Nevada Regional Haze 5-Year Progress Report, November 2014 1-1

Chapter One – Introduction

Table of Contents

1.1 Clean Air Act Requirements for Addressing Regional Haze........................................... 2

1.2 Requirements for Periodic Reports and Premises............................................................ 3

1.3 Class I Areas in Nevada and Nearby................................................................................ 4
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1.1 Clean Air Act Requirements for Addressing Regional Haze

In 1977, Congress amended the CAA, establishing a national goal to protect visibility in Class I 

federal areas – national parks, forests and wilderness areas. The amendments called for 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.” CAA § 

169A. In 1979, the USEPA, in consultation with the Secretary of Interior, promulgated a list of 

156 mandatory Class I areas in which visibility was determined to be an important factor. In 

Nevada, one area was designated: the Jarbidge WA in the northeast corner of the State.

On July 1, 1999, USEPA issued the RHR, thereby establishing a comprehensive visibility 

protection program for Class I federal areas. The rule is codified in 40 CFR 51.308. The intent of 

the RHR is to improve visibility over the long term in all 156 mandatory Class I areas across the 

country. It requires each affected state to develop and adopt an implementation plan that will 

improve the haziest days and protect the clearest days at each mandatory Class I area in the state,

with a goal of returning to natural visibility conditions by the year 2064. Each plan must provide 

a comprehensive analysis of natural and man-made sources of haze in each mandatory Class I 

area in the state and contain strategies to control anthropogenic emissions that contribute to haze. 

The plan must also address the transport of haze across state boundaries. The 2009 RH SIP,

prepared by the NDEP, was submitted to the USEPA on November 18, 2009. The 2009 RH SIP 

addressed the initial planning period of the RHR, 2008-2018, and is considered the foundational 

plan for subsequent planning periods. 

The USEPA designated five Regional Planning Organizations (RPOs) to assist with the technical 

support, coordination and cooperation needed to address the visibility issue for the first regional 

haze SIPs. The multistate RPOs were established to perform the technical regional analyses for

these SIPs. The RPO supporting the western states’ regional haze effort is the Western Regional 

Air Partnership (WRAP). 

Most of the technical data included in this progress report is from the “Western Regional Air 

Partnership Regional Haze Rule Reasonable Progress Summary Report” (WRAP TSD) (WRAP 

2013) developed by the WRAP (www.wrapair2.org, last viewed 8/4/2014) in June of 2013 and 

the WRAP Technical Support System (TSS) (http://vista.cira.colostate.edu/tss/, last viewed 

8/25/2014). The Nevada subsection in the “State and Class I Area Summaries” section of the 

WRAP TSD is included as Appendix A. The WRAP TSD was prepared to provide the technical 

basis for use by the western states to develop the first of their individual reasonable progress

reports for the 116 federal Class I areas located in the western states. Data are presented in the 

WRAP report on a regional, state, and Class I area-specific basis that characterize the difference 

between 2000-2004 baseline conditions and current conditions, represented by the most recent

successive 5-year average, that is, the 2005-2009 period. The WRAP report characterizes

changes in visibility impairment using aerosol measurements from the Interagency Monitoring of 

Protected Visual Environments (IMPROVE) network, and it analyzes the differences between 

emissions inventory years represented by the baseline and current progress periods.
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1.2 Requirements for Periodic Reports and Premises

Section 51.308(f) of 40 CFR 51 requires the state to submit a comprehensive SIP revision July

31, 2018 and every 10 years thereafter. Section 308(g) requires periodic reports every five years 

after the initial regional haze SIP was 

submitted. Periodic reports must 

evaluate progress towards the 

reasonable progress goals (RPG) for 

each Class I area located within the 

state, as well as those located outside 

the state which may be affected by 

emissions from within the state. This 

report satisfies the first 5-year 

progress report requirement. The 

minimum elements required in each 

periodic report are listed in 40 CFR 

§§ 308(g)(1-7) and 308(h)(1-4). This 

report is organized according to those 

elements.

Five-year progress reports must include: 1) the status of implementation of control measures 

included in the original regional haze SIP, 2) a summary of emission reductions achieved 

through the implementation of control measures, 3) an assessment of visibility conditions, 4) an 

analysis of the changes in emissions of visibility-impairing pollutants, 5) an assessment of 

significant changes in anthropogenic emissions that may have limited or impeded progress in 

improving visibility, 6) an assessment of whether the current SIP elements and strategies are 

sufficient to meet reasonable progress goals, and 7) a review of the state’s visibility monitoring 

strategy. 

At the same time the state submits its progress report, the state must also make a determination 

of the adequacy of the existing implementation plan. This 5-year review provides a progress 

report on the initial 2009 RH SIP. It addresses each required element based on data that was 

available as of March 1, 2014. The 2000 through 2004 baseline period planning inventory was 

developed by the WRAP to represent baseline conditions for comparison with future year 

projected emissions, as well as for gauging reasonable progress with respect to future year 

visibility. The baseline inventory, Plan02d, was used in the initial RH SIP and is used in this 

report, also, as the reference planning period. To assess progress, this report relies on emissions 

information from the 2008 National Emissions Inventory (NEI) as updated by the WRAP 

through its WestJump Air Quality Modeling Study (WestJump 2008), 2011 NEI data, and 

visibility data from the 5-year period from 2008 to 2012.

In discussing the status of control strategies, USEPA guidance suggests that “[t]he report should 

focus on a targeted evaluation of important control measures that achieve reductions in visibility51.308(g) Requirements for periodic 

reports describing progress towards the 

reasonable progress goals. Each State 

identified in § 51.300(b)(3) must submit 

a report to the Administrator every 5 

years evaluating progress towards the 

reasonable progress goal for each 

mandatory Class I Federal area located 

within the State and in each mandatory 

Class I Federal area located outside the 

State which may be affected by 

emissions from within the State.
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impairing pollutant species.” USEPA 2013, page 5. The WRAP technical analyses of causes of 

haze in the west show significant impacts from non-anthropogenic and otherwise noncontrollable source sectors, such as fire, dust and sources outside Nevada’s jurisdiction and, 

therefore, outside of Nevada’s control. 2009 RH SIP Section 7.9.3. In Nevada, nearly threequarters of the visibility-impairing pollutant emissions come from natural sources. 

The 2009 RH SIP identifies the relative contribution of each visibility impairing pollutant from 

anthropogenic and natural emission sources. 2009 RH SIP Section 7.9.1. The data show sulfur 

dioxide (SO2) and nitrogen dioxide (NO2) emissions are predominately from anthropogenic 

sources, such as point, mobile and area sources. Nevada’s long-term strategy for the first 

planning period focused on these pollutants in part due to the important role of BART for the 

first planning period, but also due to the controllable nature of these emissions. This report, 

therefore, focuses on the status of efforts to date to control SO2 and NO2 emissions. In addition, 

controlling SO2 and NO2 emissions has a co-benefit of reducing other visibility-impairing 

pollutants. 

40 CFR Section 51.308(i) sets forth the requirements for State and federal land managers 

(FLMs) coordination. Subparagraphs (2) and (3) require an opportunity for FLMs to consult 

with the state on visibility impairment, reasonable progress goals and control strategies for Class 

I areas in the state. Evidence of compliance with these requirements is included as Appendix C 

of this report. Subparagraph (4) requires a plan for continued consultation by the state with 

FLMs. In the 2009 RH SIP, Nevada committed to continuing consultation between the State and 

FLMs on the implementation of the visibility protection program, including development and 

review of implementation plan revisions and 5-year progress reports, and on the implementation 

of other programs having the potential to contribute to impairment of visibility in any mandatory 

federal Class I area within the State. Nevada also committed to continued participation in the 

WRAP and coordination and consultation with nearby states and tribes. The State of Nevada 

reaffirms its commitment to participate in a regional planning process with the WRAP states, the 

U.S. Department of Interior (USDOI), the Fish and Wildlife Service (FWS) and the National 

Park Service (NPS).

1.3 Class I Areas in Nevada and Nearby

Nevada’s single mandatory Class I area, the 113,167 acre Jarbidge WA, is located within the 

Humboldt National Forest in the northeastern portion of Nevada, as shown in Figure 1. Chapter 

Eight describes the geographic and physiographic setting of the Jarbidge WA. Chapter One of 

the 2009 RH SIP contains a more in depth description.
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Figure 1-1. Location Map Showing Mandatory Class I Areas in the WRAP Region

The primary contributors to visibility impairment at Jarbidge WA for the worst days are 

particulate organic matter (POM), coarse mass (CM) and ammonium sulfate (sulfate). 2009 RH 

SIP, Table 2-2 and Chapter Four of this report. Elevated levels of particulate organic matter and 

its seasonal pattern suggest these particles are the result of volatile organic compounds (VOCs) 

and primary organic aerosols (POAs) emitted from biogenic sources and wildfires, respectively. 

Similarly, coarse mass is due mostly to naturally occurring emissions from windblown dust and 

fugitive dust events. Sulfate is the third highest contributor to light extinction on the worst days 

and the one most closely associated with anthropogenic sources of SO2. Fine soil, elemental 

carbon (EC) and ammonium nitrates (nitrates) have only a minimal contribution to light 

extinction at Jarbidge WA. In summary, most of the light extinction at Jarbidge WA is due to 

natural sources (more than 70 percent) with SO2 being the most significant anthropogenic 

pollutant contributing to visibility impairment.
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In the 2009 RH SIP, Nevada established its 2018 reasonable progress goal for Jarbidge WA at 

11.05 deciviews.

1

 The goal was set equal to the 2018 visibility projection modeled by the 

WRAP’s contractor, the Regional Modeling Center, and slightly under the uniform rate of 

progress glidepath2(11.09 deciviews). 2009 RH SIP, Chapter Two. In April 2011, the NDEP 

was notified that there had been an error in the Regional Modeling Center’s modeling and the 

corrected 2018 visibility projection for Jarbidge WA was 11.8 deciviews. 

In establishing a reasonable progress goal, the RHR requires that states “consider the uniform 

rate of improvement in visibility and the emission reduction measures needed to achieve it for 

the period covered by the implementation plan.” 51.308(d)(1)(i)(B). The uniform rate of 

progress for Jarbidge WA in 2018 is 11.09 deciviews. In developing this progress report, the 

NDEP evaluated the status of control measures included in the 2009 RH SIP and changes in 

source activity that have occurred since the 2009 RH SIP that would affect emissions included in 

the corrected 2018 visibility projection. Chapter Two provides evidence not only of emissions

reductions from the control measures included in the 2009 RH SIP, but also additional reductions 

from implementation of BART and new State legislation. Furthermore, the 2018 emission 

projections included a large coal-fired power plant that has since been decommissioned and three 

proposed power plants that are no longer viable. Chapter Five provides evidence that emissions 

from anthropogenic sources in Nevada as of 2008 are already lower than the emissions 

projections used by the WRAP in the 2018 regional air quality modeling. Considering all of this 

evidence, the NDEP concludes that it is appropriate to retain the reasonable progress goal of 

11.05 deciviews for Jarbidge WA, which aligns with the glidepath value for 2018, and that 

reasonable progress toward the 2018 goal is being achieved. 

The 2009 RH SIP looked at Nevada’s contribution to visibility impairment in nearby Class I 

areas. The Particulate Matter Source Attribution Tracking modeling results (TSS, 

http://vista.cira.colostate.edu/tss/, last viewed 8/4/2014) were evaluated to determine which Class 

I areas in adjacent states might be affected by emissions from Nevada sources (2009 RH SIP 

Chapter Four). Visibility modeling results for 2018 indicated that, for best days, Nevada’s largest 

contribution to light extinction due to sulfate at a nearby Class I area would occur at the 

Sawtooth Wilderness Area in Idaho, with a contribution of 7.2 percent. For the worst days, 

Nevada’s maximum contribution was projected to occur at the Zion National Park in Utah, with 

a contribution of 5.6 percent. For nitrate extinction, 2018 modeling results of best days projected 

that Nevada’s maximum contribution would occur at the Joshua Tree National Park in 

California, with a contribution of 12.4 percent. For the worst days, 2018 modeling showed 

Nevada’s maximum contribution to nitrate extinction occurring at Bliss State Park in California, 

 

1 The deciview is a measure of visibility derived from calculated light extinction measurements that is designed so 

that uniform changes in the haze index correspond to uniform incremental changes in visual perception, across the 

entire range of conditions from pristine to highly impaired. See USEPA’s Guidance for Tracking Progress Under 

the Regional Haze Rule at: http://www.epa.gov/ttn/oarpg/t1/memoranda/rh_tpurhr_gd.pdf. (last viewed 9/8/2014)

2 The glidepath is one of the indicators used to set reasonable progress goals and is simply a graph portraying a 

straight line drawn from the level of visibility impairment for the worst days baseline period to the natural 

background level with 2064 as the attainment date.
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with a contribution of 20.0 percent. The monitor located at Bliss serves the Desolation 

Wilderness Area and the Mokelumne Wilderness Area. 2009 RH SIP, Tables 4-3 and 4-4.

As discussed in Chapter Six, the NDEP’s analysis of the State’s contribution to visibility 

impairment at nearby Class I areas in 2018 demonstrates that the percentage of Nevada’s 

anticipated emissions reductions or weighted emissions reductions exceed the percentage of 

Nevada’s projected contribution. 2009 RH SIP Section 7.9.3.2. Thus, Nevada’s impact on 

nearby Class I areas was determined to be insignificant. Chapter Two of this 5-year progress 

report evaluates the status of the control measures in the 2009 RH SIP and Chapter Three 

summarizes emissions reductions achieved through implementation of those measures. Both of 

these chapters confirm that the conclusions in the 2009 RH SIP still stand.