

Figure 9-77: Weighted Emissions Potential – Nitrogen Oxides 

Sulfur Oxides 

Figure 9-78 shows that New Mexico has the highest potential to contribute to sulfur oxide emissions. 

Point and on-road mobile sources decrease from the baseline (2000-2004) to 2018, with area sources 

more than doubling in contribution. Contribution from Mexico increases over the planning period. 
New Mexico Section 308 Regional Haze SIP 113

Figure 9-78: Weighted Emissions Potential – Sulfur Oxides 

Organic Carbon 

Figure 9-79 shows that New Mexico has the highest potential to contribute to organic carbon emissions. 

The source category with the greatest potential to contribute is natural fire. The other categories include 

area, on-road mobile and anthropogenic fire sources. Total potential for New Mexico sources to emit 

organic carbon is projected to decrease in 2018. 

Figure 9-79: Weighted Emissions Potential – Organic Carbon 

Elemental Carbon 

As shown in Figure 9-80, New Mexico has the greatest potential to contribute to elemental carbon. The 

primary source is natural fire, followed by on- and off-road mobile sources. Elemental carbon from onand off-road mobile sources is expected to decrease by 2018. 
New Mexico Section 308 Regional Haze SIP 114

Figure 9-80: Weighted Emissions Potential – Elemental Carbon 

Fine Particulate Matter 

Sources of fine particulate matter from New Mexico have the greatest potential to contribute on the 20% 

worst days. The potential for fine PM from New Mexico, CENRAP states, Arizona and Mexico is 

projected to increase in 2018. The source categories in New Mexico with the greatest potential to 

contribute are windblown and fugitive dust. 

Figure 9-81: Weighted Emissions Potential – Fine Particulate Matter 

Coarse Particulate Matter 

Figure 9-82 shows that fugitive dust from New Mexico has the greatest potential to contribute to coarse 

mass. 
New Mexico Section 308 Regional Haze SIP 115

Figure 9-82: Weighted Emissions Potential – Coarse Particulate Matter 

9.4.8 White Mountain Wilderness 

Nitrogen Oxides 

Figure 9-83 shows that CENRAP and New Mexico have the highest contribution of nitrogen oxide. Onand off-road mobile source contribution decreases from the baseline (2000-2004) to 2018. Overall, New 

Mexico's contributions to nitrogen oxides decrease from the baseline period to 2018. Contributions from 

Mexico increase over the planning period. 

Figure 9-83: Weighted Emissions Potential – Nitrogen Oxides 
New Mexico Section 308 Regional Haze SIP 116

Sulfur Oxides 

Figure 9-84 shows that the CENRAP region has highest contribution to sulfur oxide emissions, with New 

Mexico also having a large contribution. Contribution from Mexico point sources increases significantly 

over the planning period. 

Figure 9-84: Weighted Emissions Potential – Sulfur Oxides 

Organic Carbon 

Figure 9-85 shows that New Mexico has the highest contribution of organic carbon emissions. The source 

category with the greatest contribution in New Mexico is natural fire. The other categories include area, 

on-road and off-road mobile, and fugitive dust sources. Contribution from the CENRAP region Arizona is 

projected to increase. Total potential for New Mexico sources to emit organic carbon is projected to 

decrease in 2018. 

Figure 9-85: Weighted Emissions Potential – Organic Carbon 
New Mexico Section 308 Regional Haze SIP 117

Elemental Carbon 

As shown in Figure 9-86, New Mexico sources have the greatest contribution of elemental carbon. The 

primary source for New Mexico is fire, followed by on- and off-road mobile sources. Contribution from 

elemental carbon from on- and off-road mobile sources is expected to decrease by 2018. 

Figure 9-86: Weighted Emissions Potential – Elemental Carbon 

Fine Particulate Matter 

Sources of fine particulate matter from the CENRAP region have the greatest contribution on the 20% 

worst days. The source categories in New Mexico with the greatest potential to contribute are fugitive and 

windblown dust. 

Figure 9-87: Weighted Emissions Potential – Fine Particulate Matter 
New Mexico Section 308 Regional Haze SIP 118

Coarse Particulate Matter 

Figure 9-88 shows that the CENRAP region has the greatest contribution to coarse mass. Road, fugitive, 

and windblown dust are large contributors in CENRAP, with fugitive and windblown dust being the 

largest contributors from New Mexico. 

Figure 9-88: Weighted Emissions Potential – Coarse Particulate Matter 
New Mexico Section 308 Regional Haze SIP 119

CHAPTER 10: BEST AVAILABLE RETROFIT TECHNOLOGY (BART) EVALUATION 

10.1 Introduction 

In 1999, the EPA published a final rule to address a type of visibility impairment known as regional haze 

(64 FR 35714, July 1, 1999). The regional haze rule requires States to submit state implementation plans 

(SIPs) to address regional haze visibility impairment in 156 Federally-protected parks and wilderness 

areas. The 1999 rule was issued to fulfill a long-standing EPA commitment to address regional haze 

under the authority and requirements of sections 169A and 169B of the Clean Air Act (CAA).1 

As required by the CAA, the EPA included in the final regional haze rule a requirement for Best 

Available Retrofit Technology (BART) for certain large stationary sources. The regulatory requirements 

for BART were codified at 40 CFR 50.308(e) and in definitions that appear in 40 CFR 50.301. 

The BART-eligible sources are those sources which have the potential to emit 250 tons per year or more 

of a visibility impairing air pollutant, were put in place between August 7, 1962 and August 7, 1977, and 

whose operations fall within one or more of 26 specifically listed source categories. Under the CAA, 

BART is required for any BART-eligible source which a State determines “emits any air pollutant which 

may reasonably be anticipated to cause or contribute to any impairment of visibility in any such area.” 

Accordingly, for stationary sources meeting these criteria, States must address the BART requirement 

when they develop their regional haze SIPs. 

The EPA published a second rulemaking on June 6, 2005 that made changes to the Final Rule published 

July 1, 1999. The second rulemaking was in response to a U.S. District Court of Appeals ruling that 

vacated part of the regional haze rule. The June 6, 2005 Final Rule required the BART analysis to 

include an analysis of the degree of visibility improvement resulting from the use of control technology at 

BART-subject sources; revised the BART provisions; included new BART Guidelines contained in a new 

Appendix Y to Part 51; and added the requirement that States use Appendix Y for determining BART at 

certain large electrical generating units (EGUs). 

The Guidelines also contained specific presumptive limits for SO2 and NOx for certain large EGUs based 

on fuel type, unit size, cost effectiveness, and presence or absence of pre-existing controls. For NOx 

emissions, the EPA directs states to generally require owners and operators to meet the presumptive limits 

at coal-fired EGUs greater than 200 MW at power plants with a total generating capacity greater than 750 

MW. The presumptive limits for NOx are based on coal type, boiler type and whether SCR or SNCR are 

already installed at the source. 

10.2 SO2: Regional SO2 Milestone and Backstop Trading Program 

New Mexico was a §309 state participating in the Regional SO2 Milestone and Backstop Trading 

Program from 2003 through 2010. Section 308(e)(2) provides states with the option to implement or 

require participation in an emissions trading program or other alternative measure rather than to require 

sources subject to BART to install, operate, and maintain additional control technology to meet an 

established emission limit on a continuous basis. However, the alternate program must achieve greater 

reasonable progress than would be accomplished by installing BART. A demonstration that the alternate 

program can achieve greater reasonable progress is prescribed by §308(e)(2)(i). 

As part of the §309 program, participating states, including New Mexico, submitted an annual Regional 

Sulfur Dioxide Emissions and Milestone Report that compares actual emissions to pre-established 

milestones. Participating states have been filing these reports since 2003. Each year, states have been able 
New Mexico Section 308 Regional Haze SIP 120

to demonstrate that actual SO2 emissions are well below the milestones. The actual emissions and their 

respective milestones are shown below: 

Table 10-1 Regional Sulfur Dioxide Emissions and Milestone Report Summary 

Year Reported SO2 Emissions (tons) 3-year Milestone Average (tons) 

2003 330,679 447,383 

2004 337,970 448,259 

2005 304,591 446,903 

2006 279,134 420,194 

2007 273,663 420,637 

2008 244,189 378,398 

10.3 Summary of BART Modeling Results (Visibility Impact Analysis) 

After determining BART-eligibility, the State must then determine whether the air pollution emission unit 

is potentially-subject-to-BART. EPA finalized several options that allowed States flexibility when 

making the determination of whether a source "emits any pollutants which may reasonably be anticipated 

to cause or contribute to any visibility impairment." 

Option 1: All BART-eligible sources are Subject to BART 

EPA provided the States with the discretion to consider all BART-eligible sources within the State to be 

"reasonably anticipated to cause or contribute" to some degree of visibility impairment in a Class I area. 

EPA held that this option is consistent with the American Corn Growers court's decision, as it would be 

an impermissible constraint of State authority for the EPA to force States to conduct individualized 

analyses in order to determine that a BART-eligible source "emits any air pollutant which may reasonably 

anticipated to cause or contribute to any impairment of visibility in any [Class I] area." 

Option 2: All BART-Eligible Sources Do Not Cause or Contribute to Regional Haze 

EPA also provided States with the option of performing an analysis to show that the full group of BARTeligible sources in a State may not, as a whole, be reasonably anticipated to cause or contribute to any 

visibility impairment in Class I areas. Although the option was provided, EPA did also state that it 

anticipated that in most, if not all States, BART eligible-sources are likely to cause or contribute to some 

level of visibility impairment in at least one Class I area. 

Option 3: Case-by-Case BART Analysis 

The final option that was provided to the States was to consider the individual contributions of a BARTeligible source to determine whether the facility is subject-to-BART. Specifically, EPA allowed States to 

choose to undertake an analysis of each BART-eligible source in the State in considering whether each 

such source "emit[s] any air pollutant which may reasonably be anticipated to cause or contribute to any 

impairment of visibility in any [Class I] area." Alternatively, States may choose to presume that all 

BART-eligible sources within the State meet this applicability test, but provide sources with the ability to 

demonstrate on a case-by-case basis that this is not the case. 

10.3.1 New Mexico Process 

When considering the options provided by EPA, NMED determined that the third option is the most 

consistent with the American Corn Growers case, as this option provides a rebuttable method for the 
New Mexico Section 308 Regional Haze SIP 121

evaluation of the visibility impact from a single source. If the air dispersion modeling analysis shows that 

a facility causes or contributes to Regional Haze, then it is required to address BART. A State is also 

provided with flexibility under this option, as it may exempt from BART any source that is not 

reasonably anticipated to cause or contribute to visibility degradation in a Class I area. 

In May 2006, the New Mexico Environment Department Air Quality Bureau (Department) conducted an 

internal review of sources potentially subject to the BART rule. 

Section II of the Guidelines prescribes how to identify BART-eligible sources. States are required to 

identify those sources that satisfy the following criteria: sources that fall within the 26 listed source 

categories as listed in the CAA, sources that were “in existence” on August 7, 1977 but were not “in 

operation” before August 7, 1962, and sources that have a current potential to emit that is greater than 250 

tons per year of any single visibility impairing pollutant. New Mexico identified 11 sources as BARTeligible sources as part of this review. 

The Guidelines then prescribe to the states how to identify those sources that are subject to BART. At 

this point, states are directed to either (1) make BART determinations for all BART-eligible sources, or 

(2) to consider exempting some of the sources from BART because they may not reasonably be 

anticipated to cause or contribute to any visibility impairment in a Class I area. New Mexico opted to 

perform an initial screening model on the BART-eligible sources to determine whether a source did cause 

or contribute to any visibility impairment. The Guidelines direct States that if the analysis shows that an 

individual source or group of sources is not reasonably anticipated to cause or contribute to any visibility 

impairment in a Class I area, then the States do not need to make a BART determination for that source or 

group of sources. 

The Western Regional Air Partnership (WRAP) performed the initial BART modeling for the state of 

New Mexico. The procedures used are outlined in the WRAP Regional Modeling Center (RMC) BART 

Modeling Protocol that is available at: 

http://pah.cert.ucr.edu/aqm/308/bart/WRAP_RMC_BART_Protocol_Aug15_2006.pdf

The basic assumptions in the WRAP BART CALMET/CALPUFF modeling used for New Mexico are as 

follows: 

• Use of three years of modeling of 2001, 2002, and 2003. 

• Visibility impacts due to emissions of SO2, NOx and primary PM emissions were calculated. PM 

emissions were modeled as PM2.5. 

• Visibility was calculated using the Original IMPROVE equation and Annual Average Natural 

Conditions. 

Initial modeling was performed for the 11 source complexes in New Mexico with visibility estimated 

from the sources’ SO2, NOx, and PM emissions. Then for those sources whose 98th percentile visibility 

impacts at any Class I area due to their combined SO2, NOx, and PM emissions exceeded the 0.5 dv 

significance threshold, the separate contribution to visibility at Class I areas was assessed for SO2 alone 

(SO4), NOx alone (NO3), PM alone (PMF) and combined NOx plus PM emissions (NO3 + PMF). 

Of the 11 source complexes analyzed, only one source complex’s visibility impacts at any Class I area 

due to combined SO2, NOx, and PM emissions exceeded the 0.5 dv threshold (PNM San Juan Generating 

Station Boilers #1-4). Of the 10 other source complexes, none exceed a 0.33 dv impact. Consequently, 

only the PNM San Juan Boilers #1-4 were subjected to a BART determination. 
New Mexico Section 308 Regional Haze SIP 122

On November 9, 2006, the New Mexico Environment Department informed PNM that the modeling 

performed by the WRAP indicated the visibility impairment from the San Juan Generating Station (SJGS) 

was over the 0.5 dv threshold, and was therefore subject to a BART determination. In response, Black & 

Veatch (B&V), on behalf of PNM, submitted the BART Modeling Protocol document which described 

the CALPUFF modeling methodology to be used as part of the BART engineering evaluation for Units 1-

4 at the SJGS. The results are presented in Table 10-2 below. 

Table 10-2: Visibility Impact Analysis of PNM's San Juan Generating Station 

NM SRC02 Unit # 350450902, PNM SJ #1-4: SO2 = 35,735 TPY; NOx = 38,763 TPY; PM = 

3,884 TPY 

Annual Average Natural Conditions 

Class I Area with at least 1 receptor within 300 km of source

Minimum 

Distance 98th Percentile for Each Year 98th 

Class I Area (km) 2001 2002 2003 

3 year 

AVG 

Mesa Verde NP 40 5.54 5.34 5.30 5.40 

Weminuche Wilderness 98 2.24 2.99 2.41 2.55 

San Pedro Parks Wilderness 155 3.80 4.07 4.14 4.01 

La Garita Wilderness 169 1.63 1.82 1.77 1.74 

Canyonlands NP 170 6.21 4.33 4.44 4.99 

Black Canyon Gunnison NM 203 2.38 2.27 2.43 2.36 

Bandelier NM 210 2.47 2.90 3.08 2.82 

Petrified Forest NP 213 1.62 1.27 1.03 1.31 

West Elk Wilderness 216 2.14 1.90 2.20 2.08 

Arches NP 222 4.06 3.71 3.59 3.79 

Capitol Reef NP 232 4.00 2.02 2.35 2.79 

Pecos Wilderness 248 2.17 2.63 2.81 2.53 

Wheeler Peak Wilderness 258 1.94 1.73 1.97 1.88 

Great Sand Dunes NM 269 1.47 1.59 1.74 1.60 

Maroon Bells-Snowmass WA 271 1.19 1.27 1.15 1.21 

Grand Canyon NP 285 2.12 1.50 1.18 1.60 
New Mexico Section 308 Regional Haze SIP 123

NM SRC02 Unit # 350450902, PNM SJ #1-4: PM Only (PM = 3,884 TPY) 

Annual Average Natural Conditions 

Class I Area with at least 1 receptor within 300 km of source

Minimum 

Distance 98th Percentile for Each Year 98th 

Class I Area (km) 2001 2002 2003 

3 year 

AVG 

Mesa Verde NP 40 0.86 0.96 1.13 0.98

Weminuche Wilderness 98 0.15 0.24 0.25 0.21

San Pedro Parks Wilderness 155 0.25 0.28 0.22 0.25

La Garita Wilderness 169 0.06 0.08 0.09 0.08

Canyonlands NP 170 0.28 0.20 0.22 0.23

Black Canyon Gunnison NM 203 0.09 0.11 0.07 0.09

Bandelier NM 210 0.13 0.19 0.17 0.16

Petrified Forest NP 213 0.05 0.03 0.05 0.05

West Elk Wilderness 216 0.07 0.09 0.07 0.08

Arches NP 222 0.19 0.19 0.15 0.17

Capitol Reef NP 232 0.12 0.07 0.09 0.09

Pecos Wilderness 248 0.08 0.10 0.10 0.09

Wheeler Peak Wilderness 258 0.07 0.06 0.07 0.06

Great Sand Dunes NM 269 0.07 0.05 0.06 0.06

Maroon Bells-Snowmass WA 271 0.04 0.04 0.03 0.04

Grand Canyon NP 285 0.08 0.04 0.05 0.05

NM SRC02 Unit # 350450902, PNM SJ #1-4: NOx Only (NOx = 38,763 TPY) 

Annual Average Natural Conditions 

Class I Area with at least 1 receptor within 300 km of source

Minimum 

Distance 98th Percentile for Each Year 98th 

Class I Area (km) 2001 2002 2003 

3 year 

AVG 

Mesa Verde NP 40 3.59 3.73 3.24 3.52 

Weminuche Wilderness 98 1.66 2.15 1.71 1.84 

San Pedro Parks Wilderness 155 2.70 2.74 2.89 2.78 

La Garita Wilderness 169 1.09 1.30 1.22 1.20 

Canyonlands NP 170 4.28 3.22 2.79 3.43 

Black Canyon Gunnison NM 203 1.67 1.72 1.86 1.75 

Bandelier NM 210 1.69 2.13 2.23 2.02 

Petrified Forest NP 213 0.80 0.70 0.30 0.60 

West Elk Wilderness 216 1.22 1.44 1.60 1.42 

Arches NP 222 3.22 2.50 2.40 2.71 

Capitol Reef NP 232 2.89 0.92 1.45 1.75 

Pecos Wilderness 248 1.49 1.72 1.94 1.72 

Wheeler Peak Wilderness 258 1.15 1.09 1.36 1.20 

Great Sand Dunes NM 269 1.09 1.00 1.10 1.07 

Maroon Bells-Snowmass WA 271 0.76 0.88 0.88 0.84 

Grand Canyon NP 285 1.56 0.80 0.44 0.93 
New Mexico Section 308 Regional Haze SIP 124

NM SRC02 Unit # 350450902, PNM SJ #1-4: SO2 Only (SO2 = 35,735 TPY) 

Annual Average Natural Conditions 

Class I Area with at least 1 receptor within 300 km of source

Minimum 

Distance 98th Percentile for Each Year 98th 

Class I Area (km) 2001 2002 2003 

3 year 

AVG 

Mesa Verde NP 40 2.78 3.17 3.14 3.03 

Weminuche Wilderness 98 1.28 1.23 0.89 1.13 

San Pedro Parks Wilderness 155 1.77 2.13 1.72 1.87 

La Garita Wilderness 169 0.81 0.89 0.70 0.80 

Canyonlands NP 170 2.65 1.79 2.06 2.17 

Black Canyon Gunnison NM 203 0.92 1.03 0.89 0.95 

Bandelier NM 210 1.17 1.62 1.24 1.34 

Petrified Forest NP 213 0.94 0.83 0.94 0.91 

West Elk Wilderness 216 0.75 0.79 0.59 0.71 

Arches NP 222 1.74 1.22 1.33 1.43 

Capitol Reef NP 232 1.68 1.47 1.32 1.49 

Pecos Wilderness 248 1.09 1.16 1.24 1.16 

Wheeler Peak Wilderness 258 1.00 0.86 1.06 0.97 

Great Sand Dunes NM 269 0.64 0.69 0.68 0.67 

Maroon Bells-Snowmass WA 271 0.54 0.62 0.36 0.51 

Grand Canyon NP 285 1.18 0.78 0.73 0.90 

NM SRC02 Unit # 350450902, PNM SJ #1-4: PM plus NOx (NOx = 38,763 TPY; PM = 3,884 

TPY) 

Annual Average Natural Conditions 

Class I Area with at least 1 receptor within 300 km of source

Minimum 

Distance 98th Percentile for Each Year 98th 

Class I Area (km) 2001 2002 2003 

3 year 

AVG 

Mesa Verde NP 40 4.27 4.06 3.46 3.93 

Weminuche Wilderness 98 1.74 2.28 1.76 1.93 

San Pedro Parks Wilderness 155 2.85 2.87 3.07 2.93 

La Garita Wilderness 169 1.15 1.36 1.30 1.27 

Canyonlands NP 170 4.39 3.33 2.91 3.54 

Black Canyon Gunnison NM 203 1.73 1.84 1.90 1.82 

Bandelier NM 210 1.77 2.29 2.31 2.12 

Petrified Forest NP 213 0.83 0.72 0.31 0.62 

West Elk Wilderness 216 1.26 1.50 1.64 1.47 

Arches NP 222 3.30 2.65 2.50 2.82 

Capitol Reef NP 232 3.06 0.95 1.50 1.83 

Pecos Wilderness 248 1.55 1.77 2.04 1.79 

Wheeler Peak Wilderness 258 1.20 1.12 1.40 1.24 

Great Sand Dunes NM 269 1.14 1.05 1.15 1.11 

Maroon Bells-Snowmass WA 271 0.78 0.91 0.91 0.87 

Grand Canyon NP 285 1.60 0.82 0.45 0.96 
New Mexico Section 308 Regional Haze SIP 125

10.3.2 Subject-to-BART Determination 

Once the "universe" of potentially-BART-eligible sources has been set, the State must make a 

determination about which of these sources are truly subject-to-BART. In order for a source to be subjectto-BART, a State must conclude that emissions of visibility impairing pollution from a BART-eligible 

source may reasonably be anticipated to cause or contribute to any visibility impairment in a mandatory 

Class I area. 

As noted in Section 10.3.1 above, NMED's process resulted in the determination that San Juan Generating 

Station is subject-to-BART. 

10.3.3 Determining BART 

Clean Air Act § 169A(g)(7) directs States to consider five factors in making BART determinations. The 

regional haze rule codified these factors in 40 CFR § 51.308(e)(1)(ii)(B), which directs States to identify 

the "best system of continuous emissions control technology" taking into account "the technology 

available, the costs of compliance, the energy and non-air quality environmental impacts of compliance, 

any pollution control equipment in use at the source, and the remaining useful life of the source." 

The BART regulations define BART as meaning "...an emission limitation based on the degree of 

reduction achievable through the application of the best system of continuous emission reduction for each 

pollutant which is emitted by ... [a BART-eligible source]. In its guidance, EPA was clear that each State 

must determine the appropriate level of BART control for each source that is determined to be subject-toBART. In making a BART determination, a State must consider the following factors: 

(1) The costs of compliance; 

(2) The energy and non-air quality environmental impacts of compliance; 

(3) Any existing pollution control technology in use at the source; 

(4) The remaining useful life of the source; and 

(5) The degree of improvement in visibility which may reasonably be anticipated to result from the 

use of such technology. 

To consider these factors, New Mexico applied the following 5 step processs as specified in the BART 

Guidelines at Appendix Y to 40 CFR Part 51: 

Step 1 – Identify All Available Retrofit Control Technologies 

Step 2 – Eliminate Technically Infeasible Options 

Step 3 – Evaluate Control Effectiveness of Remaining Control Technologies 

Step 4 – Evaluate Impacts and Document the Results 

a) Costs of Compliance 

b) Energy Impacts 

c) Air quality environmental impacts 

d) Non-air environmental impacts 

e) Remaining useful life 

Step 5 – Evaluate Visibility Impacts 
New Mexico Section 308 Regional Haze SIP 126

10.4 Summary of BART Control Analysis for PNM San Juan 

Based on the five factor analysis, the Department has determined that BART for Units 1-4 for PM is 

existing pulse jet fabric filter control technology and an existing emission rate of 0.015 lb/MMbtu. The 

Department’s determination of BART was based on the following results of the full five factor analysis: 

1. Each of Units 1-4 is equipped with a pulse jet fabric filter (PJFF) and is subject to a federallyenforceable emission limit of 0.015 lb PM/MMbtu. 

2. The Department reviewed both the cost-effectiveness and incremental cost-effectiveness of 

additional control technology (WESP) and found these costs to be excessive. See Table 3.0. 

3. There are no non-air impacts associated with the WESP technology. 

4. There are additional energy impacts associated with the WESP technology and the Department 

considers these costs to be reasonable. 

5. The Department reviewed the visibility improvement that resulted from the installation of the 

consent decree technology (PJFF and LNB/OFA) and that would result from the addition of 

WESP technology. The Department determined that on a facility-wide basis the visibility 

improved by 1.06 deciviews (dv) from the installation of the consent decree technology at Mesa 

Verde National Park (Mesa Verde). The installation of WESP would result in a facility-wide 

improvement of 0.62 dv at Mesa Verde. 

Based on the five factor analysis, the Department has determined that BART for Units 1-4 for NOx is 

SCR plus sorbent injection and an emission rate of 0.07 lb/MMbtu. The Department’s determination of 

BART was based on the following results of the five factor analysis, and additional information submitted 

in the BART analysis: 

1. The cost-effectiveness of SCR + sorbent technology ranges from $5,946/ton for Unit 4 to 

$7,398/ton for Unit 2, and the incremental cost-effectiveness of SCR + sorbent ranges from 

$1,691/ton for Unit 4 to $4,431/ton for Unit 2. 

2. The cost-effectiveness and incremental cost-effectiveness of SCR + sorbent technology is 

considered reasonable by the Department. These costs are in line with acceptable costeffectiveness values for BACT determinations, which involve a similar control technology 

evaluation process. 

3. Annual NOx emissions from the facility will be reduced by 16,100 tons from SCR + sorbent. 

4. The Department reviewed the visibility improvement that resulted from the installation of the 

SCR + sorbent technology. The Department determined that on a facility-wide basis the visibility 

improved by 1.34 deciviews (dv) from the installation of SCR + sorbent technology at Mesa 

Verde, 0.88 dv at San Pedro, 0.75 dv at Bandalier, 0.73 dv at Capital Reef, 0.67 dv at 

Canyonlands, 0.59 dv at Arches, 0.59 dv at Weminuche, 0.52 dv at Black Canyon, 0.49 dv at La 

Garita, 0.49 dv at West Elk, 0.44 dv at Grand Canyon, 0.43 dv at Pecos, 0.40 dv at Wheeler Peak, 

0.34 dv at Petrified Forest, 0.31 at Great Sand Dunes, and 0.28 dv at Maroon Bells. 

5. SCR + sorbent technology reduced the number of days that each Unit exceeded a 0.5 dv impact. 

For Unit 1, the number of days exceeding 0.5 dv was reduced from 46 days to 16 days; Unit 2’s 

impact decreased from 46 days to 16 days; Unit 3’s impact decreased from 68 days to 31 days; 

and Unit 4’s impact decreased from 67 days to 29 days. 

6. The installation of SCR + sorbent technology will result in additional energy impacts, no non-air 

environmental impacts, and the remaining useful life of 20 years did not further impact costs. 

None of the additional energy impacts prohibit selection of this technology. 
New Mexico Section 308 Regional Haze SIP 127

10.5 Visibility Improvement Resulting from BART Evaluation in New Mexico 

The visibility improvement resulting from the installation of BART that will be achieved in each Class I 

area as a result of the emission reduction achievable from San Juan Generating Station is shown in Figure 

10-1. The BART determination, including visibility modeling analysis, is included as Appendix A. 

Figure 10-1: Visibility Improvement from BART Controls at San Juan Generating Station 
New Mexico Section 308 Regional Haze SIP 128

CHAPTER 11: REASONABLE PROGRESS GOAL DEMONSTRATION 

11.1 Reasonable Progress Requirements 

Several steps for establishing reasonable progress goals were outlined in the RHR and are discussed in the 

following subsections. 

Calculate/Estimate Baseline and Natural Visibility Conditions 

Baseline visibility conditions were determined by the Western Regional Air Partnership (WRAP) 

Technical Support System (TSS) using the Interagency Monitoring of Protected Visual Environments 

(IMPROVE) algorithm. The IMPROVE algorithm followed the established guidelines presented in the 

RHR. To determine baseline visibility conditions, the average degree of visibility (expressed as dv) for 

the 20% least impaired days and the 20% worst impaired days was calculated, using IMPROVE air 

quality monitoring data, for each calendar year from 2000 to 2004. The IMPROVE monitoring program 

collects speciated PM2.5, and PM2.5 and PM10 mass. IMPROVE is a nationwide network which began in 

1988 and expanded significantly in 2000 in response to the EPA’s Regional Haze Rule (RHR). The 

Regional Haze Rule specifically requires data from this program to be used by states and tribes to track 

progress in reducing haze. The annual values were then averaged over five years to determine the baseline 

visibility condition values. Baseline visibility is discussed in detail in Chapter 7. 

Natural conditions are an estimate of the amount of visibility impairment that would occur if no humancaused visibility impairment existed. Natural conditions were determined by the WRAP through the 

Natural Haze Levels II Committee for the 20% worst visibility days and the 20% best visibility days 

using available monitoring data and the IMPROVE algorithm. The Natural Haze Levels II Committee 

was established in 2006 to review and refine the default approach. The committee included 

representatives from NOAA, NPS, Cooperative Institute for Research in the Atmosphere (CIRA), 

Regional Planning Organizations (RPOs) and industry representatives, and other participants. The final 

report of the committee can be found at: 

http://wrapair.org/forums/aoh/meetings/060726den/NaturalHazeLevelsIIReport.pdf. 

Additional information about the baseline and natural visibility impairment calculations can be found in 

Chapter 6. 

Determine the Uniform Rate of Progress (URP) 

The URP (also known as the glide slope), which was determined by the State of New Mexico for all 

mandatory Class I areas within the state, is the rate of visibility change necessary to achieve natural 

visibility conditions by the year 2064. The URP represents the slope between baseline visibility 

conditions in 2004 and natural visibility conditions in 2064. Using interpolation, the improvement 

necessary by 2018 to achieve natural visibility conditions in 2064 can be calculated. The URP is 

discussed in greater detail in Chapters 6 and 9. 
New Mexico Section 308 Regional Haze SIP 129

Table 11-1: 20% Best and Worst Days Baseline, Natural Conditions, and Uniform Rate of Progress 

Goal for New Mexico Class I Areas 

20% Worst Days 20% Best Days 

IMPROVE 

Monitor 

Name 

New Mexico 

Class I Area 

2000-04 

Baseline 

(dv) 

2018 URP 

Goal 

 (dv) 

2018 

Reduction 

Needed 

2064 Natural 

Conditions 

(dv) 

2000-04 

Baseline 

(dv) 

2064 Natural 

Conditions 

(dv) 

BAND1 Bandelier 

Wilderness 12.22 10.83 1.39 6.26 4.95 1.28 

BOAP1 

Bosque del 

Apache National 

Wildlife Refuge 

13.8 12.15 1.65 6.73 6.28 2.15 

GUMO1 Carlsbad Caverns 

National Park 17.19 14.73 2.46 6.65 5.95 0.99 

GILA1 Gila Wilderness 13.11 11.61 1.50 6.66 3.31 0.52 

WHPE1 Pecos/Wheeler 

Peak Wilderness 10.41 9.40 1.01 6.08 1.22 -0.56 

SACR1 Salt Creek 

Wilderness 18.03 15.41 2.62 6.81 7.84 2.12 

SAPE1 San Pedro Parks 

Wilderness 10.17 9.13 1.04 5.72 1.45 -0.72 

WHIT1 White Mountain 

Wilderness 13.7 12.09 1.61 6.8 3.55 0.66 

Four Factor Analysis 

In an effort to reduce visibility impairing air pollutants, emission control measures had to be evaluated. 

The four factor analysis process was established in the RHR and is discussed in detail in Section 11.2 of 

this chapter. Each emission control strategy, as required by the four factor analysis guidelines, was 

evaluated based on 1) the cost of compliance, 2) time necessary for compliance, 3) the energy and non-air 

quality environmental impacts of compliance, and 4) the remaining useful life of any existing source 

subject to such emission controls. 

Consultation With Other States 

According to the RHR, the State of New Mexico must consult with other states that may cause or 

contribute to visibility impairment in New Mexico Class I areas. For the State of New Mexico, 

consultations with other states contributing to visibility impairment in Class I areas were conducted 

through the WRAP. Additional information on the state consultations can be found in Chapter 2. 

Determination of Reasonable Progress Goals 

Reasonable progress goals, when established, demonstrate the amount of visibility improvement the State 

of New Mexico believes to be feasible, based on the four factor analysis and Clean Air Act (CAA) 

requirements, during the first planning period. The reasonable progress goal may be the same, less 

stringent, or more stringent than the visibility improvement based on the URP. The reasonable progress 

goals, and the logic used to determine the goals, are discussed in Section 11.3 of this chapter. 

11.2 Four Factor Analysis Performed for New Mexico Sources 

The four factor analysis, which is provided in the RHR, is a method for evaluating potential control 

strategies for facilities that are not eligible for Best Available Retrofit Technology (BART). The analysis 

considers 1) the cost of compliance, 2) the time necessary for compliance, 3) environmental impacts of 

compliance, and 4) the remaining useful life of the facility. 

The WRAP hired EC/R Incorporated (EC/R), headquartered in Chapel Hill, North Carolina, to complete 

the four factor analysis for specific source types throughout the WRAP region (Appendix B). In addition, 

EC/R completed a four factor analysis for specific sources in New Mexico (Appendix C). Control 

measures for SO2 and NOx were evaluated for selected sources in New Mexico. Data on emissions of 
New Mexico Section 308 Regional Haze SIP 130

volatile organic compounds (VOC) were also collected. In addition, although VOC emission control 

measures were not explicitly evaluated in the four factor analysis study by EC/R, the impacts of NOx and 

SO2 controls on VOC were calculated where co-control benefits would occur. 

11.2.1 Detailed Description of the Four Factors 

Cost of Compliance 

Both control costs and net annual costs were analyzed for all control measures identified by EC/R. 

Control costs cover direct and indirect capital costs. Examples of direct capital expenses includes the 

costs associated with purchased equipment, construction, installation, instrumentation and process 

controls, ductwork and piping, electrical components, and structural and foundation components. Indirect 

capital expenses include costs such as engineering and design, contractor fees, startup and performance 

testing, contingency costs, and process modifications. 

Net annual costs include the expenses associated with the typical operation of the control equipment over 

a year. Annual costs include items such as the utility expenses, labor, waste disposal expenses, and 

amortized costs of the capital investment. All cost estimates calculated by EC/R were updated to 2007 

dollars using the Marshall and Swift Equipment Cost Index or the Chemical Engineering Plant Cost 

Index, which are both published in the journal Chemical Engineering. 

Time Necessary for Compliance 

The time necessary for compliance includes the time needed for the State of New Mexico to develop and 

implement regulations for emissions controls, as well as the time the sources require to procure the capital 

to purchase the emission control equipment, design and fabricate the equipment, and to install the 

emission controls. 

Energy and Other Non-Air Quality Environmental Impacts 

Emission control devices often require some form of energy input to operate. To determine the energy 

requirements for a particular control device, the electricity needs, steam requirements, increased fuel 

requirements, and any additional energy inputs required were quantified. Only the direct energy 

requirements were considered; indirect energy needs, such as the amount of energy required to produce 

the fuel for the control device, were not analyzed. In addition, any impacts the control technologies had 

on other source processes, such as boiler efficiency, were not evaluated. 

Remaining Equipment Life at Source 

The remaining equipment life of the source will impact the cost of emission control technologies if the 

expected life of the source is less than the lifetime of the pollution control device being considered. 

Therefore, if the remaining equipment life is less than the lifetime of the pollution control device, the 

capital cost of the pollution control device is amortized for the remaining life of the emission source. The 

ages of major pieces of equipment were determined where possible, and compared with the service life of 

pollution control equipment. The impact of a limited useful life on the amortization period for control 

equipment was then evaluated, along with the impact on annualized cost-effectiveness. 

11.2.2 Source Selection Process for Four Factor Analysis 

To select the sources that would undergo the required four factor analysis, emission data for sources in 

New Mexico had to first be collected. Emissions assessments were initially based on 2002 emissions 

inventory in the WRAP Emissions Data Management System (EDMS) which consists of data submitted 

by the WRAP states in 2004. New Mexico then reviewed the emissions data and parameters from the 

EDMS used for this analysis and provided updated data when applicable. In some cases, detailed data on 

PM10 and PM2.5 emissions were not available from the WRAP inventory. Therefore, PM10 and PM2.5 data 
New Mexico Section 308 Regional Haze SIP 131

from the U.S. Environmental Protection Agency’s (EPA) 2002 National Emissions Inventory (NEI) were 

used to supplement the WRAP inventory where necessary. 

Once the important emission sources were identified within a given emission source category, a list of 

potential additional control technologies was compiled from a variety of sources, including control 

techniques guidelines published by the EPA, emission control cost models such as AirControlNET and 

CUECost, Best Available Retrofit Technology (BART) analyses, White Papers prepared by the Midwest 

Regional Planning Organization (MRPO), and a menu of control options developed by the National 

Association of Clean Air Agencies (NACAA). The options for each source category were then narrowed 

to a set of technologies that would achieve the emission reduction target under consideration. 

From this evaluation the following sources were identified as major emission sources for the WRAP 

states: 

• Reciprocal Internal Combustion Engines and Turbines; 

• Oil and Gas Exploration and Production Field Operations; 

• Natural Gas Processing Operations; 

• Industrial Boilers; 

• Cement Kilns; 

• Sulfuric Acid Manufacturing Plants; 

• Pulp and Paper Lime Kilns; and 

• Oil Refineries. 

Information regarding each of these sources is outlined in ER/C's analysis report, Supplementary 

Information for Four Factor Analyses by WRAP States in Appendix B. 

11.2.3 Four Factor Analyses for New Mexico 

A separate Four-factor analysis was conducted by ER/C for selected emission sources at three New 

Mexico petroleum refineries (Appendix C). The following facilities and emission sources were evaluated: 

• Navajo Refining Co., Artesia Refinery – Fluid Catalytic Cracking Unit (FCCU) #1, catalyst 

regeneration and process heater; 

• Western Refining Southwest, Bloomfield Refinery – FCCU #1, catalyst regeneration and 

process heater; and 

• Western Refining Southwest, Gallup Refinery – CO Boiler Unit #1 

Navajo Refining Co., Artesia Refinery

One unit, the Fluid Catalytic Cracking Unit (FCCU) #1, catalyst regeneration and process heater, at the 

Navajo Refining Co. was selected for the four factor analysis in New Mexico. The Navajo Artesia 

refinery FCCU has a capacity of 27,000 barrels per day (bbl/day). In catalytic cracking, the heavier 

fractions of crude petroleum are treated with a catalyst which breaks the petroleum molecules into lighter 

compounds. The catalyst is continuously cycled between the cracking and a separate regeneration reactor 

in order to burn off coke build-up. 

Six possible emission control devices were identified and analyzed for the FCCU regenerator and heater 

using the four factor analysis process: optimization of NOx reduction catalyst, selective catalytic 

reduction (SCR), low NOx burners (LNB), selective non-catalytic reduction (SNCR), flue gas 

recirculation (FGR), and ultra low NOx burners (ULNB). LNB technology reduces the amount of NOx 

produced by reducing the flame temperature. The flame temperature is reduced by controlling the fuel and 

air mixing, which creates a larger, branched flame. FRG entails re-circulating a portion of relatively cool 

exhaust gases back into the combustion process in order to lower the flame temperature and reduce NOx 

formation. With SNCR, an aqueous reagent, typically either ammonia or urea, is injected into the hot flue 
New Mexico Section 308 Regional Haze SIP 132

gas. The reagent reacts with the NOx in the gas to form N2 and water vapor. Similar to the SNCR 

technology, SCR technology uses ammonia to reduce NOx to N2 and H2O. However, with SCR the NOx 

in the flue gas reacts with the ammonia within a catalyst bed. The optimization of NOx reduction catalyst 

has already been completed and analyzed for the Navajo Refinery. 

Cost 

The estimated capital costs, annual costs, and the cost effectiveness for the possible emission control 

devices at the Navajo Refinery are shown in Table 11-2. For each option, the table gives an estimate of 

the capital cost to install the necessary equipment, and the total annual cost of control, including the 

amortized cost associated with the capital equipment cost. The table also shows the estimated cost 

effectiveness for each control measure, in terms of the cost per ton of emission reduction. While SCR is 

expected to be far more efficient in controlling NOx emissions than LNB or LNB and FRG, the estimated 

capital and annual costs are far higher than the costs associated with LNB or LNB and FRG. As shown in 

Table 11-2, NOx reductions using LNB or LNB and FRG technology are far more cost effective than the 

SNCR and SCR technologies. 

Table 11-2: Estimated Costs of Potential Emission Control Devices for FCCU #1 at Navajo Refining 

Co., Artesia Refinery 

 Cost Estimates 

Unit Control Technology 

Pollutant 

Controlled 

Estimated 

Control 

Efficiency (%) 

Estimate 

Capital Cost 

($1000) 

Annual Cost 

($1000/year) 

Cost Efficiency 

($/ton) 

FCCU 

Regenerator 

#22 

Optimization NOx 

reduction catalyst 

SCR 

NOx 

NOx 

47-59 

67-84 Not Available 260-320 2,500 

FCCU 

Heater 

LNB 

ULNB 

LNB and FGR 

SNCR 

SCR 

LNB and SCR 

NOx 

NOx 

NOx 

NOx 

NOx 

NOx 

40 

75-85 

48 

60 

70-90 

70-90 

76 

131 

161 

221 

483 

553 

8.1 

13 

17 

24 

56 

63 

5,100 

3,800-4,400 

9,000 

10,100 

15,600-20,100 

17,600-22,600 

Time Necessary for Compliance 

EC/R estimated that it would take nearly 61⁄2 years for reduction strategies to become effective. It was 

determined that up to 2 years will be needed for the state to develop the necessary rules to implement the 

strategy. EC/R estimated that sources may then require up to a year to procure the necessary capital to 

purchase control equipment. The Institute of Clean Air Companies (ICAC) has estimated that 

approximately 13 months is required to design, fabricate, and install SCR or SNCR technology for NOx 

control. However, the time necessary will depend on the type and size of the unit being controlled. For 

instance, state regulators’ experience indicates that closer to 18 months is required to install this 

technology. In the CAIR analysis, EPA estimated that approximately 30 months is required to design, 

build, and install SO2 scrubbing technology for a single emission source. The analysis by EC/R also 

estimated that up to an additional 12 months may be required for staging the installation process if 

multiple sources are to be controlled at a single facility. 

Energy and Non-Air Quality Environmental Impacts 

The energy required to operate the emission control devices, including additional fuel, electricity and 

steam, and the waste produced by the emission control devices, such as solid waste and wastewater, are 

shown in Table 11-3. As illustrated by the values in Table 11-2, none of the six technologies are expected 

to produce a significant amount of solid waste or any wastewater. The solid waste produced by the SCR 

technology would occur when the catalyst is changed. None of the technologies are expected to increase 

fuel consumption, though LNB may reduce the fuel consumption due to optimized fuel combustion. 
New Mexico Section 308 Regional Haze SIP 133

Table 11-3: Estimated Energy and Non-Air Environmental Impacts of Potential Emission Control 

Devices for FCCU #1 at Navajo Refining Co. 

 Energy and Non-Air Pollution Impacts 

Unit Control 

Technology 

Pollutant 

Controlled 

Potential 

Emission 

Reduction 

(tons/year) 

Electricity 

Requirement 

(kW) 

Solid Waste 

Generated 

(ton/hr) 

Waste Water 

Produced 

(gal/min) 

FCCU 

Regenerator 

#21 

optimization NOx 

reduction catalyst 

SCR 

NOx 

NOx 

72-90 

103-129 8,400 

~0.03 

0.073 

FCCU 

Heater 

LNB 

ULNB 

LNB and FGR 

SNCR 

SCR 

LNB and SCR 

NOx 

NOx 

NOx 

NOx 

NOx 

NOx 

1.6 

3-3.4 

1.9 

2.4 

2.8-3.6 

2.8-3.6 

3,300 

460 

8,400 

8,400 

0.073 

0.073 

A blank indicts that no impact is expected 

Remaining Equipment Life 

Information was not available on the age of the FCCU processes at the time of EC/R's analysis. However, 

industrial processes are often refurbished to extend their lifetimes. Therefore, the remaining lifetime of 

most equipment is expected to be longer than the projected lifetime of pollution control technologies 

which have been analyzed for these sources. 

Navajo Refining Co., Artesia Refinery FCCU #1 Four Factor Analysis Conclusion 

The process heater at Artesia Refinery is rated at 35 MMBtu/hr, has no controls, limits of SO2 - 2.2 tpy; 

NOx - 20.2 tpy; CO - 13.9 tpy; PM - 1.3 tpy. The FCCU Regenerator #21 exhaust is controlled by a wet 

scrubber to control SO2 and PM. Controls currently operated include Tertiary Cyclones & Caustic 

Scrubber, EMTROL CYTROL, and Monsanto Dynawave® Scrubber. After control emissions vented to 

atmosphere from FCCU-REGEN are: SO2 - 61.0 tpy; NOx - 101.9 tpy; CO - 106.8 tpy; PM - 109.5 tpy. 

Based on these relatively low levels of emissions and the factors discussed above, , NMED considers 

additional controls on the Artesia Refinery to be unnecessary at this time for the purposes of the visibility 

program. 

Western Refining Southwest, Bloomfield Refinery

One unit, the Fluid Catalytic Cracking Unit (FCCU) #1 catalyst regeneration and process heater at the 

Western Refining Southwest, Bloomfield Refinery was selected for the four factor analysis in New 

Mexico. Western Refining Southwest Bloomfield refinery FCCU has a capacity of 7,200 bbl/day. 

The Western Refining Bloomfield refinery FCCU regenerator is well controlled for particulate matter, 

with an electrostatic precipitation (ESP). No baseline controls have been identified for NOx or SO2 from 

the regenerator vent. As discussed above, a number of options are available for reducing NOx and SO2. 

Ten possible emission control devices for SO2 and NOx were identified and analyzed for the FCCU 

regenerator and heater using the four factor analysis process: catalyst additives for NOx reduction, low 

temperature oxidation technology (LoTOxTM), SCR, SNCR, catalyst additives for SO2 absorption, 

desulfurization of catalytic cracker feed, and wet scrubbing. Information regarding SCR, SNCR, LNB, 

ULNB, and FGR are discussed above. 

The LoTOxTM process has been developed to control NOx emissions in the catalytic cracking 

regenerator offgas. In this system, ozone is injected into the offgas to convert the nitrogen oxide (NO) and 

nitrogen dioxide (NO2) which comprise NOx into more highly oxidized forms of nitrogen such as 
New Mexico Section 308 Regional Haze SIP 134

dinitrogen pentoxide (N2O5). These more highly oxygenated compounds are more soluble in water, and 

are removed from the offgas stream in a wet scrubber. SO2 catalyst additives adsorb sulfur oxide 

compounds produced in the catalyst regenerator. These compounds are then converted to H2S in the 

catalytic cracking reactor, and exit this reactor with the cracked hydrocarbon stream. The H2S is 

eventually removed from the hydrocarbon stream in an amine treatment process, and then recovered in 

the sulfur recovery process. NOx catalyst additives promote the reduction of NOx formed to nitrogen and 

water. These catalysts promote the reduction reaction between carbon or carbon monoxide and nitrogen 

oxides inside the regenerator. Wet scrubbing brings polluted gas stream into contact with a scrubbing 

liquid, by spraying it with the liquid, by forcing it through a pool of liquid, or by some other contact 

method, so as to remove the pollutants. 

Cost 

The estimated capital costs, annual costs, and the cost effectiveness for the possible emission control 

devices at the Bloomfield Refinery are shown in Table 11-4. For each option, the table gives an estimate 

of the capital cost to install the necessary equipment, and the total annual cost of control, including the 

amortized cost associated with the capital equipment cost. The table also shows the estimated cost 

effectiveness for each control measure, in terms of the cost per ton of emission reduction. 

Table 11-4: Estimated Costs of Potential Emission Control Devices for FCCU at Western Refining 

Southwest, Bloomfield Refinery 

 Cost Estimates 

Unit Control Technology 

Pollutant 

Controlled 

Estimated 

Control 

Efficiency 

(%) 

Estimate 

Capital Cost 

($1000) 

Annual 

Cost 

($1000/ 

year) 

Cost 

Efficiency 

($/ton) 

FCCU 

Regenerator 

A-201 

Catalyst additives for 

NOx reductions 

LoTOxTM 

SNCR 

SCR 

Catalyst additives for 

SO2 absorption 

Desulfurization of 

catalytic cracker feed 

Wet scrubbing 

NOx 

NOx 

NOx 

NOx 

SO2

SO2

SO2

75-81 

85 

40-80 

85-92 

98 

98 

98 

Not Available 

Not Available 

Not Available 

Not Available 

Not Available 

Not Available 

Not Available 

Not 

Available 

80-100 

60-120 

120-130 

Not 

Available 

Not 

Available 

180-660 

Not Available 

1,700-2,000 

2,500 

2,500 

Not Available 

Not Available 

1,500-1,800 

FCCU 

Heater 

LNB 

ULNB 

LNB and FGR 

SNCR 

SCR 

LNB and SCR 

NOx 

NOx 

NOx 

NOx 

NOx 

NOx 

40 

75-85 

48 

60 

70-90 

70-90 

117 

199 

245 

337 

736 

843 

12 

20 

26 

37 

86 

97 

5,200 

3,800-4,300 

9,000 

9,900 

15,600-20,000 

17,600-22,500 

Time Necessary for Compliance 

As with Navajo Refinery, EC/R estimated that it would take nearly 61⁄2 years for reduction strategies to 

become effective. This includes 2 years for regulatory development, 1 year for capital acquisition, and 21⁄2 

years for designing, building and installing a scrubber, if this option is selected. If catalyst additives are 

used, time will be required to select and test the appropriate additives, and to determine the optimum feed 

rate for the additive. 

Energy and Non-Air Quality Environmental Impacts 

The energy required to operate the emission control devices, including additional fuel, electricity and 

steam, and the waste produced by the emission control devices, such as solid waste and wastewater, are 

shown in Table 11-5. 
New Mexico Section 308 Regional Haze SIP 135

The use of catalyst additives for the FCCU or desulfurization of the FCCU feed stream involve process 

modifications which are tailored to each specific refinery. Therefore, it was not possible to quantify the 

energy and non-air pollution impacts of these modifications within the time limitations of this project. 

However, process modifications to desulfurize the FCCU feed stream would generally require increases 

in catalytic hydrotreatment processing. These modifications may increase the generation of spent catalyst, 

which would need to be treated as a solid waste or a hazardous waste. Catalyst additives for reducing 

NOx and SO2 emissions from fluid catalytic cracking units are likely to result in increased generation of 

spent catalyst, which would have to be disposed as hazardous waste. These catalyst additives may also 

result in increases in fuel consumption. 

A LoTOxTM scrubbing system or wet scrubbing system applied to the fluidized catalytic cracking unit 

would require electricity to operate fans and other auxiliary equipment, and would produce a wastewater 

stream which would require treatment. In addition, sludge from the scrubber would require disposal as 

solid waste. As stated earlier SCR and SNCR systems would also require electricity for fans, and SCR 

systems would produce additional solid waste because of spent catalyst disposal. 

Table 11-5: Estimated Energy and Non-Air Environmental Impacts of Potential Emission Control 

Devices for FCCU #1 at Western Refining Southwest, Bloomfield Refinery 

 Energy and Non-Air Pollution Impacts 

Unit Control Technology 

Pollutant 

Controlled 

Potential 

Emission 

Reduction 

(tons/year) 

Electricity 

Requirement 

(kW) 

Solid Waste 

Generated 

(ton/hr) 

Waste 

Water 

Produced 

(gal/min) 

FCCU 

Regenerator 

#21 

Catalyst additives for 

NOx reductions 

LoTOxTM 

SNCR 

SCR 

Catalyst additives for 

SO2 absorption 

Desulfurization of 

catalytic cracker feed 

Wet scrubbing 

NOx 

NOx 

NOx 

NOx 

SO2

SO2

SO2

43-46 

49 

23-46 

49-53 

364 

364 

364 

1,100 

460 

8,400 

1,100 

~0.03 

1.9 

0.073 

0.03 

<0.03 

3.7 

3.7 

FCCU 

Heater 

LNB 

ULNB 

LNB and FGR 

SNCR 

SCR 

LNB and SCR 

NOx 

NOx 

NOx 

NOx 

NOx 

NOx 

2.4 

4.6-5.2 

2.9 

3.7 

4.3-5.5 

4.3-5.5 

3,300 

460 

8,400 

8,400 

0.073 

0.073 

A blank indicts that no impact is expected 

Remaining Equipment Life 

Information was not available on the age of the FCCU processes at the time of EC/R's analysis. However, 

industrial processes often refurbished to extend their lifetimes. Therefore, the remaining lifetime of most 

equipment is expected to be longer than the projected lifetime of pollution control technologies which 

have been analyzed for these sources. 

Western Refining Southwest, Bloomfield Refinery FCCU #1 Four Factor Analysis Conclusion 

Bloomfield Refinery has been in “suspended operations” since November 2009. The FCCU is subject to 

NOx and SO2 reductions according to the Catalyst Additive Program required by an Amended Stipulation 

and Final Order (AFSO) as the result of an enforcement action. The Order requires that Bloomfield 

Refinery decrease FCCU NOx down to 20 ppmvd and SO2 down to 25 ppmvd (both at 0% O2) by 
New Mexico Section 308 Regional Haze SIP 136

December 31, 2010. If these emissions limits are not met, the ASFO has complex emissions offset 

requirements. NMED has determined that additional controls for regional haze are not required. 

Western Refining Southwest, Gallup Refinery 

One unit, CO Boiler Unit #1, at the Western Refining Southwest, Gallup Refinery was selected for the 

four factor analysis in New Mexico. The Western Refining Gallup refinery FCCU has a capacity of 8,500 

bbl/day. 

The Gallup Refinery uses a CO boiler to combust CO and volatile organic compound (VOC) off-gases 

produced by the refinery. The steam generated by the boiler is used as process steam at the refinery. The 

CO boiler is uncontrolled. Eight possible emission control devices for SO2 and NOx were identified and 

analyzed for the CO boiler using the four factor analysis process: LNB with overfire air (OFA); LNB, 

OFA, and FGR; SCR; SNCR; dust sorbent injection (DSI), spry dryer absorber (SDA); and flue gas 

desulfurization. 

NOx emissions from a CO boiler can be controlled using a variety of combustion modifications including 

overfire air (OFA), LNB, FGR, and combinations of these technologies. Add-on control systems such as 

SCR and SNCR can also be used to reduce NOx emissions from boilers. In SCR, the flue gas is treated 

with a small quantity of ammonia (NH3) in a catalyst bed. The ammonia reacts with NOx to produce 

nitrogen gas (N2). Alternatively, urea [(NH3)2CO] can be added instead of ammonia. In this case, the 

urea decomposes to produce ammonia, which reacts with NOx. SNCR also involves the addition of 

ammonia or urea to reduce NOx, but without a catalyst. SNCR is less efficient at reducing NOx than 

SCR, but is also generally less expensive. SNCR can also be used in situations where flue gas 

contaminants would poison the SCR catalyst. 

It should be noted that SCR and SNCR for controlling NOx require injection of ammonia (NH3), urea 

[(NH3)2CO], or other nitrogen compounds into the exhaust stream. These chemicals react with NOx to 

chemically convert the pollutant to elemental nitrogen (N2). However, the use of these chemicals 

generally results in ammonia emissions, termed ammonia slip. 

Emissions of SO2 can be reduced by using DSI, spray dryer absorber SDA, or flue gas desulfurization 

FGD. DSI uses dry limestone to react with the SO2 in the flue gas. The reacted limestone is then collected 

in a particulate control device, The SDA process is similar to the DSI process, except that a limestone 

slurry is injected into the flue gas where it reacts with the SO2 and is removed in a particulate control 

device. FGD involves the flue being passed through a vessel where it is contacted with an alkaline 

solution which reacts with the flue gas SO2 to form a sulfate particulate. The sulfate particulate is 

removed in the system and the used alkaline solution is recycled through the process. 

Cost 

The estimated capital costs, annual costs, and the cost effectiveness for the possible emission control 

devices at the Bloomfield Refinery are shown in Table 11-6. For each option, the table gives an estimate 

of the capital cost to install the necessary equipment, and the total annual cost of control, including the 

amortized cost associated with the capital equipment cost. The table also shows the estimated cost 

effectiveness for each control measure, in terms of the cost per ton of emission reduction. 
New Mexico Section 308 Regional Haze SIP 137

Table 11-6: Estimated Costs of Potential Emission Control Devices for CO Boiler at Western 

Refining Southwest, Gallup Refinery 

 Cost Estimates 

Unit Control Technology 

Pollutant 

Controlled 

Estimated 

Control 

Efficiency (%) 

Estimate 

Capital Cost 

($1000) 

Annual Cost 

($1000/ year) 

Cost 

Efficiency 

($/ton) 

CO Boiler 

Unit 10 

LNB with OFA 

LNB, OFA, and FGR 

SNCR 

SCR 

DSI 

SDA 

FGD 

NOx 

NOx 

NOx 

NOx 

SO2

SO2

SO2

30-50 

30-50 

30-75 

40-90 

50-90 

80-90 

80-90 

0.5-0.7 

0.8-1.0 

0.5-0.7 

1.5-2.0 

1.5-2.0 

1.5-2.0 

1.5-2.0 

80-110 

125-170 

320-440 

400-600 

720-970 

1,380-1,860 

1,150-1,560 

2,500-5,600 

3,800-8,700 

6,600-22,500 

6,800-10,200 

1,100-3,400 

2,200-3,300 

1,800-2,800 

Time Necessary for Compliance 

EC/R estimated that it would take nearly 5 1/2 years to achieve emission reductions for the CO boiler at 

the Western Refinery in Gallup. This includes 2 years for regulatory development, 1 year for capital 

acquisition, and 11⁄2 years for designing, building and installing NOx controls. 

Energy and Non-Air Quality Environmental Impacts 

The energy required to operate the emission control devices, including additional fuel, electricity and 

steam, and the waste produced by the emission control devices, such as solid waste and wastewater, are 

shown in Table 11-7 below. 

Table 11-7: Estimated Energy and Non-Air Environmental Impacts of Potential Emission Control 

Devices for CO Boiler at Western Refining Southwest, Gallup Refinery 

 Energy and Non-Air Pollution Impacts 

Unit Control Technology 

Pollutant 

Controlled 

Potential 

Emission 

Reduction 

(tons/year) 

Electricity 

Requirement 

(kW) 

Solid Waste 

Generated 

(ton/hr) 

Waste Water 

Produced 

(gal/min) 

FCCU 

Regenerator 

#21 

LNB with OFA 

LNB, OFA, and FGR 

SNCR 

SCR 

DSI 

SDA 

FGD 

NOx 

NOx 

NOx 

NOx 

SO2

SO2

SO2

20-33 

20-33 

20-49 

26-59 

352-633 

563-633 

563-633 

3,300 

460 

8,400 

1,207 

836 

2,387 

0.073 

6.7 

8.0 

7.0 

3.7 

84 

67 

148 

A blank indicts that no impact is expected 

Remaining Equipment Life 

Information was not available on the age of the CO boiler at the time of EC/R's analysis. However, 

industrial processes often refurbished to extend their lifetimes. Therefore, the remaining lifetime of most 

equipment is expected to be longer than the projected lifetime of pollution control technologies which 

have been analyzed for these sources. 

Western Refining Southwest, Gallup Refinery CO Boiler #1 Four Factor Analysis Conclusion 

The Gallup FCCU is a “partial-burn” type, in which high-CO offgas is fed to a CO Boiler. The CO Boiler 

was recently chosen as one Western wishes to use to demonstrate compliance with the Covered Heaters 

and Boilers NOx Reduction requirement of the ASFO, dated January 22, 2009. After modifications 

(which will include low-NOx burners, increase in capacity from 50 MMBtu/hr to 70 MMBtu/hr, and 

addition of water tempering), the new NOx emission rate will be 0.040 lb/MMBtu. The CO Boiler is 

otherwise uncontrolled. 
New Mexico Section 308 Regional Haze SIP 138

The FCCU is subject to NOx and SO2 reductions according to the Catalyst Additive Program required by 

the ASFO. The Order requires that Gallup decrease FCCU NOx to 20 ppmvd and SO2 to 25 ppmvd (both 

at 0% O2) by December 31, 2010. If these emissions limits are not met, the ASFO has complex emissions 

offset requirements. NMED has determined that additional controls for the visibility program are not 

required. 

11.3 Setting Reasonable Progress Goals 

Under Section 308(d)(1) of the Regional Haze Rule, states must “establish goals (expressed in deciviews) 

that provide for reasonable progress towards achieving natural visibility conditions” for each Class I area 

of the state. These RPGs must provide for an improvement in visibility for the most impaired visibility 

days, and ensure no degradation for the least impaired visibility days over the same period. The RPGs are 

interim goals that represent incremental visibility improvement over time, in this case out to the year 

2018, to be compared to the 2018 Uniform Rate of Progress (URP) glide slope. Based on the steps 

outlined in Section 11.1 and the Four-Factor Analysis in Section 11.2, NMED has established RPGs for 

each of New Mexico’s seven Class I areas, as described below. These RPGs are based primarily on 

results of the CMAQ modeling described in Section 9.2, and on the four-factor analysis on major source 

categories. 

Table 11-8 shows that for the 20% best days, the RPGs show an improvement over baseline conditions 

for most of New Mexico's Class I areas. For the 20% worst days, the RPGs are short of the 2018 URP, 

but are justified based on the demonstration provided below. 

Table 11-8: Reasonable Progress Goals for 20% Worst Days and 20% Best Days for New Mexico 

Class I Areas 

20% Worst Days 20% Best Days 

New Mexico 

Class I Areas 

Baseline 

Condition 

(dv) 

2018 Uniform 

Progress Goal 

(dv) 

2018 Reasonable 

Progress Goal 

(dv) 

Baseline 

Conditions 

(dv) 

2018 Reasonable 

Progress Goal 

(dv) 

Bandelier 

Wilderness 12.22 10.83 11.9 4.95 4.89 

Bosque del 

Apache National 

Wildlife Refuge 

13.8 12.15 13.59 6.28 6.1 

Carlsbad 

Caverns 

National Park 

17.19 14.73 16.92 5.95 6.12 

Gila Wilderness 13.11 11.61 15.14 3.31 3.44 

Salt Creek 

Wilderness 18.03 15.41 17.07 7.84 7.43 

San Pedro Parks 

Wilderness 10 9.13 9.94 1.45 1.24 

White Mountain 

Wilderness 13.7 12.09 13.26 3.55 3.41 

Wheeler Peak 

Wilderness 10.41 9.40 10.23 1.22 1.12 

Demonstration That the RPGs for 20 Percent Best and Worst Days are Reasonable 

EPA guidance indicates that “States may establish an RPG that provides for greater, lesser or equivalent 

visibility improvement as that described by the glidepath.” The 2018 RPGs identified in Figure 11-8 for 

20 percent worst days show an improvement in visibility, although less than the 2018 URP, except for the 
New Mexico Section 308 Regional Haze SIP 139

Gila Wilderness. NMED believes that RPGs are reasonable for all seven of the New Mexico's mandatory 

Class I areas, as follows 

11.3.1 Bandelier Wilderness Area 

There is an improvement in visibility for Bandelier from baseline conditions to the modeled projected 

visibility in 2018. This improvement is less than the URG for Bandelier, but this is primarily due to OMC 

(Figure 11-1). As Figure 9-43 shows, this high level of OMC for BAND is primarily due to natural fires 

locally and regionally. Emissions from natural sources greatly affect the State’s ability to meet the 2018 

deciview URP goal. The State has little or no control over OC, EC, and PM2.5 associated with natural fire. 

Prolonged droughts in the West have resulted in extensive wildfires. The idea of setting deciview URP 

goals was developed before the causes of haze in the West were well understood. The extensive technical 

analysis of the causes of haze conducted by the WRAP has led to a better understanding of the role of 

wildfire. As long as there are wildfires in the Western United States, there will be significant impact to 

visibility in Class I areas and there is little states can do about it. 

Figure 11-1: Uniform Rate of Progress Comparison to Reasonable Progress Goals for Bandelier 

Uniform Rate of Progress Vs. Reasonable Progress Goal for 

BAND

0

2

4

6

8

10

12

14

16

SO4 NO3 OMC EC Soil CM SeaSalt

Extinction 1/Mm

2018 Uniform Rate of Progress 2018 Projected Visibility

11.3.2 Bosque del Apache National Wildlife Refuge 

There is some improvement in visibility from baseline to 2018 projected for BOAP. Although less than 

URP, the State believes this lesser improvement is once again due to natural sources. Two of the primary 

sources of emissions at BOAP are OMC and CM. Wildfires in this region are common, causing increases 

in OMC. High winds are also very common across the state particularly during the spring months (MarchMay) increasing CM and SOIL emissions. Due to the limited amount of control that the State has over 

these natural occurrences, the State believes that the progress projected for BOAP is reasonable. Sulfate is 

also a factor in visibility impairment in BOAP. 
New Mexico Section 308 Regional Haze SIP 140

Figure 11-2: Uniform Rate of Progress Comparison to Reasonable Progress Goals for Bosque del 

Apache 

Uniform Rate of Progress Vs. Reasonable Progress Goal for 

BOAP

0

2

4

6

8

10

SO4 NO3 OMC EC Soil CM SeaSalt

Extinction 1/Mm

2018 Uniform Rate of Progress 2018 Projected Visibility

11.3.3 Carlsbad Caverns National Park 

The monitor for Carlsbad Caverns National Park is the closest one to Mexico in the VISTAS network for 

New Mexico's Class I areas. New Mexico has historically received pollution from international sources 

affecting air quality as well as visibility in the state. GUMO is showing some improvement in visibility 

from baseline to 2018 projected, but is hindered by international and interstate contributions. As Section 

9.4.3 shows, international and interstate emissions are a significant contributor to SO4, CM, and OMC in 

New Mexico. Although New Mexico continues to work with Mexico and Texas on air quality issues 

within the southern region of the state, New Mexico has no control or jurisdiction over emissions coming 

from Mexico or Texas. Future work is needed on the federal level to determine the extent of emission 

contributions from Mexico on bordering states for regional haze and the National Ambient Air Quality 

Standards. Due to the lack of information available on emissions from Mexico and the jurisdiction to 

control a majority of the emissions affecting GUMO, New Mexico believes the improvement projected 

for 2018 is reasonable. 
New Mexico Section 308 Regional Haze SIP 141

Figure 11-3: Uniform Rate of Progress Comparison to Reasonable Progress Goals for Carlsbad 

Caverns 

Uniform Rate Of Progress Vs. Reasonable Progress Goals GUMO

0

2

4

6

8

10

12

14

16

18

SO4 NO3 OMC EC Soil CM SeaSalt

Extinction 1/Mm

2018 Uniform Rate of Progress 2018 Projected Visibility

11.3.4 Gila Wilderness 

The Gila Wilderness is the only Class I area in New Mexico that showed an increase in visibility 

impairment from baseline to 2018 projected rather than a decrease. As Figure 11-4 below shows, organic 

matter is the primary source of visibility impairment within GILA, but the area is also affected by SO4

and EC emissions. Contributions of OMC and EC, as shown in Section 9.4.4, to visibility impairment in 

GILA are primarily from wildfires both locally and regionally. Controlled burns conducted under New 

Mexico's Smoke Management Program are often used as a forest management tool in this area, but the 

emissions from wildfires affecting visibility in GILA are more than ten times greater than the emissions 

from controlled burns. Wildfires are a common occurrence throughout the state and regardless of where 

they occur, New Mexico has little to no control over the emissions that are generated from them. 

Gila Wilderness is affected by SO2 emissions from New Mexico as well as interstate and international 

source, as shown in Section 9.4.4. BART Implementation will assist in reducing SO2 emissions generated 

in New Mexico, but will not have any affected on interstate or international sources of SO2. Due to the 

limited control that New Mexico has for a majority of these emissions, New Mexico believes that the 

progress projected for GILA is reasonable. 
New Mexico Section 308 Regional Haze SIP 142

Figure 11-4: Uniform Rate of Progress Comparison to Reasonable Progress Goals for Gila 

Uniform Rate of Progree Vs. Reasonable Progress Goal for GILA

0

5

10

15

20

25

SO4 NO3 OMC EC Soil CM SeaSalt

Extinction 1/Mm

2018 Uniform Rate of Progress 2018 Projected Visibility

11.3.5 Pecos / Wheeler Peak Wilderness Areas 

Wheeler Peak is located in the northern region of the state near the San Juan Basin. As with San Pedro 

Parks, the Class I area's close proximity to two major point sources as well as extensive oil and gas 

development is potentially the cause of limited visibility improvement at WHPE. New Mexico has 

initiated several different programs in the north eastern region of the state to control SO2 and NOx 

emissions. In 2003, New Mexico developed an Ozone Early Action Compact (EAC) for San Juan County. 

As part of the EAC, New Mexico developed a voluntary emission reduction programs called VISTAS

(Voluntary Innovated Strategies for Today's Air Standards). The purpose of VISTAS is to identify, 

promote, and implement cost-effective technologies and Best Management Practices to reduce air 

pollution affecting northwestern New Mexico, including ozone, haze, and greenhouse gases. San Juan 

VISTAS is open to industries, municipalities, and other organizations in San Juan, Rio Arriba, and 

Sandoval Counties. 

The Consent Decree with San Juan Generating Station will also benefit visibility at Wheeler Peak. The 

reductions required by the Consent Decree outlined above, will assist in reducing SO2 and NOx emissions 

within the region. As discussed in Chapter 10, the Department subsequently determined that additional 

controls for NOx are required to satisfy BART requirements. Because the BART determination was 

made after the WRAP’s CMAQ analysis was completed, the additional improvements visbility in 2018 

expected from these controls are not reflected in this modeling Most of the initiatives put in place by New 

Mexico for emission reductions in this region of the state are fairly new and will take some time to show 

their full benefits, due to this fact the state believes that the projected 2018 visibility improvements for 

WHPE are reasonable. 
New Mexico Section 308 Regional Haze SIP 143

Figure 11-5: Uniform Rate of Progress Comparison to Reasonable Progress Goals for Wheeler 

Peak 

Uniform Rate of Progress Vs. Reasonable Progress Goal for 

WHPE

0

1

2

3

4

5

6

7

8

9

SO4 NO3 OMC EC Soil CM SeaSalt 

Extinction 1/Mm

2018 Uniform Rate of Progress 2018 Projected Visibility

11.3.6 Salt Creek Wilderness Area 

The Salt Creek Wilderness area is located in Chavez County in the southeastern region of the state on the 

Permian Basin. The Permian Basin is 250 miles (mi) wide and 300 mi long and stretches from 

southeastern New Mexico into western Texas. In 2006, there were a total of 6,054 oil and gas wells in 

Chavez County alone. The State believes that the level of local and regional oil and gas development and 

wind blown dust from high wind exceptional event are the primary factors in the limited visibility 

improvement from baseline to 2018 projected for SACR. The second largest category of stationary 

sources in the West is oil and gas development and production. Increased oil and gas development is 

expected in many areas of the West, due in large part to increased leasing to oil and gas operators on 

Federal land. The WRAP has developed the first comprehensive oil and gas inventory in the Western 

United States, and many states are moving forward with evaluating control options. New Mexico is 

evaluating and testing control strategies, but the specific strategies are not ready for incorporation into this 

first round of regional haze SIPs. Control options for ozone are being evaluated simultaneously and the 

State believes that many co-benefits from controlling emissions for ozone will be realized under the 

regional haze program. Numerous additional emission reductions from oil and gas are expected over the 

next ten-year period. 

In 2005, New Mexico was awarded grant funding from WRAP to develop a State SIP Pilot Study on 

visibility impairment caused by dust in one of New Mexico's Class I areas. The area chosen for the pilot 

study was SACR. The New Mexico Dust SIP Pilot for the Salt Creek Wilderness Area determined that 

CM and SOIL emissions affecting SACR were local, interstate and international in nature as shown in 

WEP Section 9.4.6. Many of the local emissions were caused by wind-blown dust from high wind 

exceptional events. Based the state's limited ability to control CM emissions affecting SACR and the 
New Mexico Section 308 Regional Haze SIP 144

Uniform Rate of Progress Vs. Reasonable Progress Goals SACR

0

2

4

6

8

10

12

14

16

SO4 NO3 OMC EC Soil CM SeaSalt

Extinction 1/Mm

2018 Uniform Rate of Progress 2018 Projected Visibility

anticipate reduction in the oil and gas emissions, New Mexico believes that the projected visibility 

improvement is reasonable. 

Figure 11-6: Uniform Rate of Progress Comparison to Reasonable Progress Goals for Salt Creek 

11.3.7 San Pedro Parks Wilderness Area 

There is an improvement in visibility for San Pedro Parks from baseline conditions to the modeled 

projected visibility in 2018. This improvement is less than the URG for San Pedro Parks, but this is 

primarily due to OMC, SO4, and NO3 (Figure 11-6). As Section 9.4.7 shows, this high level of OMC for 

San Pedro Parks is primarily due to natural fires locally and regionally. As with Bandelier, this area was 

heavily affected by the Cerro Grande fire in 2000 and continues to be affected by regional and local 

wildfires. 

San Pedro Parks is located in the northern region of the state near the San Juan basin. The area is also 

within close proximity to two coal fired power plants, one that is located on the Navajo Nation. The area's 

close proximity to two major point sources as well as extensive oil and gas development is potentially the 

cause of limited visibility improvement for SO4 at San Pedro Peak. In 2005, PNM San Juan Generating 

Station located in San Juan County, NM signed a Consent Decree with the Grand Canyon Trust, Sierra 

Club, and the New Mexico Environment Department to reduce emissions for NOx, SO2, particulate 

matter (PM) and mercury. The consent decree required PNM to reduce annual SO2 emissions by at least 

90 percent for four of their fossil fuel-fired steam generating units (Units 1, 2, 3, and 4); a PM emission 

rate not to exceed 0.015 lb/MMBTU for Units 1, 2, 3, and 4); and a 30 day emission rate not to exceed 

0.30 lb/MMbtu for NOx. All required emissions controls were to be in place by spring of 2009. As 

discussed in Chapter 10, the Department subsequently determined that additional controls for NOx are 

required to satisfy BART requirements. Because the BART determination was made after the WRAP’s 

CMAQ analysis was completed, the additional improvements visbility in 2018 expected from these 

controls are not reflected in this modeling. 
New Mexico Section 308 Regional Haze SIP 145

Figure 11-7: Uniform Rate of Progress Comparison to Reasonable Progress Goals for San Pedro 

Parks 

Uniform Rate of Progress Vs Reasonable Progress Goals SAPE

0

1

2

3

4

5

6

7

8

SO4 NO3 OMC EC Soil CM SeaSalt

Extinction 1/Mm

2018 Uniform Rate of Progress 2018 Projected Visibility

11.3.8 White Mountain Wilderness Area 

There is some improvement in visibility from baseline to 2018 projected for WHIT. The primary 

emissions affecting visibility in WHIT are SO4, OMC, and CM. The White Mountain Wilderness area is 

within close proximity to the Permian Basin and is thus potentially impacted by oil and gas development 

in the region. This area is also affected by natural emissions from wild fires and wind blown dust from 

high wind exceptional events. A WRAP study conducted in 2006 by the Desert Research Institute (DRI) 

for the New Mexico Dust SIP Pilot for the Salt Creek Wilderness Area determined that CM emissions 

affecting WHIT are from local and international sources. White Mountain is located just to the east of 

White Sands National Monument, which includes 275 square mi of gypsum sand dunes. The study 

developed by DRI indicates that White Sands is one of the major sources of CM emissions affecting 

WHIT, particularly during high wind events. The area is also heavily affected by CM emissions from 

interstate sources (see Section 9.4.8). 

The high level of OMC at WHIT is primarily due to local wildfires and interstate emissions. SO4 levels at 

WHIT are affected heavily by international emissions, as shown in Section 9.4.8. The SO2 cap and trade 

program initiate by New Mexico under the 309 program will assist in reducing SO2 emissions generated 

in New Mexico, but will not have any affect on international sources of SO2. Due to the limited control 

that New Mexico has over a majority of these emissions, New Mexico believes that the progress projected 

for WHIT is reasonable. 
New Mexico Section 308 Regional Haze SIP 146

Figure 11-8: Uniform Rate of Progress Comparison to Reasonable Progress Goals for White 

Mountain 

Uniform Rate of Progress Vs. Reasonable Progress Goal for WHIT

0

1

2

3

4

5

6

7

8

9

10

SO4 NO3 OMC EC Soil CM SeaSalt

Extinction 1/Mm

2018 Uniform Rate of Progress 2018 Projected Visibility

11.4 Conclusions for State-Wide Reasonable Progress 

Overall for New Mexico the predominate pollutants affecting the state's ability to meet URP goals at our 

Class I areas are OMC, CM and SO4. Much if not all of the source contributions for OMC and CM are 

natural. Much of the west is affected by wildfire and windblown dust from high wind exceptional events, 

particularly during droughts. These naturally occurring events are prevalent throughout the state and 

affect all of the Class I areas in New Mexico. The State has developed a Smoke Management Program for 

controlled burns and Natural Event Action Plans for anthropogenic sources of windblown dust, but the 

effect that these types of emissions have on visibility in New Mexico's Class I area is minimal compared 

to the naturally generated emissions. As Figure 11-9 below shows, over 70 percent of OMC emissions 

that affect New Mexico's Class I areas are due to wildfires and over 65% of CM emissions are from windblown dust. At present, the State has initiated programs to control sources of these pollutants where they 

are controllable; unfortunately the state has no control now or in the future over natural events that may 

affect visibility impairment within the State's Class I areas. 
New Mexico Section 308 Regional Haze SIP 147

Figure 11-9: OMC and EC Emissions Affecting New Mexico's Class I Areas

OMC and CM Emissions for New Mexico's Class I Areas

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

OMC 2000-04 OMC Prp18d CM 2000-04 CM Prp18b

Percentage

WB Dust

Fugitive Dust

Road Dust

Off-Road Mobile

On-Road Mobile

Off-Shore

WRAP Area O&G

Area

Biogenic

All Fire

Natural Fire

Anthro Fire

Point

Emissions from sources outside the WRAP modeling domain (CENWRAP and international emissions) 

also affect the State’s ability to meet the 2018 URP goal. The analysis in Chapter 9 of this Plan containing 

the weighted emission potential results show the emissions from interstate and international sources are a 

significant contributor to sulfate and coarse mass concentrations at the monitors in New Mexico's Class I 

areas. As Figure 11-10 below shows, sources outside of the WRAP, contribute to more than 50% of the 

SO4 and CM emissions affecting New Mexico's Class I areas. Contributions from outside of the WRAP 

also affect OMC emissions in New Mexico, but to a lesser degree. 

New Mexico is currently a member of the Paso del Norte Joint Advisory Committee (JAC). The Joint 

Advisory Committee includes the communities of Ciudad Juárez, Chihuahua, El Paso, Texas, and Doña 

Ana County, New Mexico. The JAC is a binational committee made up of private citizens, private sector 

representatives, university officials, federal, state, and local government officials, and non-governmental 

environmental and public health organizations. Although New Mexico has been an active participant in 

the JAC and has worked with the committee to assist in decreasing emissions within the Paso del Norte 

Airshed, this work only covers a small portion of New Mexico, Texas, and Mexico. Although New 

Mexico has no control over international emissions, the state feels very strongly that unless future work is 

conducted by the federal government to determine the extent of international emissions affecting areas 

with the United States, improvements in visibility and general air quality will continue to elude states. 
New Mexico Section 308 Regional Haze SIP 148

Figure 11-10: Impacts from Sources Outside of WRAP on New Mexico 

Impact from Interstate/International Sources

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

SO4 OMC CM

Percentage

NM

Mex 

CEN 
New Mexico Section 308 Regional Haze SIP 149

CHAPTER 12: LONG-TERM STRATEGY (LTS) 

12.1 Overview 

The Regional Haze Rule requires states to submit a 10-15 year long-term strategy (LTS) to address 

regional haze visibility impairment in each Class I area in the state, and for each Class I area outside the 

state which may be affected by emissions from the state. The LTS must include enforceable measures 

necessary to achieve reasonable progress goals, and identify all anthropogenic sources of visibility 

impairment considered by the state in developing the long-term strategy. Where the state contributes to 

Class I visibility impairment in other states it must consult with those states and develop coordinated 

emission management strategies, and demonstrate it has included all measures necessary to obtain its 

share of the emission reductions. If the state has participated in a regional planning process, the state must 

include measures needed to achieve its obligations agreed upon through that process. 

Summary of all Anthropogenic Sources of Visibility Impairment Considered in Developing the Long-Term 

Strategy 

Section 51.308(d)(3)(iv) of the Regional Haze Rule requires the identification of “all anthropogenic 

sources of visibility impairment considered by the State when developing its long-term strategy.” Chapter 

8 of this Plan describes New Mexico's statewide emissions, including projections of emissions reductions 

from anthropogenic sources from 2002 to 2018. Section 9.3 of this Plan provides source apportionment 

results, including projected reductions from anthropogenic sources during the same period. Chapter 9 

addresses anthropogenic sources from all potential sources in the world. Together, these chapters show 

the major anthropogenic sources affecting regional haze in New Mexico and in the West. Chapter 11 

further describes the major anthropogenic source categories evaluated through the four-factor analysis. 

Summary of Interstate Transport and Contribution 

Sections 51.308(d)(3)(i) and (ii) of the Regional Haze Rule requires that the Long-Term Strategy address 

the contribution of interstate transport of haze pollutants between states. Chapter 8 of this Plan illustrated 

New Mexico's statewide emissions, while Chapter 9 identified interstate transport of pollutants and larger 

source categories based on source apportionment results. 

12.2 Other States’ Class I Areas Affected by New Mexico Emissions 

New Mexico used baseline period visibility data from the IMPROVE monitors along with the WRAP 

baseline modeling results to estimate New Mexico's emissions impact on neighboring states’ Class I areas 

(see Figure 12-1 through Figure 12-12). New Mexico focused on anthropogenic emissions transported 

to other states, primarily sulfates and nitrates.

The charts and tables below, show the contribution of particle mass calculated from the modeled 

concentrations of nitrates and sulfates for the baseline years. The charts and tables illustrate the probable 

share of New Mexico's emissions contributing to the pollutant species in surrounding states. 

12.2.1 Nitrate Contributions from New Mexico on Surrounding States' Class I Areas 

New Mexico's NOx emissions contribute up to 24% percent of the nitrate concentrations at some 

neighboring states on the worst 20% days according to modeling. As shown in the table below, 

however, nitrate contributes only up to 19 percent of the visibility impairment in neighboring states. 

By 2018, NOx emissions from New Mexico are projected by the WRAP to decrease by 57,975 tons, 

which will help reduce New Mexico's impact to out of state Class I areas. Actual decreases are 
New Mexico Section 308 Regional Haze SIP 150

expected to be higher due to the BART determination of 0.03 to 0.07 lb/mmBtu for San Juan 

Generating Station. 

Table 12-1: Nitrate Contribution to Haze in Baseline Years for Worst 20% Days 

State 

2000-2004

Average Annual Nitrate

Share of Particle Light

Extinction

(measured values)

2000-2004

New Mexico’s Average

Annual Share of Nitrate

Concentration

(based on modeling)

Arizona 13.5% 2.7% 

Colorado 10.0% 24.7% 

Nevada 19.1% 0.1% 

Utah 15.9% 6.0% 

Texas 6.0% 11.2% 

Wyoming 9.9% 0.3% 

Figure 12-1: Nitrate Contributions from New Mexico on Arizona Class I Areas 

WRAP State Nitrate Contributions on Arizona's Class I Areas

AZ

75%

ND

0%

NM

4%

CA

16%

CO

0%

ID

0%

NV

2%

MT

0%

OR

0%

SD

0% UT

3% WA

0% WY

0%
New Mexico Section 308 Regional Haze SIP 151

Figure 12-2: Nitrate Contributions from New Mexico on Colorado Class I Areas 

WRAP State Nitrate Contributions on Colorado's Class I Areas

AZ

8% CA

10%

CO

32%

ID

3%

MT

1%

NV

1%

NM

24%

ND

1%

OR

1%

SD

1%

UT

10%

WA

1%

WY

7%

Figure 12-3: Nitrate Contributions from New Mexico on Nevada Class I Areas 

WRAP States Nitrate Contributions on Nevada's Class I Areas

AZ

0%

CA

17%

CO

0%

ID

36%

MT

1%

NV

15%

NM

0%

ND

0%

OR

7%

SD

0%

UT

15%

WA

8%

WY

1%
New Mexico Section 308 Regional Haze SIP 152

Figure 12-4: Nitrate Contributions from New Mexico on Utah Class I Areas 

WRAP State Nitrate Contributions on Utah's Class I Areas

AZ

6%

CA

25%

CO

3%

ID

3%

MT

1%

NV

8% NM

6%

ND

0%

OR

2%

UT

42%

WA

2%

WY

2%

SD

0%

Figure 12-5: Nitrate Contributions from New Mexico on Texas Class I Areas 

WRAP State (Including CENWRAP and Mexico) Nitrate 

Contributions on Texas' Class I Areas 

CEN

61%

CO

2%

ID

0%

MEX

12%

NM

11%

NV

MT 0%

1%

UT

0% SD

2%

WA

0%

CA

5%

WY

1% AZ

3%

OR

0%

ND

2%
New Mexico Section 308 Regional Haze SIP 153

Figure 12-6: Nitrate Contributions from New Mexico on Wyoming Class I Areas 

WRAP State Nitrate Contributions on Wyoming's Class I Areas

AZ

1%

CA

6%

CO

2%

ID

29%

MT

13%

NM

0%

ND

2%

OR

7%

SD

1%

UT

12%

WA

10%

WY

15%

NV

2%

12.2.2 Sulfate Contributions from New Mexico on Surrounding State's Class I Areas 

According to modeling, New Mexico sulfate emissions contribute up to 16.9 percent of the sulfate 

concentrations at some neighboring states on the worst 20% days. As shown in Table 12-2 below, 

sulfate contributes up to 44 percent of the visibility impairment at the nearest Class I areas in 

neighboring states. By 2018, SO2 emissions from New Mexico are projected by the WRAP to 

decrease by 10,457 tons, which will help reduce New Mexico’s impact on out of state Class I areas.

Table 12-2: Sulfate Contribution to Haze in Baseline Years for Worst 20% Days 

State 

2000-2004

Average Annual Sulfate

Share of Particle Light

Extinction

(measured values)

2000-2004

New Mexico’s Average

Annual Share of Sulfate

Concentration

(based on modeling)

Arizona 18.9% 6.7% 

Colorado 21.7% 16.9% 

Nevada 17.1% 1.7% 

Utah 23.3% 6.9% 

Texas 44.0% 1.9% 

Wyoming 23.3% 2.5% 
New Mexico Section 308 Regional Haze SIP 154

Figure 12-7: Sulfate Contributions from New Mexico on Arizona Class I Areas 

WRAP State Sulfate Contributions on Arizona's Class I Areas

AZ

50%

CA

17%

CO

3%

ID

1%

MT

0%

NV

10%

NM

7%

ND

0%

OR

3%

SD

0%

UT

4%

WA

2%

WY

3%

Figure 12-8: Sulfate Contributions from New Mexico on Colorado Class I Areas 

WRAP State Sulfate Contributions on Colorado's Class I Areas

AZ

10% CA

7%

CO

33%

ID

3%

MT

1%

NV

6%

NM

17%

ND

2%

OR

2%

SD

0%

UT

9%

WA

2%

WY

8%
New Mexico Section 308 Regional Haze SIP 155

Figure 12-9: Sulfate Contributions from New Mexico on Nevada Class I Areas 

WRAP State Sulfate Contributions on Nevada's Class I Areas

AZ

4%

CA

21%

CO

2%

ID

15%

MT

1%

NV

16%

NM

2%

ND

0%

OR

15%

SD

0%

UT

5%

WA

15%

WY

4%

Figure 12-10: Sulfate Contributions from New Mexico on Utah Class I Areas 

WRAP State Sulfate Contributions on Utah's Class I Areas

AZ

8%

CA

20%

CO

5%

ID

2%

MT

0%

NV

19%

NM

7%

ND

1%

OR

6%

SD

0%

UT

24%

WA

3%

WY

5%
New Mexico Section 308 Regional Haze SIP 156

Figure 12-11: Sulfate Contributions from New Mexico on Texas Class I Areas 

WRAP State Sulfate Contributions on Texas' Class I Areas

CEN

56%

MEX

37%

UT

0%

OR

0%

NV

0%

WA

0%

WY

1% AZ

1% CA

1%

SD

NM 0%

2%

MT

0%

ND

1%

CO

1%

ID

0%

Figure 12-12: Sulfate Contributions from New Mexico on Wyoming Class I Areas 

WRAP State Sulfate Contributions on Wyoming's Class I Areas

AZ

3%

CA

7%

CO

13%

ID

13%

MT

6% NV

6%

NM

3%

ND

2%

OR

7%

SD

0%

UT

9%

WA

6%

WY

25%
New Mexico Section 308 Regional Haze SIP 157

12.3 New Mexico Class I Areas Affected by Other States, Nations and Areas of the World 

The contribution of WRAP, CENRAP, Canada, Eastern U.S., Mexico, Pacific Offshore, and Outside of 

Domain to New Mexico Class I areas were examined below in Table 12-3 through Table 12-6 to 

determine where significant emissions of nitrates and sulfates might be coming from. This review focused 

on nitrates and sulfates since those emissions tend to focus on anthropogenic sources. Data for this impact 

analysis comes from the PSAT runs performed by the WRAP and documented in the TSS. 

12.3.1 Nitrate Emissions 

For nitrates on the worst 20% days in the baseline years, the most significant impacts on New Mexico 

Class I areas came from sources within WRAP, CENRAP and outside the modeling domain (emissions 

from other parts of the world). Within the WRAP region, the sources within New Mexico, Arizona, 

California, and Colorado had the most significant impact on New Mexico Class I areas. New Mexico has 

worked with Arizona, California and Colorado through the WRAP process and believes all three states 

are working to reduce nitrate impacts to New Mexico's Class I areas. Arizona is projected by the WRAP 

to reduce nitrate causing emissions by 242,136 tons by 2018; California is projected to reduce nitrates by 

661,661 tons by 2018; and Colorado is project to reduce emissions by 215,036 tons by 2018. New 

Mexico is committed to reducing projected WRAP emissions of at least 57,975 tons by 2018. 

Table 12-3: Nitrate Contribution to New Mexico Haze in Baseline Years for 20% Worst Days 

NM Class 

I Area 

WRAP Canada Eastern 

U.S. 

Mexico Pacific 

Offshore 

Outside 

of 

Domain 

CENRAP 

Bandelier 17% 2% 0% 1% 1% 15% 10% 

Bosque 

del 

Apache 

61% 3% 0% 1% 1% 8% 26% 

Carlsbad 30% 5% 0% 5% 2% 14% 44% 

Gila 58% 0% 0% 2% 5% 33% 2% 

Salt Creek 61% 0% 0% 2% 0% 11% 26% 

San Pedro 

Parks 

69% 3% 0% 1% 1% 10% 16% 

Pecos / 

Wheeler 

Peak 

57% 3% 2% 1% 1% 8% 28% 

White 

Mountain 

40% 4% 0% 2% 2% 16% 36% 
New Mexico Section 308 Regional Haze SIP 158

Table 12-4: WRAP Nitrate Contribution to New Mexico Haze Baseline Years for Worst 20% Days 

NM Class I 

Area 

AZ CA CO ID MT NV NM ND OR SD UT WA WY 

Bandelier 13% 9% 6% 0% 1% 2% 58% 1% 0% 1% 8% 0% 1% 

Bosque del 

Apache 15% 5% 7% 0% 1% 1% 61% 2% 0% 2% 3% 0% 3% 

Carlsbad 12% 19% 7% 0% 3% 1% 42% 6% 0% 5% 1% 1% 3% 

Gila 38% 51% 0% 0% 0% 7% 3% 0% 0% 0% 1% 0% 0% 

Salt Creek 9% 2% 7% 0% 0% 1% 75% 0% 0% 0% 5% 0% 1% 

San Pedro 

Parks 19% 10% 4% 0% 1% 3% 53% 1% 1% 1% 5% 1% 1% 

Pecos / 

Wheeler Peak 13% 7% 6% 0% 1% 1% 64% 2% 0% 2% 3% 0% 1% 

White 

Mountain 14% 17% 13% 1% 2% 1% 38% 3% 0% 3% 2% 1% 5% 

12.3.2 Sulfate Emissions 

For the 20% worst days in the baseline years, New Mexico's Class I areas are predominately 

impacted by sulfate emissions from WRAP, CENRAP, Eastern U.S., and sources outside of the 

modeling domain. Within WRAP, the largest contributions of sulfates come from New Mexico, 

Arizona, California, and Colorado, contributing up to 88 percent of the sulfate emissions in the 

baseline years from the WRAP region. New Mexico has worked with Arizona, California and Colorado 

through the WRAP process and believes all three states are working to reduce sulfate impacts to New 

Mexico's Class I areas. Arizona is projected by the WRAP to reduce sulfate causing emissions by 33,475 

tons by 2018; California is projected to reduce sulfate by 5,340 tons by 2018; and Colorado is project to 

reduce emissions by 59,442 tons by 2018. New Mexico is committed to reducing projected WRAP 

emissions of at least 10,457 tons by 2018. 

Table 12-5: Sulfate Contribution to New Mexico Haze in Baseline Years for Worst 20% Days 

NM Class I 

Area 

WRAP Canada Eastern 

U.S. 

Mexico Pacific 

Offshore 

Outside 

Domain 

CENRAP

Bandelier 32% 1% 12% 9% 3% 27% 16% 

Bosque del 

Apache 21% 1% 20% 14% 2% 19% 23% 

Carlsbad 5% 2% 43% 10% 1% 11% 28% 

Gila 18% 1% 18% 20% 4% 20% 19% 

Salt Creek 12% 2% 31% 10% 1% 15% 29% 

San Pedro 

Parks 31% 2% 8% 12% 5% 26% 16% 

Pecos / 

Wheeler Peak 34% 2% 6% 10% 4% 27% 17% 

White 

Mountain 11% 2% 34% 10% 1% 12% 30% 
New Mexico Section 308 Regional Haze SIP 159

Table 12-6: WRAP Sulfate Contribution to New Mexico Haze Baseline Years for Worst 20% Days 

NM Class I 

Area 

AZ CA CO ID MT NV NM ND OR SD UT WA WY 

Bandelier 25% 7% 4% 1% 0% 5% 48% 1% 0% 0% 5% 1% 2% 

Bosque del 

Apache 29% 7% 8% 1% 1% 6% 32% 2% 1% 0% 6% 1% 6% 

Carlsbad 15% 7% 10% 2% 3% 4% 29% 10% 2% 2% 4% 2% 10% 

Gila 36% 12% 6% 1% 1% 9% 23% 1% 2% 0% 4% 1% 4% 

Salt Creek 17% 3% 5% 1% 1% 3% 54% 5% 1% 1% 4% 1% 4% 

San Pedro 

Parks 28% 11% 5% 1% 1% 8% 32% 1% 2% 0% 5% 2% 4% 

Pecos / 

Wheeler Peak 12% 7% 9% 1% 1% 5% 42% 2% 1% 1% 5% 1% 4% 

White 

Mountain 26% 5% 10% 1% 1% 4% 33% 7% 1% 1% 4% 1% 6% 

12.4 Summary of Interstate Consultation 

In addition to evaluating interstate transport, the affected states are required to consult with each other 

under Section 51.308(d)(3)(i), in order to develop coordinated emission management strategies. See 

Chapter 2 for information on the state-to-state consultation process. 

12.5 Estimated Contributions from CENRAP and Eastern U.S. 

As shown above in Table 12-4 and Table 12-6, many of New Mexico's Class I areas are affected by 

sulfate emissions from the eastern region of the U.S and sulfate and nitrate emissions from CENRAP. 

New Mexico has no regulatory authority for emissions outside of our jurisdiction, so we are depending on 

current and future federal standards to assist in reducing the extent that New Mexico's Class I areas are 

affected by sulfate and nitrate emissions from the eastern portion of the U.S. and CENRAP. Some of 

these federal programs include: 

• Regional Haze/BART; 

• 2010 Final Primary National Ambient Air Quality Standard for Sulfur Dioxide; 

• 2010 Final Primary National Ambient Air Quality Standard for Oxides of Nitrogen; 

• 2010 Final Primary National Ambient Air Quality Standard for Ozone; 

• Clean Air Interstate Replacement Rule/Transport Rule; 

• MACT Standards for Industrial, Commercial & Institutional (ICI) Boilers - Phase I & II; 

• NSPS and MACT Standards for Cement Kilns - Phase I & II; and

• MACT Standards for Electric Generating Units (Utility MACT).

12.6 Estimated International Contribution to New Mexico's Class I Areas 

Although not specifically addressed under the Regional Haze Rule in terms of interstate transport, it is 

important to identify the contribution to visibility impairment in New Mexico from international sources, 

such as Mexico. The PSAT and WEP results in Chapter 9 describe the amount of contribution to visibility 

impairment in New Mexico from sources in Mexico. New Mexico has historically been affected by 

international emissions from Mexico. As Table 12-5 above shows, Mexico is a major contributor to 

sulfate emissions at many of New Mexico's Class I areas. 
New Mexico Section 308 Regional Haze SIP 160

New Mexico has been an active member of the Paso del Norte Joint Advisory Committee (JAC). The 

JAC was established in 1996 for the improvement of air quality in the Paso del Norte region, that includes 

the communities of Ciudad Juárez, Chihuahua, El Paso, Texas, and Doña Ana County, New Mexico. The 

JAC is a binational committee made up of private citizens, private sector representatives, university 

officials, federal, state, and local government officials, and non-governmental environmental and public 

health organizations. The JAC is charged with the development and recommendation of air quality 

improvement projects and programs to the Air Work Group established under the 1983 U.S.- Mexico La 

Paz Agreement. 

As a long term strategy for international emissions, New Mexico will continue to be an active member on 

the JAC. Unfortunately, the Paso del Norte covers only a small area of the Mexico/New Mexico borders 

region. Current emission inventories and modeling of Mexico sources are needed by states to help 

differentiate between local and international contributions for regional haze and general air quality 

planning purposes. Until these types of resources are available, particularly for border states, it will be 

difficult to meet regional haze progress goals. Because the State of New Mexico does not have any 

authority over any international sources, the state is not pursuing any new strategy for haze impacts due to 

these sources. 

12.7 Required Factors for the Long-Term Strategy 

As required in Section 51.308(d)(3)(v) of the Regional Haze Rule, the State must consider, at a minimum, 

the following factors: 1) emission reductions due to ongoing air pollution control programs; 2) measures 

to mitigate the impacts of construction activities; 3) emission limitations and schedules for compliance; 4) 

source retirement and replacement schedules; 5) smoke management techniques for agricultural and 

forestry burning; 6) the enforceability of emission limitations and control measures; and 7) the anticipated 

net effect on visibility over the period of the long-term strategy. These factors are discussed in the 

following pages along with all measures to mitigate the impacts of anthropogenic sources. The seventh 

factor is discussed at the end of the Long-Term Strategy Chapter. 

12.7.1 Emission Reductions Due to Ongoing Air Pollution Control Programs 

The following summary describes ongoing programs and regulations in New Mexico that directly protect 

visibility, or can be expected to improve visibility in New Mexico Class I areas, by reducing emissions in 

general. This summary does not attempt to estimate the actual improvements in visibility that will occur, 

as many of the benefits are secondary to the primary air pollution objective of these programs/rules, and 

consequently would be extremely difficult to quantify due to the technical complexity and limitations in 

current assessment techniques. 

12.7.2 New Source Review Program 

The New Source Review (NSR) Program is a permit program for the construction of new sources and 

modification of existing sources as established by 20.2.72 NMAC - Construction Permits and 20.2.74 

NMAC - Permits - Prevention of Significant Deterioration. The primary purpose of the NSR Program is 

to assure compliance with ambient standards set to protect public health, assure that Best Available 

Control Technology (BACT) is utilized to reduce and eliminate air pollution emissions, and to prevent 

deterioration of clean air areas. Any amount of air contaminant emissions from a facility subjects it to 

New Mexico’s NSR Program. 

12.7.3 Prevention of Significant Deterioration (PSD) Program 

New Mexico considers its Prevention of Significant Deterioration (PSD) program as being protective of 

visibility impairment from proposed major stationary sources or major modifications to existing facilities. 
New Mexico Section 308 Regional Haze SIP 161

New Mexico has a fully-approved PSD program, and has successfully implemented this program for 

many years. 

12.7.4 Minor Source BACT Program 

The BACT process is most appropriately defined as the elimination of emissions whenever technically 

and economically feasible to do so. New Mexico takes the State-required BACT review in minor source 

permitting actions very seriously, as the bulk of the New Mexico's workload is made up of minor sources. 

New Mexico will continue to review BACT considerations on each source type and size on a case-bycase basis with consideration to the technical practicability and economic reasonableness of eliminating 

or reducing the emissions from the proposed facility. The application of BACT in the minor source 

permitting program has resulted in minimized emissions in the state as a whole and will continue to do so 

as the New Mexico continues to receive NSR permit applications for new and modified sources. 

12.7.5 Title V Operating Permit Program 

As required by Title V of the Clean Air Act Amendments of 1990 and the implementing regulations in 40 

CFR part 70, New Mexico established an Operating Permit Program under 20.2.70 NMAC - Operating 

Permits. A Title V Operating Permit consolidates all air quality regulatory requirements in a single 

document, so a permittee can clearly determine compliance with the air quality requirements applicable to 

its operation. The Title V Operating Permit also establishes appropriate compliance assurance monitoring 

on a pollutant-by-pollutant basis for large emission sources with add-on pollution control equipment, and 

establishes periodic monitoring for other regulated pollutants. The process of issuing the Operating 

Permit is designed to allow participation by the public, the EPA and nearby states to avoid 

misinterpretation of air quality regulatory requirements. This permitting is done to enhance enforceability 

by clearly defining the playing field for all concerned parties, so that all regulated industry is governed by 

the same rules. These permits are issued for a term of five years and must be renewed and updated to 

incorporate current regulatory requirements. Nationally, this program is intended to set minimum 

standards for all states to implement, in an attempt to foster consistency in air quality permitting from 

state to state. The Operating Permit Program is intended to be self supporting, and states are required 

under the Clean Air Act to charge regulated industry fees based upon their actual air pollutant emissions 

on an annual basis; thus, Title V permittees pay for the operation of the regulating program. 

The Operating Permit Program affects only major sources of air pollution operating in the State. A major 

source is defined as a source which emits, or has the potential to emit, 100 tons per year of an air 

pollutant, or any source which emits, or has the potential to emit, 10 tons per year of an individual 

hazardous air pollutant (or 25 tons per year of any combination of hazardous air pollutants) which has 

been listed pursuant to section 112(b) of the Clean Air Act. The number of Title V sources within the 

State is variable but has typically ranged from 150 to 160 sources at any given time. 

12.7.6 New Source Performance Standards (NSPS) 

NMED periodically incorporates by reference the Federal New Source Performance Standards (NSPS). 

These standards were first incorporated into New Mexico Administrative Code under 20.2.77 NMAC -

New Source Performance Standards in July 1985, with the latest revision becoming effective in August 

2009. 
New Mexico Section 308 Regional Haze SIP 162

12.7.7 National Emission Standards for Hazardous Air Pollutants 

The New Mexico Environment Department periodically incorporates by reference the Federal National 

Emission Standards for Hazardous Air Pollutants (NESHAPs). To the extent that NESHAPs regulate 

visibility impairing pollutants through surrogates, these programs may prove helpful in reducing visibility 

impairment. These standards are incorporated under 20.2.78 NMAC - Emission Standards for Hazardous 

Air Pollutants. 20.2.78 NMAC first became an effective State rule in July 1984, with the latest revision 

becoming effective in August 2009. 

The New Mexico Environment Department determines case-by-case MACT determinations under 20.2.82 

NMAC - Maximum Achievable Control Technology Standards for Source Categories of Hazardous Air 

Pollutants. 

12.7.8 New Mexico Reasonably Attributable Visibility Impairment Rules 

In response to EPA’s Phase I visibility rules, New Mexico adopted the New Mexico Visibility Protection 

Plan for Phase I in August of 1986. It was approved by the U.S. EPA by notice in the Federal Register on 

January 27, 2006. A revision to the 1986 Phase I SIP was submitted to EPA in August of 1992. This 

revision was also approved by EPA in January of 2006. This visibility rule contains short and long-term 

strategies for making reasonable progress toward the national goal, related to addressing reasonably 

attributable impairment in the State’s Class I areas through visibility monitoring and control strategies. 

This rule incorporates PSD requirements for visibility protection from new or modified major stationary 

sources, and if necessary applying BART to existing stationary sources if certified as causing reasonably 

attributable visibility impairment. 

12.7.9 Ongoing Implementation of Federal Mobile Source Regulations 

The Federal Motor Vehicle Control Program (FMVCP) has produced and is continuing to produce large 

reductions in motor vehicle emissions of NOx, PM, and VOCs. Beginning in 2006, EPA mandated new 

standards for on-road (highway) diesel fuel, known as ultra-low sulfur diesel (ULSD). This regulation 

dropped the sulfur content of diesel fuel from 500 ppm to 15 ppm. ULSD fuel enables the use of cleaner 

technology diesel engines and vehicles with advanced emissions control devices, resulting in significantly 

lower emissions. Diesel fuel intended for locomotive, marine and non-road (farming and construction) 

engines and equipment was required to meet the low sulfur diesel fuel maximum specification of 500 ppm 

sulfur in 2007 (down from 5,000 ppm). By 2010, the ULSD fuel standard of 15-ppm sulfur will apply to 

all non-road diesel fuel. Locomotive and marine diesel fuel will be required to meet the ULSD standard 

beginning in 2012, resulting in further reductions of diesel emissions. These rules not only reduce SO2

emissions, but also NOx and PM emissions. 

In addition to the ULSD standard, listed below are several other significant Federal programs. 

Federal On-Road Measures: 

• Tier 2 vehicle emission standards and Federal low-sulfur gasoline 

• National low emissions vehicle standards (NLEV) 

• Heavy-duty diesel standards 

Federal Non-Road Measures: 

• Lawn and garden equipment 

• Tier 2 heavy-duty diesel equipment 

• Locomotive engine standards 

• Compression ignition standards for vehicles and equipment 

• Recreational marine engine standards 
New Mexico Section 308 Regional Haze SIP 163

In addition, the Renewable Fuel Standard Under Section 211(o) of the Clean Air Act as Amended by the 

Energy Policy Act of 2005, is determined annually (must be published in the Federal Register by 

November 30 of each year) by EPA and is applicable to refiners, importers and blenders of gasoline. 

12.7.10 Ongoing Implementation of State Mobile Source Regulations 

In December of 2007, the New Mexico Environment Department adopted 20.2.88 NMAC - Emission 

Standards for New Motor Vehicles, which established emissions standards for new passenger cars, light 

duty trucks, and medium duty vehicles sold in New Mexico beginning with model year 2011. These 

standards, commonly known as "clean car standards" or "California standards", actually consist of three 

separate sets of standards: (1) standards applicable to air pollutants, including non-methane organic gases, 

known as phase two of the Low Emission Vehicle program, or "LEV II"; (2) standards requiring a 

percentage of total sales for each manufacturer to consist of zero emission vehicles, or "ZEV"; and (3) 

standards for carbon dioxide, measured in grams per mile, or "greenhouse gas standards". 

The standards strengthen the emission standards for conventional air pollutants, including non-methane 

organic gases ("NMOG"), carbon monoxide, oxides of nitrogen, formaldehyde, and particulates. These 

pollutants aggravate asthma and contribute to lung diseases, cancer, and heart disease. NOx and 

particulate emissions contribute to regional haze as well. Based on aanalysis of States that already have 

the LEV II standards on the books, the LEV II standards are expected to reduce VOCs by five (5) percent 

over federal standards and NOx by eleven (11) percent. 

12.7.11 Ongoing Implementation of Programs to Meet PM10 NAAQS 

Currently, only one community in New Mexico, Anthony, is designated as a nonattainment area under the 

PM10 National Ambient Air Quality Standard (NAAQS). Anthony is located in the southern region of 

Doña Ana County. This area was designated nonattainment for PM10 in 1991. Anthony was designated 

nonattainment due to wind blown dust from high wind exceptional events. 

Natural Events 

On May 30, 1996, EPA issued a Natural Events Policy (NEP) which recognized that certain 

uncontrollable natural events, such as high winds, wildland fires, and volcanic/seismic activity can result 

in adverse consequences for the National Ambient Air Quality Standard (NAAQS). The NEP set forth 

procedures for protecting public health through the development of a Natural Events Action Plan (NEAP) 

which implements Best Available Control Measures (BACM) for human-generated particulate emissions 

in areas where the PM10 standard may be violated due to these uncontrolled natural events. The NEP also 

provides that if an approved NEAP is implemented, future air quality exceedances due to uncontrollable 

natural events may be flagged, and, if demonstrated to be a natural event, not be considered when 

determining the region’s air quality designation if BACM measures are being implemented. 

In 2000, a Natural Events Action Plan was submitted for Doña Ana County, which included the Anthony 

PM10 Nonattainment area was submitted to EPA. Doña Ana County is 3,804-square-miles in the southcentral section of New Mexico with a population of 174,682. Doña Ana County borders El Paso, Texas 

and Ciudad Juarez, Mexico. This area is considered part of the Paso del Norte air shed, which includes El 

Paso County, Texas and Ciudad Juarez, Mexico. This region of the state has historically had air quality 

problems, including particulate matter and ozone pollution. The Natural Events Action plan for Doña Ana 

County outlines specific procedures to be taken in response to future high wind events. These procedures 

include: 

• Techniques to educate the public about the problem; 
New Mexico Section 308 Regional Haze SIP 164

• Mitigation of health impacts on exposed populations during future events; and 

• Best Available Control Measures (BACM) for significant, anthropogenic sources of windblown dust. 

For any NEAP under the Natural Events Policy, a reevaluation of the plan must be conducted every five 

(5) years to determine if any changes are necessary to protect public health and control anthropogenic 

sources that may contribute to exceedances of the PM10 NAAQS. A reevaluation of Doña Ana County's 

Natural Events Action Plan was submitted to EPA in 2005. The reevaluation reviewed the conditions 

causing violations of the PM10 NAAQS in Doña Ana County; the status of the implementation of the 

plan; and the adequacy of the actions being implemented. 

A Natural Events Action Plan was submitted to EPA for Luna County, NM in 2004. Luna County is 

2,965 square miles in southwestern New Mexico with a total population of near 27,000, of which 

approximately 14,000 are in Deming. In 2003, violations of the federal standard for particulate matter 

occurred, requiring the creation of this Luna County Natural Events Action Plan to avoid nonattainment. 

The Natural Events Action plan for Luna County outlines specific procedures to be taken in response to 

future high wind events. These procedures include: 

• Techniques to educate the public about the problem; 

• Mitigation of health impacts on exposed populations during future events; and 

• Best Available Control Measures (BACM) for significant, anthropogenic sources of windblown dust. 

In March of 2007, EPA adopted the Exceptional Events rule (EER). The Exceptional Events rule replaced 

the NEP. The EER established procedures and criteria related to the identification, evaluation, 

interpretation, and use of air quality monitoring data related to any NAAQS where States petition EPA to 

exclude data that are affected by exceptional events. 

12.7.12 Measures to Mitigate the Impacts of Construction Activities 

Currently, NMED is developing a rule concerning the control of fugitive dust emissions in the state of 

New Mexico outside of Bernalillo County and tribal lands. A review of the complaints received by 

NMED over the past five years shows that fifteen percent concern fugitive dust from sources that are not 

required to obtain an air quality construction or operating permit. The industries receiving the most 

complaints include construction and development sites, bulk material processing and handling, and 

confined animal feeding operations (CAFOs). The rule will initially apply to emission sources having a 

disturbed surface area greater than two (2) acres in size as well as bulk material handling, transport, and 

storage. Activities addressed in the rule include but are not limited to construction, demolition, grading, 

excavation, clearing, grubbing, and track out of material. As scheduled, the rule is set to be adopted in 

early 2011. 

12.7.13 Emission Limitations and Schedules of Compliance 

The implementation of BART, as described in Chapter 10, will contain emission limits and schedules of 

compliance for those sources either installing BART controls or taking federally enforceable permit 

limitations. The four-factor analysis identifies some additional measures that are appropriate for this first 

Regional Haze Plan. The evaluation of non-BART sources as part of the LTS identifies additional 

emission reductions and improves visibility by 2018. 
New Mexico Section 308 Regional Haze SIP 165

12.7.14 Source Retirement and Replacement Schedules 

The New Mexico Environment Department is not currently aware of any specific scheduled shutdowns, 

retirements in upcoming years, or replacement schedules, such as planned installation of new control 

equipment to meet other regulations or routine equipment replacement or modernization. As NMED 

becomes aware of such actions, they will be factored into upcoming reviews. 

12.7.15 Agricultural and Forestry Smoke Management Techniques 

In December of 2003, NMED adopted 20.2.65 NMAC - Smoke Management. The New Mexico 

Environment Department developed the state Smoke Management Program (SMP) to protect the health 

and welfare of New Mexicans from the impacts of smoke from all sources of fire. In addition, this SMP 

meets the requirements of the Clean Air Act and the Regional Haze Rule (40 CFR 51.309). The SMP is 

applicable in all of New Mexico, except for tribal lands and Bernalillo County, which are separate air 

quality jurisdictions. Burners must also comply with all city and county ordinances relating to smoke 

management and vegetation burning. The regulation was submitted to EPA in December 2003 as part of 

the Regional Haze Section 309 SIP submittal. It is included in this Section 308 submittal as Appendix D. 

The SMP requirements of burners are based on those required by EPA, and fall under two categories of 

burners. SMP I is primarily an information gathering level, with registration and tracking requirements for 

all burners at this level of emissions. SMP II has more stringent requirements related to smoke 

management and emissions reduction, in keeping with the higher level of emissions produced by these 

larger burns. These requirements make up the Smoke Management Regulation that provides the 

enforcement mechanism for the SMP. 

A Smoke Management Program Guidance Document was revised in May of 2005, to assist burners in 

understanding the requirements and aid in the implementation of 20.2.65 NMAC. The intent of this 

process was to create a SMP that is equitable, reasonable, and implementable; is based on the best 

available science; and that provides all burners with the tools and information they need to manage 

impacts from smoke. Clarity, flexibility and ease of application were also fundamental principles of the 

SMP development process. The SMP is dynamic, and will be evaluated and revised as necessary, 

involving stakeholder review and input. Topics for evaluation could include SMP thresholds and 

requirements, time frames, fees, airshed boundaries, and other aspects of the program as appropriate. 

NMED staff has actively participated in the WRAP Fire Emissions Joint Forum (FEJF), formed to 

address both policy and technical issues concerning smoke effects that are caused by wildland and 

agricultural fires on public, tribal, and private lands. The FEJF is guided by the recommendations 

contained in the GCVTC Final Report and the requirements of the Regional Haze Rule regarding fire 

emissions and visibility. The FEJF has developed several policies for the WRAP through a stakeholderbased consensus process to assist the WRAP states and tribes in addressing emissions from fire sources. 

In these policies, the WRAP seeks to provide a consistent framework that states and tribes can use to 

efficiently develop their individual regional haze implementation plans, long-term strategies, and periodic 

progress reports. 

The WRAP has advanced the following policies developed by the FEJF as viable tools for states to meet 

the requirements of the Rule. 

• The WRAP Policy for Categorizing Fire Emissions was developed to clarify the complex relationship 

between what is considered a natural source of fire and what is considered a human-caused source, as 

acknowledged in the Rule. A methodology to categorize fire emissions as either “natural” or 
New Mexico Section 308 Regional Haze SIP 166

“anthropogenic” is the basis of the Policy; thus providing the foundation for fire’s inclusion in natural 

background condition values and ultimately, the tracking of reasonable progress. 

• The WRAP Policy on Enhanced Smoke Management Programs for Visibility defines the enhanced 

smoke management program as smoke management efforts that specifically address visibility, 

thereby going beyond the EPA Interim Policy and the AAQTF Air Quality Policy specific guidance 

provided for smoke management programs that address public health and nuisance concerns. The 

Policy identifies for states/tribes in the WRAP region the elements of an enhanced smoke 

management program to address visibility effects from all types of fire that contribute to visibility 

impairment in mandatory Federal Class I areas. 

• The WRAP defines the annual emission goal as a quantifiable value that is used to measure progress 

each year toward the desired outcome of achieving the minimum emission increase from fire. In the 

WRAP Policy on Annual Emissions Goals for Fire, the WRAP outlines a process by which 

states/tribes may establish annual emission goals, based on the utilization of currently available 

emission reduction techniques, to include in their Regional Haze SIPs. 

• It is the position of the WRAP Policy on Fire Tracking Systems that it is necessary to track fire 

activity information in the WRAP region using a fire tracking system, which will also provide the 

information essential to create a fire emissions inventory. The Policy identifies seven essential 

components of a fire tracking system that represent the minimum spatial and temporal fire activity 

information necessary to consistently calculate emissions and to meet the requirements of the Rule. 

12.7.16 Enforceability of New Mexico’s Measures 

Section 51.308(d)(3)(v)(F) of the Regional Haze Rule requires states to ensure that emission limitations 

and control measures used to meet reasonable progress goals are enforceable. 

New Mexico has ensured that all existing emission limitations and control measures, for which the State 

of New Mexico is responsible, used to meet reasonable progress goals are enforceable either through New 

Mexico Administrative Code (NMAC), or SIP measures previously approved by EPA. Enforceability of 

future emission limitations and control measures, for which the State of New Mexico is responsible, will 

be enforceable through permit conditions (BART) or SIP measures to be approved in the future by EPA. 

12.8 Additional Measures in the Long-Term Strategy 

This section of the LTS identifies new measures being proposed by NMED for achieving reasonable 

progress. These reasonable progress measures will be evaluated and discussed in the next Plan update in 

2013. 

12.8.1 Future Federal Mobile Programs 

A new rule, “Control of Emissions of Air Pollution from Locomotives and Marine Compression-Ignition 

Engines Less Than 30 Liters per Cylinder”, was signed on March 14, 2008. EPA estimates that by 2030, 

this program will reduce annual emissions of NOx by about 800,000 tons and PM emissions by 27,000 

tons. Emission reductions are expected to continue as fleet turnover is completed. These standards are 

intended to achieve these large reductions in emissions through the use of technologies such as incylinder controls, aftertreatment, and low sulfur fuel, perhaps as early as 2011. 
New Mexico Section 308 Regional Haze SIP 167

In June 2009, EPA announced a rule (Control of Emissions from New Marine Compression-Ignition 

Engines at or Above 30 Liters per Cylinder) proposing more stringent exhaust emission standards for the 

largest marine diesel engines used for propulsion on oceangoing vessels (called Category 3 engines). The 

proposed engine standards are equivalent to the nitrogen oxides limits recently adopted in amendments to 

Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL). The 

near-term standards for newly-built engines would apply beginning in 2011. Long-term standards would 

begin in 2016, and are based on the application of high-efficiency aftertreatment technology. By 2030, 

this strategy to address emissions from oceangoing vessels is expected to reduce annual emissions of NOx 

in the U.S. by approximately 1.2 million tons and particulate matter emissions by about 143,000 tons. 

When fully implemented, the coordinated strategy is anticipated to reduce NOx emissions by 80 percent 

and PM emissions by 85 percent, compared to the current limits applicable to these engines. 

A proposed rule, the Renewable Fuel Standard (RFS2), was signed by Administrator Jackson on May 5, 

2009. This rule took effect on March 26, 2010. The rule addresses changes to the Renewable Fuel 

Standard program as required by the Energy Independence and Security Act of 2007 (EISA). The revised 

statutory requirements establish new specific volume standards for cellulosic biofuel, biomass-based 

diesel, advanced biofuel, and total renewable fuel that must be used in transportation fuel each year. The 

revised statutory requirements also include new definitions and criteria for both renewable fuels and the 

feedstocks used to produce them, including new greenhouse gas emission (GHG) thresholds for 

renewable fuels. The regulatory requirements for RFS will apply to domestic and foreign producers and 

importers of renewable fuel. It is estimated that annual GHG emissions from transportation will be 

reduced by approximately 160 million tons, the equivalent of the removal of 24 million vehicles from the 

highways. In addition, 36 billion gallons of renewable fuel will displace approximately 11% of gasoline 

and diesel consumption in 2022. The majority of the reductions are expected to come from reduced 

petroleum imports. 

12.8.2 Efforts to Address Offshore Shipping 

As depicted by PSAT results in Chapter 9, offshore marine vessel emissions contribute marginally to 

New Mexico Class I areas. New Mexico has no authority to regulate offshore shipping emissions and 

must rely upon the EPA and coastal states such as California for adoption of regulations. 

EPA adopted emission standards for new marine diesel engines installed on vessels flagged or registered 

in the United States with displacement at or above 30 liters per cylinder. Also adopted in this rulemaking 

were additional standards for new engines with displacement at or above 2.5 liters per cylinder but less 

than 30 liters per cylinder. This rule established a deadline of April 27, 2007 for EPA to promulgate a 

second set of emission standards for these engines. Because much of the information necessary to develop 

more stringent Category 3 marine diesel engines standards has become available only recently, a new 

deadline for the rulemaking to consider the next tier of Category 3 marine diesel engine standards has 

been set for December 17, 2009. On December 7, 2007, EPA announced an advance notice of proposed 

rulemaking regarding the above-referenced standards, first set in 2003. The advanced notice of proposed 

rulemaking stated that EPA was considering standards for achieving large reductions in NOx and PM 

through the use of technologies such as in-cylinder controls, aftertreatment, and low sulfur fuel, starting 

as early as 2011. 

On July 24, 2008, the State of California adopted new strict regulations for marine vessels within 24 miles 

of shore. NMED expects that implementation of these new regulations for marine vessels will have 

benefits in New Mexico. 
New Mexico Section 308 Regional Haze SIP 168

In October 2008, Member States of the International Maritime Organization (IMO) adopted new 

international standards for marine diesel engines and their fuels (2008 Amendments to MARPOL Annex 

VI) that apply globally, and establishes additional, more stringent emission requirements for ships that 

operate in specially-designated coastal areas where air quality problems are acute. 

Under the new global standards, NOx emissions will be reduced, and the fuel sulfur cap will drop to 

5,000 ppm in 2020 (pending a fuel availability review in 2018). Under the new geographic standards, 

ships operating in designated areas will be required to use engines that meet the most advanced 

technology-forcing standards for NOx emissions, and to use fuel with sulfur content at or below 1,000 

ppm. 

On March 27, 2009, the United States submitted a joint proposal with Canada to the IMO to designate 

specific areas of our coastal waters as an Emission Control Area (ECA). Compared to fuels used in ships 

today, ECA standards will lead to a 96 percent reduction in sulfur in ships’ fuels, as well as a cut in 

emissions of PM by 85 percent and NOx by 80 percent. To achieve these reductions, ships must use fuel 

with no more than 1,000 parts per million sulfur beginning in 2015, and new ships will have to use 

advanced emission control technologies beginning in 2016. 

12.8.3 Long-Term Control Strategies for BART Facilities 

Chapter 10 and Appendix A outline the BART determination and requirements for San Juan Generating 

Station. 

12.8.4 Evaluation of Control Strategies for Sources Identified in the Reasonable Progress - FourFactor Analysis 

The Reasonable Progress Goals section evaluated certain non-BART sources through a four-factor 

analysis for additional controls, as was required by the Federal Regional Haze Rule. This evaluation was 

limited, in that no guidance was provided for identifying “significant sources”, and no contribution to 

visibility impairment thresholds were established. The New Mexico Environment Department will 

conduct further research to evaluate non-BART sources for possible emission controls and retrofits. 

12.8.5 Oil and Gas 

Oil and gas production, which is not limited to just one area of New Mexico, is a large, important, and 

critical component of the State economy. However, the sources associated with oil and gas production 

emit NOx, and to a lesser extent, PM. An extensive fleet of field equipment and an array of processing 

plants operate continuously conducting exploration, production, and gathering activities. Exploration and 

drilling includes seismic studies, engineering, well testing, drilling operations, and transportation of 

personnel or equipment to and from sites. Oil and gas production includes operation, maintenance, and 

servicing of production properties, including transportation to and from sites. Sources include turbines, 

drill rig engines, glycol dehydrators, amine treatment units, flares and incinerators. 

Understanding the sources and volume of emissions at oil and gas production sites is key to recognizing 

the impact that these emissions have on visibility. To better understand the emissions from these sources, 

the WRAP instituted a three-phase project. One of the issues was to quantify emission inventories from 

stationary and mobile equipment operated as part of oil and gas field operations. 

Phase I, which was completed in 2005, was an emission inventory project that estimated regional 

emissions from oil and gas field operations. Phase II, completed in late 2007, was an effort to more fully 

characterize the oil and gas field operations emissions. Phase III which began in late 2007 with the 
New Mexico Section 308 Regional Haze SIP 169

Independent Petroleum Association of Mountain States (IPAMS) in conjunction with WRAP initiating a 

regional oil and gas emission inventory project is underway. 

A component of New Mexico’s long-term strategy for reducing oil and gas emissions that affect visibility 

is the State’s ongoing efforts to reduce emissions that contribute to ozone formation. In 2009, legislation 

was passed (House Bill 195) that allows the state to be to be more stringent than federal rule for areas that 

are violating or within 95% of violating a federal air quality standard. This allows the state to be more 

proactive for those areas that are violating or in jeopardy of violating a federal air quality standard. 

EPA has also adopted emissions standard for the oil and gas industry that will assist the state in reducing 

NOx emissions. These emissions standards include: 

• 40 CFR. pts. 63.160-.183 (Subpart H) – National Emission Standards for Organic Hazardous Air 

Pollutants for Equipment Leaks – This applies to pumps, compressors, agitators, pressure relief 

devices, and other pieces of equipment that are intended to operate in organic hazardous air pollutant 

service 300 hours or more per year within a source subject to part 63 that references subpart H. Pt. 

63.160(a); 

• 40 C.F.R. pts. 63.760-.777 (Subpart HH) – National Emission Standards for Hazardous Air Pollutants 

from Oil and Natural Gas Production Facilities – This applies to emission points of hazardous air 

pollutants located at oil and natural gas production facilities that are major or area sources of 

hazardous air pollutants, as well as facilities that process, upgrade, or store hydrocarbon liquids prior 

to the point of custody transfer, and facilities that process, upgrade, or store natural gas prior to the 

point at which natural gas enters the natural gas transmission and storage source category or is 

delivered to a final end user; 

• 40 C.F.R. pts. 63.1100-.1114 (Subpart YY) – National Emission Standards for Hazardous Air 

Pollutants for Source Categories: Generic Maximum Achievable Control Technology (MACT) 

Standards – Subpart YY applies MACT standards to eight different source categories and affected 

sources, including ethylene production emission points located at major sources; 

• 40 C.F.R. pts. 63.6080-.6175 (Subpart YYYY) – National Emission Standards for Hazardous Air 

Pollutants for Stationary Combustion Turbines – This subpart applies to stationary combustion 

turbines located at major sources of hazardous air pollutant emissions, including turbines located at 

oil and gas production facilities. Pt. 63.6085(a)-(b). 

• 40 C.F.R. pts. 63.6580-.6675 (Subpart ZZZZ) – National Emissions Standards for Hazardous Air 

Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) – This applies to RICE 

located at major sources of hazardous air pollutant emissions, including oil and gas production 

facilities. Pt. 63.6585(a)-(b). 

12.9 Projection of the Net Effect on Visibility 

The WRAP has projected the net effect on visibility from emission reductions by point, area and mobile 

sources throughout the WRAP region through 2018. The first emission projection inventory was 

compiled in 2006. The inventory was revised in 2007 to make preliminary evaluations of reasonable 

progress towards Class I areas visibility goals. The 2007 inventory focused on the most significant point 

and area sources of visibility impairing pollution in states and Indian Reservations. This effort included 

updating projections of electric generating units and incorporating known and presumed BART emission 

levels. Then, in the spring of 2009, the WRAP once again updated emission inventory projections for 
New Mexico Section 308 Regional Haze SIP 170

point and area sources in the WRAP region to give the most current assessment of reasonable progress 

towards visibility goals. Again, the updated projection inventory reflected new information about BART 

determinations and projection of future fossil fuel plants needed to achieve 2018 Federal electrical 

generation demands. 

Chapter 9 of this Plan shows the specific results of the CMAQ modeling which was used to make all 

projections of visibility. Those results show anthropogenic emissions sources generally declining across 

the West through 2018. However, natural sources such as wildfires and dust and international sources in 

Mexico appear to offset improvements in visibility from controls on manmade sources in the U.S. In spite 

of the large number of growing uncontrollable sources in the WRAP region, however, New Mexico does 

see a net visibility improvement at the New Mexico's Class I areas through 2018. The net effect of all of 

the reductions in the WRAP region, known at the time of the most recent model run is demonstrated in 

the WRAP Class I Summary Tables shown below for each of the Class I areas in New Mexico. 

 
New Mexico Section 308 Regional Haze SIP 171

Table 12-7: Class I Area Visibility Summary for BAND1 on 20% Worst Days 

Class I Area Visibility Summary: Bandelier NM, NM 

Visibility Conditions: Worst 20% Days 

RRF Calculation Method: Specific Days (EPA) 

Emissions Scenarios: 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

Monitored Estimated Projected

 

 

2000-04 

Baseline 

Conditions

(Mm-1)

2064 

Natural 

Conditions

(Mm-1)

2018 

Uniform 

Rate of 

Progress 

Target

(Mm-1)1

2018 

Projected 

Visibility 

Conditions

(Mm-1)

Baseline to 

2018 Change 

In Statewide 

Emissions

(tons / %)

Baseline to 

2018 Change 

In Upwind 

Weighted 

Emissions2

(%)

Baseline to 2018 

Change In 

Anthropogenic 

Upwind 

Weighted 

Emissions2

(%)

Sulfate 6.89 0.65 5.17 5.99 -1,320 

-3% -4% -4%

Nitrate 2.51 0.81 2.09 2.53 -64,814 

-19% -24% -26%

Organic 

Carbon 14.23 4.01 11.32 14 -813 -4% 1% 3%

Elemental 

Carbon 3.15 0.32 2.43 2.65 -1,296 -21% -21% -41%

Fine Soil 1.12 1.07 1.11 1.43 1,470 

11% 18% 27%

Coarse 

Material3 2.93 3.64 3.09 9,193 13% 17% 30%

Sea Salt3 0.24 0.24 0.24

Not 

Applicable

Total Light 

Extinction 40.07 19.74 34.02 38.77

Deciview 12.22 6.26 10.83 11.9

Not Applicable

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined.

2) Results based on Weighted Emissions Potential analysis using the 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

emissions scenarios.

3) Visibility projections not available due to model performance issues.

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

 
New Mexico Section 308 Regional Haze SIP 172

Table 12-8: Class I Area Visibility Summary for BOAP1 on 20% Worst Days 

Class I Area Visibility Summary: Bosque del Apache NWRW, NM 

Visibility Conditions: Worst 20% Days 

RRF Calculation Method: Specific Days (EPA) 

Emissions Scenarios: 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

Monitored Estimated Projected

 

 

2000-04 

Baseline 

Conditions

(Mm-1)

2064 

Natural 

Conditions

(Mm-1)

2018 

Uniform 

Rate of 

Progress 

Target

(Mm-1)1

2018 

Projected 

Visibility 

Conditions

(Mm-1)

Baseline to 

2018 Change 

In Statewide 

Emissions

(tons / %)

Baseline to 

2018 Change 

In Upwind 

Weighted 

Emissions2

(%)

Baseline to 2018

Change In 

Anthropogenic 

Upwind 

Weighted 

Emissions2

(%)

Sulfate 7.51 0.58 5.57 7.27 -1,320 

-3% -2% -2%

Nitrate 3.24 1.01 2.68 3.02 -64,814 

-19% -26% -31%

Organic 

Carbon 8.73 3.15 7.24 8.6 -813 -4% 1% 3%

Elemental 

Carbon 2.6 0.29 2.02 2.15 -1,296 -21% -18% -33%

Fine Soil 1.94 1.06 1.73 2.16 1,470 

11% 11% 23%

Coarse 

Material3 6.69 3.56 5.90 9,193 13% 4% 12%

Sea Salt3 0.19 0.25 0.21

Not 

Applicable

Total Light 

Extinction 40.90 19.89 34.57 40.09

Deciview 13.8 6.73 12.15 13.59

Not Applicable

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined.

2) Results based on Weighted Emissions Potential analysis using the 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

emissions scenarios.

3) Visibility projections not available due to model performance issues.

WRAP TSS - http://vista.cira.colostate.edu/tss/ 
New Mexico Section 308 Regional Haze SIP 173

Table 12-9: Class I Area Visibility Summary for GUMO1 on 20% Worst Days 

Class I Area Visibility Summary: Carlsbad Caverns NP, NM: Guadalupe Mountains NP, 

TX 

Visibility Conditions: Worst 20% Days 

RRF Calculation Method: Specific Days (EPA) 

Emissions Scenarios: 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

Monitored Estimated Projected

 

 

2000-04 

Baseline 

Conditions

(Mm-1)

2064 

Natural 

Conditions

(Mm-1)

2018 

Uniform 

Rate of 

Progress 

Target

(Mm-1)1

2018 

Projected 

Visibility 

Conditions

(Mm-1)

Baseline to 

2018 Change 

In Statewide 

Emissions

(tons / %)

Baseline to 

2018 Change 

In Upwind 

Weighted 

Emissions2

(%)

Baseline to 2018 

Change In 

Anthropogenic 

Upwind 

Weighted 

Emissions2

(%)

Sulfate 16.51 0.8 11.50 13.92 -267,250 

-28% 39% 39%

Nitrate 3.81 0.89 3.06 4.27 -699,080 

-34% -8% -9%

Organic 

Carbon 6.73 3.13 5.81 6.88 5,218 8% 2% 3%

Elemental 

Carbon 1.34 0.23 1.07 1.19 -9,331 -37% -13% -18%

Fine Soil 4.37 1.27 3.57 5.26 25,703 

11% 15% 27%

Coarse 

Material3 16.02 4.39 12.66 6,210 0% 1% 3%

Sea Salt3 0.1 0.14 0.11

Not 

Applicable

Total Light 

Extinction 57.87 19.84 45.20 56.64

Deciview 17.19 6.65 14.73 16.92

Not Applicable

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined.

2) Results based on Weighted Emissions Potential analysis using the 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

emissions scenarios.

3) Visibility projections not available due to model performance issues.

WRAP TSS - http://vista.cira.colostate.edu/tss/ 
New Mexico Section 308 Regional Haze SIP 174

Table 12-10: Class I Area Visibility Summary for GILA1 on 20% Worst Days 

Class I Area Visibility Summary: Gila W, NM 

Visibility Conditions: Worst 20% Days 

RRF Calculation Method: Specific Days (EPA) 

Emissions Scenarios: 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

Monitored Estimated Projected

 

 

2000-04 

Baseline 

Conditions

(Mm-1)

2064 Natural 

Conditions

(Mm-1)

2018 Uniform 

Rate of 

Progress 

Target

(Mm-1)1

2018 

Projected 

Visibility 

Conditions

(Mm-1)

Baseline to 

2018 Change 

In Statewide 

Emissions

(tons / %)

Baseline to 

2018 Change 

In Upwind 

Weighted 

Emissions2

(%)

Baseline to 

2018 Change In 

Anthropogenic 

Upwind 

Weighted 

Emissions2

(%)

Sulfate 6.87 0.58 5.13 7.67 -1,320 

-3% -2% -2%

Nitrate 0.91 0.7 0.86 0.49 -64,814 

-19% -23% -29%

Organic 

Carbon 16 4.46 12.67 23.26 -813 -4% 1% 7%

Elemental 

Carbon 3.17 0.41 2.46 5.7 -1,296 -21% -8% -31%

Fine Soil 1.45 1.21 1.40 2.14 1,470 

11% 14% 27%

Coarse 

Material3 2.85 3.53 3.00 9,193 13% 7% 17%

Sea Salt3 0.07 0.16 0.09

Not 

Applicable

Total Light 

Extinction 40.31 20.05 34.30 51.16

Deciview 13.11 6.66 11.61 15.14

Not Applicable

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined.

2) Results based on Weighted Emissions Potential analysis using the 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

emissions scenarios.

3) Visibility projections not available due to model performance issues.

WRAP TSS - http://vista.cira.colostate.edu/tss/ 
New Mexico Section 308 Regional Haze SIP 175

Table 12-11: Class I Area Visibility Summary for SACR1 on 20% Worst Days

Class I Area Visibility Summary: Salt Creek NWRW, NM 

Visibility Conditions: Worst 20% Days 

RRF Calculation Method: Specific Days (EPA) 

Emissions Scenarios: 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

Monitored Estimated Projected

 

2000-04 

Baseline 

Conditions

(Mm-1)

2064 

Natural 

Conditions

(Mm-1)

2018 Uniform 

Rate of 

Progress 

Target

(Mm-1)1

2018 

Projected 

Visibility 

Conditions

(Mm-1)

Baseline to 

2018 Change 

In Statewide 

Emissions

(tons / %)

Baseline to 

2018 Change In 

Upwind 

Weighted 

Emissions2

(%)

Baseline to 

2018 Change In 

Anthropogenic 

Upwind 

Weighted 

Emissions2

(%)

Sulfate 16.75 0.78 11.64 13.9 -1,320 

-3% 2% 2%

Nitrate 11.15 0.77 8.07 11.11 -64,814 

-19% -20% -23%

Organic 

Carbon 7.49 2.97 6.31 6.64 -813 -4% -12% -17%

Elemental 

Carbon 2.31 0.26 1.79 1.62 -1,296 -21% -30% -36%

Fine Soil 3.34 0.98 2.75 3.44 1,470 

11% 5% 7%

Coarse 

Material3 11.47 4.09 9.46 9,193 13% -1% -1%

Sea Salt3 0.2 0.2 0.20

Not 

Applicable

Total Light 

Extinction 62.70 20.04 48.05 58.37

Deciview 18.03 6.81 15.41 17.31

Not Applicable

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined.

2) Results based on Weighted Emissions Potential analysis using the 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

emissions scenarios.

3) Visibility projections not available due to model performance issues.

WRAP TSS - http://vista.cira.colostate.edu/tss/ 
New Mexico Section 308 Regional Haze SIP 176

Table 12-12: Class I Area Visibility Summary for SAPE1 on 20% Worst Days 

Class I Area Visibility Summary: San Pedro Parks W, NM 

Visibility Conditions: Worst 20% Days 

RRF Calculation Method: Specific Days (EPA) 

Emissions Scenarios: 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

Monitored Estimated Projected

 

 

2000-04 

Baseline 

Conditions

(Mm-1)

2064 

Natural 

Conditions

(Mm-1)

2018 

Uniform 

Rate of 

Progress 

Target

(Mm-1)1

2018 

Projected 

Visibility 

Conditions

(Mm-1)

Baseline to 

2018 Change 

In Statewide 

Emissions

(tons / %)

Baseline to 

2018 Change 

In Upwind 

Weighted 

Emissions2

(%)

Baseline to 2018 

Change In 

Anthropogenic 

Upwind 

Weighted 

Emissions2

(%)

Sulfate 5.78 0.7 4.41 5.38 -1,320 

-3% -17% -17%

Nitrate 1.57 0.8 1.39 1.48 -64,814 

-19% -16% -17%

Organic 

Carbon 7.66 4.02 6.73 7.6 -813 -4% 0% 1%

Elemental 

Carbon 1.63 0.34 1.31 1.3 -1,296 -21% -19% -41%

Fine Soil 1.47 1.16 1.40 1.68 1,470 

11% 14% 22%

Coarse 

Material3 2.7 3.02 2.77 9,193 13% 12% 23%

Sea Salt3 0.1 0.12 0.10

Not 

Applicable

Total Light 

Extinction 28.92 18.16 25.98 28.24

Deciview 10.17 5.72 9.13 9.94

Not Applicable

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined.

2) Results based on Weighted Emissions Potential analysis using the 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

emissions scenarios.

3) Visibility projections not available due to model performance issues.

WRAP TSS - http://vista.cira.colostate.edu/tss/ 
New Mexico Section 308 Regional Haze SIP 177

Table 12-13: Class I Area Visibility Summary for WHIT1 on 20% Worst Days

Class I Area Visibility Summary: White Mountain W, NM 

Visibility Conditions: Worst 20% Days 

RRF Calculation Method: Specific Days (EPA) 

Emissions Scenarios: 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

Monitored Estimated Projected

 

 

2000-04 

Baseline 

Conditions

(Mm-1)

2064 

Natural 

Conditions

(Mm-1)

2018 

Uniform 

Rate of 

Progress 

Target

(Mm-1)1

2018 

Projected 

Visibility 

Conditions

(Mm-1)

Baseline to 

2018 Change 

In Statewide 

Emissions

(tons / %)

Baseline to 

2018 Change 

In Upwind 

Weighted 

Emissions2

(%)

Baseline to 

2018 Change In 

Anthropogenic 

Upwind 

Weighted 

Emissions2

(%)

Sulfate 10.51 0.74 7.64 9.33 -1,320 

-3% 0% 0%

Nitrate 3.05 0.98 2.53 2.99 -64,814 

-19% -23% -27%

Organic 

Carbon 8.97 3.72 7.59 8.64 -813 -4% -3% -6%

Elemental 

Carbon 1.82 0.31 1.45 1.42 -1,296 -21% -20% -32%

Fine Soil 1.89 1.19 1.72 2.02 1,470 

11% 7% 11%

Coarse 

Material3 6.68 4.35 6.10 9,193 13% 0% 1%

Sea Salt3 0.17 0.22 0.18

Not 

Applicable

Total Light 

Extinction 42.08 20.51 35.64 40.24

Deciview 13.7 6.8 12.09 13.26

Not Applicable

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined.

2) Results based on Weighted Emissions Potential analysis using the 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

emissions scenarios.

3) Visibility projections not available due to model performance issues.

WRAP TSS - http://vista.cira.colostate.edu/tss/
New Mexico Section 308 Regional Haze SIP 178

Table 12-14: Class I Area Visibility Summary for WHPE1 on 20% Worst Days 

Class I Area Visibility Summary: Pecos W, NM: Wheeler Peak W, NM 

Visibility Conditions: Worst 20% Days 

RRF Calculation Method: Specific Days (EPA) 

Emissions Scenarios: 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

Monitored Estimated Projected

 

 

2000-04 

Baseline 

Conditions

(Mm-1)

2064 

Natural 

Conditions

(Mm-1)

2018 

Uniform 

Rate of 

Progress 

Target

(Mm-1)1

2018 

Projected 

Visibility 

Conditions

(Mm-1)

Baseline to 

2018 Change 

In Statewide 

Emissions

(tons / %)

Baseline to 

2018 Change 

In Upwind 

Weighted 

Emissions2

(%)

Baseline to 2018 

Change In 

Anthropogenic 

Upwind 

Weighted 

Emissions2

(%)

Sulfate 5.27 0.75 4.07 4.68 -1,320 

-3% -21% -23%

Nitrate 1.64 0.84 1.44 1.61 -64,814 

-19% -24% -28%

Organic 

Carbon 8.37 4.2 7.30 8.23 -813 -4% 0% 2%

Elemental 

Carbon 2.18 0.4 1.74 2.1 -1,296 -21% -11% -40%

Fine Soil 1.75 1.18 1.61 2 1,470 

11% 12% 22%

Coarse 

Material3 2.77 3.21 2.87 9,193 13% 12% 27%

Sea Salt3 0.47 0.49 0.48

Not 

Applicable

Total Light 

Extinction 30.44 19.07 27.33 29.87

Deciview 10.41 6.08 9.40 10.23

Not Applicable

1) 2018 Uniform Rate of Progress Target for Best 20% Days is not defined.

2) Results based on Weighted Emissions Potential analysis using the 2000-04 Baseline (plan02d) & 2018 PRPb (prp18b) 

emissions scenarios.

3) Visibility projections not available due to model performance issues.

WRAP TSS - http://vista.cira.colostate.edu/tss/ 
New Mexico Section 308 Regional Haze SIP 179

CHAPTER 13: OTHER SIP REQUIREMENTS AND COMMITMENTS 

13.1 Enforceability of Emission Limitations and Control Measures 

Section 51.308(d)(3)(v)(F) requires States to ensure that emission limitations and control measures used 

to meet reasonable progress goals are enforceable. 

New Mexico has ensured that all emission limitations and control measures used to meet reasonable 

progress goals are enforceable. New Mexico requests EPA approval of these measures. 

13.2 Commitment to Future 308 SIP Revisions 

40 CFR 51.308(f) requires NMED to revise its Regional Haze Implementation Plan and submit a Plan 

revision to the USEPA by July 31, 2018 and every ten years thereafter. In accordance with the 

requirements listed in Section 51.308(f) of the Federal rule for regional haze, New Mexico commits to 

revising and submitting this Regional Haze Implementation Plan by July 31, 2018 and every ten years 

thereafter. 

In addition, 51.308(g) requires periodic reports evaluating progress towards the reasonable progress goals 

established for each mandatory Class I area. In accordance with the requirements listed in 51.308(g) of 

the Federal rule for regional haze, NMED commits to submitting a report on reasonable progress to the 

USEPA every five years following the initial submittal of the SIP. The report will be in the form of a SIP 

revision. The reasonable progress report will evaluate the progress made towards the reasonable progress 

goal for each mandatory Class I area located within New Mexico and in each mandatory Class I area 

located outside New Mexico which may be affected by emissions from within New Mexico. 

The requirements listed in 51.308(g) include the following: 

A description of the status of implementation of all measures included in the implementation plan for 

achieving reasonable progress goals for mandatory Class I Federal areas both within and outside the state; 

1. Summary of emission reductions achieved thus far; 

2. Assessment of changes in visibility conditions at each Class I area (current vs. baseline), 

expressed as 5-year averages of annual values for least impaired and most impaired days; 

3. Analysis of emissions changes over the 5-year period, identified by source or activity, using the 

most recent updated emissions inventory; 

4. Analysis of any significant changes in anthropogenic emissions in or out of the state which have 

impeded progress; 

5. Assessment of the sufficiency of the implementation plan to meet reasonable progress goals; 

6. Review of the State’s visibility monitoring strategy and any modifications to the strategy as 

necessary. 
New Mexico Section 308 Regional Haze SIP 180

13.3 Commitment to Periodic Progress Reports 

40 CFR 51.308(g), requires a State/Tribe to submit a progress report to EPA every five years evaluating 

progress towards the reasonable progress goals(s). The first progress report is due five years from the 

submittal of the initial implementation plan and must be in the form of an implementation plan revision 

that complies with Sections 51.102 and 51.103. at a minimum, the progress reports must contain the 

elements in paragraphs 51.308(g)(1) through (7) for each Class I area as summarized below. 

1) Implementation status of the current SIP measures; 

2) Summary of emissions reductions; 

3) Assessment of most/least impaired days; 

4) Analysis of emission reductions by pollutant; 

5) Significant changes in anthropogenic emissions; 

6) Assessment of the current SIP sufficiency to meet reasonable progress goals; and 

7) Assessment of visibility monitoring strategy. 

In accordance with the requirements listed in Section 51.308(g) of the federal regional haze rule, New 

Mexico commits to submitting a report on reasonable progress report will evaluate the progress made 

towards the reasonable progress goal for each mandatory Class I area located within New Mexico and in 

each mandatory Class I area located outside New Mexico, which may be affected by emissions from New 

Mexico. 

13.4 Determination of Plan Adequacy 

Depending on the findings of the five-year progress report, New Mexico commits to taking one of the 

actions listed in 40 CFR 51.308(h). The findings of the five-year progress report will determine which 

action is appropriate and necessary. 

List of Possible Actions (40 CFR 51.308(h)) 

1. NMED determines that the existing SIP requires no further substantive revision in order to 

achieve established goals. NMED provides to the EPA Administrator a negative declaration that 

further revision of the SIP is not needed at this time. 

2. NMED determines that the existing SIP may be inadequate to ensure reasonable progress due to 

emissions from other states, which participated in the regional planning process. NMED provides 

notification to the EPA Administrator and the states that participated in regional planning. NMED 

collaborates with states and FLMs through the regional planning process to address the SIP’s 

deficiencies. 

3. NMED determines that the current SIP may be inadequate to ensure reasonable progress due to 

emissions from another country. NMED provides notification, along with available information, 

to the EPA Administrator. 

4. NMED determines that the existing SIP is inadequate to ensure reasonable progress due to 

emissions within the state. NMED will consult with FLMs and revise its SIP to address the Plan’s 

deficiencies within one year. 
New Mexico Section 308 Regional Haze SIP 181

APPENDICES AND TECHNICAL SUPPORT DOCUMENTATION 

Appendix A: Best Available Retrofit Technology Determination for San Juan Generating Station 

Appendix B: Supplementary Information for Four Factor Analyses by WRAP States, EC/R 

Incorporated, May 4, 2009 (corrected April 20, 2010) 

Appendix C: Supplementary Information for Four-Factor Analyses for Selected Individual Facilities in 

New Mexico, May 5, 2009 

Appendix D: 20.2.65 NMAC – Smoke Management