Nevada Regional Haze 5-Year Progress Report, November 2014 

APPENDIX D

Evidence of Public Participation; 

Public Comments and Nevada’s Responses
Nevada Regional Haze 5-Year Progress Report, November 2014 

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Nevada Regional Haze 5-Year Progress Report, November 2014 

CONTENTS

D.1 Evidence of Public Participation............................................................................1

D.1.1 Notice of Public Hearing........................................................................................2

D.1.2 Notice of Cancellation of Hearing.......................................................................4

D.1.3 Newspaper Affidavits.............................................................................................5

D.1.4 SIP Approval Authority..........................................................................................8

D.2 Public Comments and Nevada’s Responses.......................................................9

D.2.1 Nevada’s Response.................................................................................................10

D.2.2 Sierra Club-National Parks Conservation Association 

Comments...................................................................................................................32
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SECTION D.1

EVIDENCE OF PUBLIC PARTICIPATION
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D.1. 1 Notice of Public Hearing

Pursuant to the public hearing requirements in Title 40 of the Code of Federal Regulations Part 51 

section 102, the Nevada Division of Environmental Protection (NDEP) is issuing the following notice.

In 1977, Congress amended the Clean Air Act (CAA) establishing a national goal to protect visibility in 

Class I federal areas – primarily national parks 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.” Nevada has one 

mandatory Class I area, the Jarbidge Wilderness Area, in the northeast corner of the state managed 

by the U.S. Forest Service. 

In 1999, the U.S. Environmental Protection Agency (USEPA) adopted the Regional Haze Rule (RHR) 

requiring each affected state to develop and adopt a plan to 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. The NDEP prepared a Regional Haze state implementation plan 

(SIP) to meet the requirements of the federal rule and submitted it to USEPA on November 18, 2009. 

The RHR further requires periodic progress reports every five years after the initial SIP is submitted. 

The NDEP has prepared a draft “Nevada Regional Haze 5-Year Progress Report” (Report) to meet the 

requirements of the federal rule. The Report will be submitted to the USEPA by November 18, 2014. 

The draft Report and related materials are available on the NDEP website at: 

http://ndep.nv.gov/admin/public.htm#air_qp or http://ndep.nv.gov/baqp/index.htm. Access to 

the draft report may also be obtained by contacting Adele Malone at NDEP, 901 S. Stewart Street, 

Suite 4001, Carson City, NV 89701; (775) 687-9356; or e-mail to amalone@ndep.nv.gov. 

Persons wishing to comment on the draft 5-year progress report during the comment period or to 

request a public hearing should submit their comments or request in writing either in person, by

postal service, or fax to Adele Malone at the NDEP address above, or by FAX at (775) 687-6396. A 

request for a hearing must be received by October 6, 2014. Written comments will be received 

by the NDEP until 5:00 PM PST, October 15, 2014 and will be retained and considered.

Upon receipt of a valid written request, the NDEP will hold a public hearing in Carson City on:

October 15, 2014

10:00 am to 12:00 pm

Great Basin Conference Room, 4th Floor-South

901 South Stewart Street

Carson City, Nevada

NOTICE OF PUBLIC COMMENT PERIOD BEGINNING 

SEPTEMBER 15, 2014 AND A PUBLIC HEARING ON 

OCTOBER 15, 2014, IF REQUESTED

Conducted by the Nevada Division of Environmental Protection

Bureau of Air Quality Planning
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An agenda will be posted on the NDEP web site at least 3 working days prior to the hearing. Oral 

comments will be received at the Hearing. If no request for a public hearing is received by October 

6, 2014, the hearing will be cancelled. Persons may check on the status of the hearing on the NDEP

web site at http://ndep.nv.gov/admin/public.htm#air_qp, or you may call the NDEP Bureau of Air 

Quality Planning at (775) 687-9349.

This notice has been published in the Las Vegas Review-Journal and the Reno Gazette Journal newspapers. It has been 

posted at the NDEP offices in Carson City and Las Vegas, at the State Library in Carson City and at County libraries throughout 

Nevada. Members of the public who are disabled and require special accommodations or assistance at the hearing are 

requested to notify Adele Malone (775-687-9356) no later than 3 full working days before the hearing. 9/10/2014
Nevada Regional Haze 5-Year Progress Report, November 2014

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D.1.2 Notice of Cancellation of Hearing

NOTICE OF CANCELLATION OF PUBLIC HEARING ON OCTOBER 15, 2014

Nevada Division of Environmental Protection

Bureau of Air Quality Planning

Pursuant to the public hearing provisions in Title 40 of the Code of Federal Regulations Part 51 

section 102, the Nevada Division of Environmental Protection (NDEP) is cancelling the following 

public hearing because no request for a hearing was received:

October 15, 2014

10:00 a.m. to 12:00 p.m.

Great Basin Conference Room, 4th Floor

901 South Stewart Street

Carson City, Nevada

The draft Nevada Regional Haze 5-Year Progress Report and related materials are available on the 

NDEP website at http://ndep.nv.gov/admin/public.htm, click on “Air Quality Planning.” Persons 

may also check on the status of Nevada’s regional haze progress report by telephone at (775) 687-

9356.
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D.1. 3 Newspaper Affidavits
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D.1. 4 SIP Approval Authority
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SECTION D.2

PUBLIC COMMENTS AND NEVADA’S RESPONSES
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On September 15, 2015, the Nevada Division of Environmental Protection (NDEP) opened a 30-

day public comment period on the draft Nevada Regional Haze 5-Year Progress Report (Progress 

Report) with the opportunity for a public hearing in Carson City to be held upon public request. 

Pursuant to the public hearing provisions in Title 40 of the Code of Federal Regulations (CFR) Part 

51 section 102, the NDEP cancelled the public hearing as no request for a hearing was received. 

The NDEP received one set of written comments during the 30-day public comment period ending 

October 15, 2014. The single set of comments had signatories from the Sierra Club and National 

Parks Conservation Association and will be referred to as the non-governmental organization 

(NGO) comments in the remainder of this document. The NGO letter in its entirety follows the 

NDEP’s response below. 

D.2.1 Nevada’s Response

SUMMARY OF COMMENTS

The NGO comments focus on the basis of Nevada’s negative declaration that emissions 

management measures in the 2009 RH SIP are being implemented on schedule and visibility 

improvement appears to be consistent with reasonable progress goals. Specifically, the NGO 

comments focus on the following:

 The perceived need for a modeling demonstration that the significant emissions reductions 

that have and will occur at numerous EGUs in the State have significant visibility impacts 

on the Jarbidge Wilderness Area (Jarbidge WA);

 The assertion that Nevada’s progress evaluation is based on a reasonable progress goal that

purportedly used a flawed modeling analysis and an outdated emission inventory;

 The NGO’s contention that visibility monitoring data do not show that the Jarbidge WA is 

on a path consistent with the reasonable progress goals; and

 The NGO’s conclusion that Nevada should revise its haze plan to include new strategies to 

improve the progress towards remedying visibility impairment at the Jarbidge WA

NEVADA’S RESPONSE 

The NDEP responds first to the general NGO comments as presented on the first two and half pages 

of the comment letter and summarized above, and then to the four specific comments detailed in the 

remainder of the letter. 

General Comments

The NDEP appreciates the NGO’s thorough review of Nevada’s Progress Report and their 

comments. However, the NGO comments overlook some of the basic facts and science supporting 

Nevada’s Progress Report. The NDEP maintains that the Progress Report fulfills every requirement 

set forth in the Regional Haze Rule (RHR) using the best data available at the time the report was 
Nevada Regional Haze 5-Year Progress Report, November 2014

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written. The report documents the first five years of progress for a 60-year planning horizon. 40 

CFR 51.308(d)(1)(i)(B). Nevada will submit a full SIP revision in 2018 with an evaluation of 

progress likely informed by Regional Planning Organization (RPO) photochemical grid modeling 

for visibility assessment and source apportionment. 

The NDEP emphasizes that three-quarters of visibility impairing emissions in Nevada are emitted 

by natural (non-anthropogenic) sources. 2009 RH SIP, Table 3-2. The Progress Report focuses on 

the major sources of anthropogenic emissions in Nevada, SO2 and NOx. Emissions of SO2 and NOx

from Nevada point sources have decreased by 78 percent and 50 percent between 2002 and 2008, 

respectively, with additional reductions through 2011. Progress Report, Sections 3.1 and 5.5.

Nevada has one mandatory Class I area, the Jarbidge WA. The Progress Report demonstrates that 

Nevada’s contribution to visibility impairment at Jarbidge WA is minimal. Five-year rolling 

averages of annual worst days visibility conditions from 2010 to 2012 (2006-2010, 2007-2011 and 

2008-2012) show nitrate contributes between 3.5 and 4.2 percent, and sulfate contributes between 

15.1 and 16.6 percent of total light extinction on the worst days at JARB1. Progress Report, Table 

4-4. Source apportionment modeling (Table 2 and Table 3 below) shows that in the worst case 

scenario, Nevada NOx and SO2 emissions contribute at most only 0.6 and 0.9 percent, respectively,

to total light extinction at the Jarbidge WA.

1

 When emissions from only point sources are 

considered, the contributions drop to 0.3 and 0.6 percent, respectively. 

The RHR requires each state to adopt a plan to improve the haziest days and protect the clearest days 

at each mandatory Class I area in the state. The Progress Report shows that from the baseline to the 

progress period, there is no degradation of the best days sulfate or nitrate light extinction at the 

Jarbidge WA. Figure 5, below. Furthermore, nitrate is not impeding worst days visibility progress 

at the Jarbidge WA. Five-year averages of annual worst days visibility conditions for nitrate show a 

persistent downward trend for the last six 5-year periods and are below the glidepath for nitrate for 

the last four 5-year periods. Progress Report, Figures 4-14 and 4-15; and Figure 3, below. Fiveyear averages of annual worst days visibility conditions for sulfate show a persistent downward 

trend consistent with the sulfate glidepath for the last seven 5-year periods, although the averages 

are above the glidepath. Significantly, three of the last six annual averages are on or below the 

glidepath for sulfate. Progress Report, Figures 4-12 and 4-13; and Figure 3, below. Trend analysis 

of the 2000 to 2012 nitrate and sulfate annual extinction values demonstrates that the slopes of the 

trend lines are comparable to (sulfate) or better than (nitrate) the speciated glide slopes for Jarbidge 

WA from baseline to natural conditions. Progress Report, Section 4.6.

The NGO comments suggest in several places that the significant emissions reductions achieved by 

Nevada do not equate to visibility improvement at both the Jarbidge WA as well as out-of-state 

Class I areas, but fail to present any hard data to substantiate these suggestions. The NDEP presents 

evidence to the contrary in our responses below. The 2018 regional haze SIP revisions are expected 

 

1 The NDEP calculated Nevada’s contributions to visibility impairment at the Jarbidge WA using: 1) the monitoring 

data for sulfate and nitrate from JARB1; and 2) the WRAP’s nitrate and sulfate source appointment modeling results for 

JARB1. The speciated contribution to the monitored light extinction was multiplied by Nevada’s percent contribution 

according to the source apportionment modeling to calculate Nevada’s contribution to sulfate and nitrate light extinction 

at JARB1. Essentially, Nevada’s point sources contribute a percentage of a percentage.
Nevada Regional Haze 5-Year Progress Report, November 2014

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to be supported by RPO modeling that will demonstrate how emissions reductions impact visibility 

impairment and will be the basis to further evaluate reasonable progress goals for the Jarbidge WA

and impacts on out-of-state Class I areas. 

In addition, the USEPA is proceeding with guidance and potential rule changes for the regional 

haze SIPs due in 2018. There are indications2the guidance and rule changes may include revisions 

to the four-factor analysis requirement and setting reasonable progress goals based on controllable 

emissions. There may also be consideration of a revised regional haze metric to replace the current 

metric of the deciview glidepath, as well as reconsideration of what natural conditions represent. 

Specific Comments

NGO Comment 1: NDEP Must Revise Its Reasonable Progress Goal for Jarbidge Wilderness to 

Be Based on the WRAP’s Revised Modeling with its 2018 PRPB Emissions Projections.

The NGOs support this comment with observations that Nevada’s reasonable progress goal is based 

on modeling subsequently found to be in error and based on outdated 2018 emission projections. 

They further contend that emissions reductions in Nevada have not been demonstrated to impact or 

improve visibility at the Jarbidge WA, and the 2018 projected emission inventory does not include 

emissions for oil and gas development. 

NDEP Response: 

Page 1-6 of the Progress Report discusses Nevada’s rationale for retaining its 2018 reasonable 

progress goal in light of the corrected modeling results noted by the NGO comments. The NDEP 

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

that have occurred since then that would affect emissions included in corrected modeling. The 

NDEP presents evidence not only of emissions reductions from the control measures included in the 

2009 RH SIP, but also further reductions from the full implementation of best available control 

technology (BART) and new state legislation. The NDEP notes the 2018 emissions projections 

included a large power plant that has since been decommissioned and three proposed power projects 

that are no longer viable. The Progress Report presents evidence that 2008 emissions from 

anthropogenic sources in Nevada are less than the 2018 emissions projections used by the WRAP in 

the 2018 visibility modeling. Based on these lines of evidence, the NDEP concluded that it was 

appropriate to retain the reasonable progress goal of 11.05 deciviews. The NDEP responds to the 

four components of this NGO comment below. 

Modeling Error Assessment

Nevada’s reasonable progress goal is based on the visibility modeling results as captured by the 

Plan02d and PRP18a emission inventories, which provided the best available information at the 

time the 2009 RH SIP was prepared and will be referred to as the original visibility modeling results 

in the discussion below. Note to Readers, 2009 RH SIP preface (noting cutoff date of January 5, 

 

2 National Association of Clean Air Agencies, Criteria Pollutants Committee September 24, 2014 conference call, 

agenda item 6 briefing by Rhea Jones, Group Leader, Geographic Strategies Group, Air Quality Policy Division. See 

also Inside EPA’s Clean Air Report, November 6, 2014, page 16.
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2009). Modeling results from the PRP18b emission inventory were not available until after this 

cutoff date. As noted in the NGO comments, the WRAP memorandum describing the modeling 

error was released in April 2011, a year and a half after Nevada submitted its initial regional haze 

SIP. Therefore, results based on PRP18b and the corrected modeling results were not evaluated for 

Nevada’s original regional haze SIP. 

In response to this comment, the NDEP evaluated how the visibility modeling results for the 

Jarbidge WA changed based on use of: 1) the corrected modeling, which is identified as modeling 

scenario Plan02d_rev, and 2) a second revision to the 2018 emissions inventory projections for 

point and area sources (or updated modeling) in the WRAP region identified as modeling scenario 

PRP18b. Table 1 presents the modeling results for the original visibility modeling, the corrected 

modeling, and the updated modeling. 

Table 1. Comparison of Visibility Modeling Results for the Jarbidge WA

Table 1 shows that visibility impairment, as measured in deciviews, increased by only seven percent 

due to correction of the modeling error (i.e., the difference between Plan02d_rev/PRP18a and 

Plan02d/PRP18a), with the greatest extinction increases occurring for elemental carbon (EC) at 32 

percent, nearly 20 percent for particulate organic matter (POM,) and 17 percent for soil. These

increases are primarily the result of non-anthropogenic emissions. Further, visibility impairment is 

only slightly impacted by the emissions inventory update from PRP18a to PRB18b (i.e., the 

difference between Plan02d_rev/PRP18b and Plan02d_rev/PRP18a) with no change to the haze 

index and the minor changes to speciated extinction noted in Table 1.

Based on this evaluation of the modeling results, the NDEP concludes: 1) the corrected modeling 

results suggest an increase in visibility impairment at the Jarbidge WA resulting mostly from large 

increases in non-anthropogenic sources; and 2) modeling based on the updated 2018 emissions 

projections did not change the visibility impairment as measured in deciviews, and most speciated 

extinction values declined slightly with a slight increase in sulfate extinction. Nevada stands by its 

evaluation of the status of control measures included in the 2009 RH SIP and the changes that have 

occurred that would affect emissions included in the 2018 visibility projections, as well as its 

decision to retain the reasonable progress goal of 11.05 deciviews. 

Modeling Scenarios by Emission 

Inventory Deciview 

(dv)

Sulfate 

Extinction 

(Mm-1)

Nitrate 

Extinction 

(Mm-1)

POM 

Extinction 

(Mm-1)

EC 

Extinction 

(Mm-1)

Soil 

Extinction 

(Mm-1)

CM 

Extinction 

(Mm-1)

Sea Salt 

Extinction 

(Mm-1)

Plan02d/PRP18a (Original) 11.05 3.34 0.70 8.24 1.12 2.29 5.47 0.06

Plan02d_rev/PRP18a (Corrected) 11.82 3.57 0.77 9.88 1.48 2.67 5.47 0.06

Difference: Plan02d_rev/PRP18a - 

Plan02d/PRP18a

0.77 0.22 0.07 1.64 0.36 0.38 0 0

Percent change from correction 6.9% 6.7% 10.7% 19.9% 32.1% 16.6% 0% 0%

Plan02d_rev/PRP18b (Updated) 11.82 3.64 0.76 9.85 1.47 2.64 5.47 0.06

Difference: Plan02d_rev/PRP18b - 

Plan02d_rev/PRP18a

0.00 0.07 -0.01 -0.04 -0.01 -0.03 0 0

Percent change from update 0.0% 1.9% -1.8% -0.4% -0.5% -1.0% 0% 0%
Nevada Regional Haze 5-Year Progress Report, November 2014

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Emissions Projections

As noted in the NGO comments, Nevada used modeling results based on projected 2018 emissions 

as captured by the PRP18a inventory to identify Nevada’s reasonable progress goal. Since 

Nevada’s reasonable progress goal was based on the PRP18a inventory, it makes sense to use this 

inventory as a basis of comparison (Progress Report, Table 5-1) to determine the emissions 

reductions achieved through the implementation of the measures included in Nevada’s 2009 RH 

SIP. The NDEP also notes that the more refined PRP18b inventory, while reducing emissions from 

some source categories and increasing others, does not change the modeled visibility impacts (as 

measured in deciviews) at the Jarbidge WA, and all speciated light extinction improves with the 

exception of sulfate extinction (see Table 1, above). 

The NDEP notes that all emission inventories are outdated immediately upon completion due to the 

changing nature of sources and their emissions. The PRP18b projections are no exception and do 

not reflect the changes noted in the Progress Report.

Impact of Emissions Reductions on Visibility at Jarbidge WA

The NGO comments acknowledge the significant reductions of anthropogenic emissions from 

Nevada sources documented in the Progress Report, but suggest these reductions do not improve 

visibility at the Jarbidge WA (i.e., emissions reductions have “not been shown to equate to an 

improvement in visibility impairment at the Jarbidge Wilderness Area”) (NGO comment letter, 

page 4). The NGO comments also suggest that projected emissions from facilities that were 

included in the WRAP modeling inventory (PRP18a), but ultimately were not constructed, also 

have not been shown to impact visibility at the Jarbidge WA because of a lack of single source 

visibility modeling. The NGOs do not provide any evidence to support these suggestions. The 

NGOs further fault the NDEP for using PRP18a emissions projections in evaluating the adequacy of 

its reasonable progress goal.

The NDEP disagrees with this assessment. The RHR was established to address “widespread haze 

from a multitude of sources which impairs visibility in every direction over a large area.” 40 CFR 

51.300 (a). The NDEP purports that although Nevada’s point source contribution to haze at 

Jarbidge WA is small, the significant reductions in SO2 and NOx emissions during the progress 

period are reflected in visibility improvement at Jarbidge WA. 

First, Table 1 above shows no change in visibility impairment at Jarbidge WA, as measured in 

deciviews, resulting from the update to the 2018 emissions projections. It shows only small 

decreases in the speciated light extinction, except for a slight increase in light extinction due to 

sulfate. The SO2 emissions increases and NOx decreases noted in the April 29, 2009 (revised 

October 16, 2009) technical memorandum from Eastern Research Group (ERG),

3 WRAP PRP18b 

Emissions Inventory – Revised Point and Area Source Projections, may account for the increase in 

modeled sulfate concentrations and the decrease in modeled nitrate concentrations at the Jarbidge 

 

3 WRAP PRP18b Emissions Inventory – Revised Point and Area Source Projections. April 29, 2009 (Revised October 

16, 2009). Technical Memorandum from Marty Wolf and Paula Fields, Eastern Research Group, to the WRAP staff. 

http://www.wrapair.org/forums/ssjf/documents/Pivot_Tables/PRP18b/Final_PRP18b_point_area_source_memo_erg_10

1609_revised.pdf (last viewed 11/5/2014)
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WA. Table 8e of the ERG memorandum shows an increase in Nevada SO2 point source emissions 

of 13,532 tons per year from the PRP18a to PRP18b inventories, as well as a decrease of 8,876 tons 

per year of NOx point source emissions. Table 9e shows no changes to the area source inventory for 

NOx or SO2, indicating that all of the changes in model results are due to changes in the point source 

inventory. 

The NDEP notes that the emissions changes between PRP18a and PRP18b may not reflect actual 

changes in facility emissions. The changes were made to address certain changes in projections and 

corrections that were identified since the January 2007 revision to the 2018 projection inventory.4 

Note that many of the facilities or units at the facilities listed below were not built, have been or are 

scheduled to be shut down, or will be converted from coal-fired to natural gas before 2018. For 

example, the Ely Energy Center, Toquop and the White Pine Energy Center all modeled with 

increases in NOx and SO2 in the PRP18b update, however, none of those facilities were permitted; 

therefore, the projected increases in emissions are unreal. Progress Report, pages 2-7, 2-8 and 3-3, 

3-4. In addition, the NOx and SO2 decreases for Mohave are underestimates, because they are based 

on BART limits, whereas the facility was actually shut down at the end of 2005.

Nevertheless, the data demonstrate that changes in Nevada’s point source inventory do impact

Jarbidge WA. The data in Tables 5 and 6 of the ERG memorandum show increases in SO2

emissions and significant decreases in NOx from Reid Gardner, Fort Churchill, and Tracy, as well 

as large reductions in NOx and SO2 from Mohave, as a result of updates to BART. Additional 

documentation of the inventory changes between the PRP18a and PRP18b inventories is presented 

in the Nevada – Point Sources table, which incorporates the changes noted in tables 5 and 6, in 

Attachment 1 of the ERG memorandum. The Nevada – Point Sources table shows:

 NOx and SO2 increases for Ely Energy Center, Toquop, TS Power (Newmont Nevada 

Energy Investment), North Valmy, and White Pine Energy Center;

 NOx increases for Graymont Western and Nevada Cement; 

 SO2 increases at Reid Gardner;

 NOx and SO2 decreases for Mohave; and

 NOx decreases for Reid Gardner, Fort Churchill, and Tracy.

These data and the data in Table 1 of this response suggest that emissions reductions from facilities 

across the state, including those in southern Nevada, do contribute to visibility improvement at the 

Jarbidge WA, since approximately half of the listed facilities are not located in northern Nevada. 

The WRAP conducted source apportionment modeling that included regional contributions to 

modeled sulfate and nitrate concentrations at the Jarbidge WA, including emissions from all Nevada 

point sources. The percent contribution to modeled sulfate on the worst 20 percent visibility days

by region and source category is presented in Table 2, while the contribution to modeled nitrate for 

the worst 20 percent visibility days is presented in Table 3. Tables 2 and 3 show Nevada’s point 

source emissions contribute 2.7 percent and 3.5 percent to the total modeled sulfate concentration in 

2002 and 2018, respectively, and 3.9 percent and 6.3 percent to the total modeled nitrate 

 

4

See supra n.3.
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concentration in 2002 and 2018, respectively.5 Recalling that light extinction due to sulfate 

accounts for approximately 15 percent and nitrate for 3.5 percent of total light extinction on worst 

days at Jarbidge WA (Progress Report, Table 4-4, 2008-2012 5-year average), overall contributions 

by Nevada point sources to worst days visibility impairment is about 0.5 percent and 0.2 percent for 

sulfate and nitrate, respectively.6 The NDEP contends that the large reductions in point source 

emissions of SO2 and NOx during the progress period do contribute to visibility improvement at the 

Jarbidge WA; however, Nevada’s overall point source contribution to light extinction at Jarbidge 

WA is small, while other source category contributions have a larger impact. Clearly, emissions 

from the North Valmy Generating Station are not a significant source of visibility impairment at the 

Jarbidge WA. 

Table 2. Percentage Contribution to Modeled Worst Days Sulfate Concentration at the 

Jarbidge WA by Source Region and Category for 2002 (plan02c) and 2018 (base18b)

Point Anthro 

Fire Mobile Natural Fires and Biogenics Area Total

2002

Canada 2.3% 0% 0.2% 0% 1.9% 4.3%

Central US 1.5% 0% 0.2% 0% 0.2% 1.9%

Eastern US 2.6% 0% 0% 0% 0.2% 2.8%

Mexico 2.1% 0% 0% 0% 0.4% 2.6%

Outside Domain* n/a n/a n/a n/a n/a 41.8%

Pacific Offshore 0.8% 0% 0.4% 0% 5.3% 6.6%

WRAP 18.8% 0.5% 6.4% 10.1% 4.3% 39.9%

WRAP States

AZ 0.6% 0% 0.1% 0% 0% 0.7%

CA 2.1% 0% 0.6% 1.3% 0.6% 4.6%

CO 0.4% 0% 0% 0% 0.0% 0.4%

ID 2.3% 0.1% 1.1% 5.1% 0.9% 9.5%

MT 0.1% 0% 0.1% 0% 0.1% 0.3%

NV 2.7% 0% 0.3% 0.9% 0.6% 4.5%

NM 0.3% 0% 0% 0% 0% 0.4%

ND 0.1% 0% 0% 0% 0% 0.1%

OR 2.9% 0.2% 1.5% 2.1% 1.0% 7.7%

SD 0% 0% 0% 0% 0% 0%

UT 1.0% 0% 0.4% 0.1% 0.1% 1.6%

WA 5.4% 0.1% 2.1% 0.1% 0.8% 8.6%

 

5 To replicate the data in Tables 2 and 3, enter the TSS website at http://vista.cira.colostate.edu/TSS/. Under the 

“Resources” tab on the left select: Haze Planning. On the map select the Jarbidge WA, then click on “Emissions and 

Source Apportionment”. Under the “Source Apportionment Results” select “Sulfate/SOx Tracer – All Source 

Regions”. Here you can switch between Nitrate/NOx and Sulfate/SOx "parameter choices. Narrow the selection to 

Nevada. The data can then be expanded below the figure under “Show Data.”

6

See supra n.1.
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Point Anthro 

Fire Mobile Natural Fires and Biogenics Area Total

WY 1.0% 0% 0% 0.3% 0.1% 1.5%

2018

Canada 2.4% 0% 0.2% 0% 2.0% 4.3%

Central US 1.2% 0% 0% 0% 0.2% 1.4%

Eastern US 1.2% 0% 0% 0% 0.2% 1.4%

Mexico 2.2% 0% 0% 0% 0.6% 2.8%

Outside Domain* n/a n/a n/a n/a n/a 43.8%

Pacific Offshore 1.0% 0% 0.2% 0% 5.5% 6.9%

WRAP 22.3% 0.3% 1.4% 10.5% 4.9% 39.4%

WRAP States

AZ 0.7% 0% 0% 0% 0% 0.7%

CA 2.5% 0% 0.4% 1.4% 0.7% 5.0%

CO 0.3% 0% 0% 0% 0% 0.3%

ID 3.6% 0.1% 0.3% 5.3% 1.0% 10.3%

MT 0.2% 0% 0% 0% 0.1% 0.3%

NV 3.5% 0% 0.1% 1.0% 0.8% 5.4%

NM 0.3% 0% 0% 0% 0.1% 0.4%

ND 0.1% 0% 0% 0% 0% 0.1%

OR 3.7% 0.1% 0.2% 2.2% 0.9% 7.2%

SD 0% 0% 0% 0% 0% 0%

UT 1.5% 0% 0.1% 0.1% 0.1% 1.8%

WA 4.5% 0% 0.2% 0.1% 1.0% 5.9%

WY 1.5% 0% 0% 0.3% 0.1% 2.0%

* n/a means not available

Source: http://vista.cira.colostate.edu/tss/, last viewed 11/07/2014

Table 3. Percentage Contribution to Modeled Worst Days Nitrate Concentration at the 

Jarbidge WA by Source Region and Category for 2002 (plan02c) and 2018 (base18b)

Point Anthro 

Fire Mobile Natural Fires and Biogenics Area Total

2002

Canada 0.3% 0% 1.0% 0% 0.3% 1.9%

Central US 0% 0% 0% 0% 0% 0%

Eastern US 0% 0% 0% 0% 0% 0%

Mexico 0% 0% 0% 0% 0% 0%

Outside Domain* n/a n/a n/a n/a n/a 20.8%

Pacific Offshore 0% 0% 0.3% 0% 0.6% 1.0%

WRAP 13.1% 1.5% 43.2% 8.2% 10.2% 76.3%
Nevada Regional Haze 5-Year Progress Report, November 2014

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Point Anthro 

Fire Mobile Natural Fires and Biogenics Area Total

WRAP States

AZ 0% 0% 0.1% 0% 0% 0.2%

CA 0.6% 0.1% 5.3% 0.5% 0.9% 7.3%

CO 0% 0% 0% 0% 0% 0%

ID 3.2% 0.3% 16.1% 3.9% 8.2% 31.7%

MT 0.1% 0% 0.3% 0.1% 0% 0.5%

NV 3.9% 0% 6.0% 1.6% 0.2% 11.6%

NM 0% 0% 0% 0% 0% 0.1%

ND 0% 0% 0% 0% 0% 0%

OR 0.8% 0.4% 3.0% 0.7% 0.2% 5.1%

SD 0% 0% 0% 0% 0% 0%

UT 4.0% 0% 7.8% 0.6% 0.3% 12.8%

WA 0.4% 0.6% 4.6% 0.8% 0.3% 6.7%

WY 0.1% 0% 0.1% 0% 0% 0.2%

2018

Canada 0.4% 0% 1.3% 0% 0.4% 2.1%

Central US 0% 0% 0% 0% 0% 0%

Eastern US 0% 0% 0% 0% 0% 0%

Mexico 0% 0% 0% 0% 0% 0%

Outside Domain* n/a n/a n/a n/a n/a 27.5%

Pacific Offshore 0% 0% 0% 0% 0.8% 1.3%

WRAP 18.9% 0.9% 23.2% 9.5% 16.5% 69.2%

WRAP States

AZ 0.1% 0% 0.1% 0% 0% 0.2%

CA 0.8% 0.1% 2.6% 0.6% 1.0% 5.1%

CO 0% 0% 0% 0% 0% 0%

ID 4.6% 0.2% 7.4% 4.5% 13.6% 30.3%

MT 0.1% 0% 0.2% 0.1% 0% 0.4%

NV 6.3% 0% 4.5% 1.9% 0.3% 13.1%

NM 0% 0% 0% 0% 0% 0.1%

ND 0% 0% 0% 0% 0% 0%

OR 1.2% 0.4% 1.9% 0.8% 0.3% 4.6%

SD 0% 0% 0% 0% 0% 0%

UT 5.0% 0% 4.3% 0.8% 0.6% 10.6%

WA 0.6% 0.3% 2.2% 0.9% 0.4% 4.4%

WY 0.1% 0% 0% 0% 0.1% 0.3%

* n/a means not available

Source: http://vista.cira.colostate.edu/tss/, last viewed 11/07/2014
Nevada Regional Haze 5-Year Progress Report, November 2014

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Failure to Include Emissions from Oil and Gas Development

The NGO comments contend that emissions resulting from oil and gas development were included 

in the 2002 inventory for Nevada, but Nevada did not report oil and gas emissions for 2008 and the 

assumption of zero emissions for 2008 is at odds with publicly reported information. In fact, 

Nevada did not report oil and gas emissions in either 2002 or 2008. Sections 5.3 and 5.4 of the 

Progress Report have been revised to make this clear. Like many other states, Nevada does not 

report oil and gas emissions directly to the NEI, relying on USEPA for this portion of the area 

source inventory in the NEI. 

The fact that Nevada did not report oil and gas emissions does not necessarily mean that there were 

no estimates. The NDEP notes that emissions resulting from oil and gas development were 

projected for Nevada’s PRP18a inventory (2009 RH SIP, Tables 3-7, 3-8, and 3-9) and, therefore, 

incorporated in Nevada’s reasonable progress goal. For the 2002 baseline inventory, the WRAP 

built on the 2002 NEI and developed a robust inventory that included oil and gas emissions 

estimates for Nevada. For the WestJump2008 inventory, the WRAP built on the 2008 NEI.

Although the WRAP developed robust oil and gas inventories for other areas within the WRAP

region, it did not conduct the same for Nevada. Progress Report, Sections 5.3 and 5.4. 

Nonetheless, such emissions must be put into perspective: in 2002 only 63 tons per year (tpy) of 

NOx and 129 tpy of VOC emissions were reported compared to a state-wide 2002 inventory of 

162,397 tpy of NOx and 897,102 tpy VOC and the state-wide 2008 inventory of 118,766 tpy NOx

and 351,142 tpy VOC. Progress Report, Table 5-7 and Table 5-10. 

The NDEP is aware of the limited oil and gas exploration efforts in northeastern Nevada to assess 

potential targets suitable for enhanced oil recovery methods such as fracking (see BLM 

Environmental Assessment for Huntington Valley Oil and Gas Exploration Project DOI-BLM-NVE020-2014-0003-EA). In Nevada, oil and gas development and production, as reflected by rig 

counts, is either declining or steady. Table 4 shows annual average rig counts by state from 2000 to 

2013 and demonstrates that Nevada is not experiencing any sort of oil and gas development boom 

as are some western states such as North Dakota or Utah. Figure 1 shows a steady decline in 

Nevada’s oil and gas production from 1990 to 2013. These data suggest that oil and gas 

development and production is not a significant activity in Nevada. The NDEP notes that oil and 

gas development and production in Nevada is currently subject to permitting requirements.

Table 4. Baker Hughes Rotary Rig Count Annual Averages by State9

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Colorado 18 32 28 39 54 74 89 107 114 50 58 72 65 63 

Montana 7 10 8 14 20 24 22 17 11 3 7 9 20 12 

Nevada 0 0 0 1 2 2 1 2 3 3 6 3 1 3 

New 

Mexico 68 68 42 65 67 83 94 78 78 44 62 79 84 77 

N Dakota 13 14 10 14 15 21 32 39 68 50 114 168 188 173

 

9 Modified from information downloaded from http://phx.corporate-ir.net/phoenix.zhtml?c=79687&p=irol-reportsother

on October 23, 2014.
Nevada Regional Haze 5-Year Progress Report, November 2014

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2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013

Utah 16 21 13 14 22 28 40 42 42 18 27 28 37 29 

Wyoming 41 55 40 54 74 78 99 74 74 40 40 48 47 48 

Figure 1. Oil Production in Nevada 1990 to 2013.10

The NDEP considered the applicable RHR requirements and available data in reaching the 

conclusion to retain the reasonable progress goal of 11.05 deciviews for the Jarbidge WA. The 

NDEP acknowledges the modeling error, but notes the update to the emission inventory 

demonstrates that state-wide reductions in Nevada point source emissions have reduced visibility 

impairment at the Jarbidge WA. Emissions from Nevada’s oil and gas development are not a 

significant emissions source and are not likely to have significant influence on visibility at the 

Jarbidge WA. Nevada stands by its conclusion to retain the reasonable progress goal of 11.05 

deciviews. 

The only change made to the Progress Report based on this NGO comment was to clarify the

discussion of oil and gas emissions reporting, as noted above. 

 

10 Figure downloaded from 

http://minerals.nv.gov/uploadedImages/mineralsnvgov/content/Programs/Oil_and_Gas/OilProdInNV1990-2013.jpg

October 23, 2014
Nevada Regional Haze 5-Year Progress Report, November 2014

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NGO Comment 2: NDEP Must Consider and Evaluate Reasonable Progress Measures for the 

Jarbidge Wilderness and Other Class I Areas Impacted by Nevada Sources.

This NGO comment hinges on the opening statement that the NDEP must find its implementation 

plan “is or may not be adequate to ensure reasonable progress due to emissions from sources within 

the State.” NGO comment letter, page 6. The NGOs suggest that NOx and SO2 emissions from 

Nevada point sources have significant contributions to visibility impairment at the Jarbidge WA and 

that Nevada should consider emission control requirements for the North Valmy Generating Station 

as well as potential visibility impacts from oil and gas development in Nevada. 

NDEP Response: The NDEP maintains Nevada’s implementation plan is adequate to ensure 

reasonable progress due to emissions from sources within the State. Nevada’s initial regional haze 

progress report focuses on controllable anthropogenic emission sources. The Progress Report 

documents progress for the first five years of a 60-year planning horizon and not all controls 

identified in the State’s 2009 RH SIP have been implemented because they are not required to do so 

until 2015 (Progress Report, Section 2.5.2). Furthermore, the majority of visibility impairing 

emission sources at the Jarbidge WA are out of Nevada’s jurisdiction (Progress Report, Section 4.4 

and 2009 RH SIP, Section 4.3). Long-term monitored light extinction trends are either better than 

or comparable to the speciated glide slopes for nitrate and sulfate (Progress Report, Section 4.6).

Finally, the 5-year annual average nitrate extinction on the worst days is below the nitrate glide 

slope, and there is no degradation of visibility resulting from nitrate or sulfate on the best days. 

Nevada Point Source Contributions to Visibility Impairment

Emissions from outside of Nevada contribute more to visibility impairment at Jarbidge WA than 

Nevada point sources. The sulfate modeling results for Nevada’s point sources are presented 

graphically in Figure 2. Coupled with the information presented in Table 2, the data show that for 

2002, Canada, Eastern US, Pacific Offshore, and Outside Domain each contribute more to modeled

worst days sulfate concentrations at the Jarbidge WA than do emissions from Nevada point sources. 

Similarly, point sources in Oregon and Washington contribute more than Nevada point sources, 

while point sources in Idaho contribute nearly as much. When total state-wide emissions are 

considered, California, Idaho, Oregon and Washington all contribute more to modeled sulfate 

concentrations at Jarbidge than do Nevada’s state-wide emissions. 
Nevada Regional Haze 5-Year Progress Report, November 2014

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Figure 2. Contributions to Modeled Sulfate Concentrations at the Jarbidge WA on the Worst 

Days

For 2018, a similar situation exists. Emissions from Canada, Pacific Offshore and Outside Domain 

each contribute more to the modeled worst days sulfate concentration than emissions from Nevada 

point sources, as do point sources in Idaho, Oregon, and Washington. When state-wide emissions 

are considered, Idaho, Oregon, and Washington each contribute more than Nevada’s state-wide 

emissions with California contributing nearly as much as Nevada. The source apportionment 

modeling supports Nevada’s conclusion that the IMPROVE monitor for the Jarbidge WA is “likely 

more strongly impacted by emissions originated from with the Snake River Basin than those 

emitted from within the Great Basin” (Progress Report, page 9-3) and emissions from sources 

within the State are not impeding reasonable progress at the Jarbidge WA. As noted in the NDEP’s 

response to the NGO comment 1, emissions from the North Valmy Generating Station are clearly 

not a significant source of visibility impairment at the Jarbidge WA.

Emissions from Outside Domain and Pacific Offshore contribute approximately 50 percent of 

modeled sulfate at Jarbidge with all sources outside of the WRAP contributing approximately 60 

percent of modeled concentration. WRAP states, excluding Nevada, contribute approximately 35 

percent. The source apportionment modeling demonstrates the majority of emission sources 
Nevada Regional Haze 5-Year Progress Report, November 2014

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contributing to sulfate visibility impairment at Jarbidge are outside the jurisdiction of Nevada or its 

WRAP co-regulators. As noted in Section 4.6 of the Progress Report, monitored sulfate extinction 

for the worst days at the Jarbidge WA is trending downward, both on an annual and five-year 

average basis. 

The NDEP is unsure why the NGOs commented on nitrate extinction at Jarbidge WA and the need 

for further emission controls when, as shown by Figure 3, five-year rolling averages of worst days

nitrate extinction for the last 4 years (2006-2010, 2007-2011, 2008-2012, and 2009-2013) are below 

the nitrate glideslope. Figure 4 graphically shows the contributions to modeled worst days nitrate 

concentrations at Jarbidge WA. Regarding the NGO comments about Nevada’s contributions to the 

best days, there is no degradation in visibility resulting from sulfate or nitrate for the least impaired 

(best) days at the Jarbidge WA over the current planning period (Figure 5).

Figure 3. Baseline and Five-Year Rolling Averages of Worst Days Sulfate and Nitrate Light 

Extinction at the Jarbidge WA. 
Nevada Regional Haze 5-Year Progress Report, November 2014

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Figure 4. Contributions to Modeled Nitrate Concentrations at the Jarbidge WA on the Worst 

Days

Figure 5. Baseline and Five-Year Rolling Averages of Best Days Sulfate and Nitrate Light 

Extinction at the Jarbidge WA.
Nevada Regional Haze 5-Year Progress Report, November 2014

D-25

Consideration of Emissions from Oil and Gas Development 

The NGO comments state Nevada must consider emissions from oil and gas development and the 

potential visibility impact, using information from a couple of newspaper articles to suggest oil 

development could be increasing, as it has in recent years in Utah. However, as discussed under the 

first NGO comment, the data in Table 4 shows that oil and gas development in Nevada has a 

considerably slower pace than other oil and gas areas in the western US, and the data in 

Figure 1 show that Nevada’s oil production has been in a state of steady decline since the 1990s. 

The NDEP continues to monitor the pace of oil and gas development in Nevada and will evaluate 

emissions sources resulting from increased activity as warranted. However, given the very limited 

oil and gas activity to date, implementation of additional emission controls on this sector at this time

would be premature. 

Nevada’s 2009 RH SIP focused on impairment resulting from Nevada’s anthropogenic emissions of 

SO2 and NOx, the precursors of sulfate and nitrate, respectively. Source apportionment modeling 

demonstrates Nevada emissions do not make a large contribution to overall visibility impairment at 

Jarbidge WA. The bulk of impairment results from emissions beyond Nevada’s jurisdiction. 

Monitoring data show that the Jarbidge WA is achieving levels of improvement in visibility

impairment necessary to achieve natural background conditions by 2064 for impairment resulting 

from nitrate and sulfate extinction in this first 5-year planning period. To the extent that SO2 and 

NOx emissions from point sources in Nevada contribute to visibility impairment at Jarbidge WA, 

Nevada’s progress report documents significant SO2 and NOx emissions reductions from sources 

within the State (see Table 5-1 of the Progress Report). 

In summary, the NDEP has fully justified Nevada’s negative declaration (i.e., emissions from 

sources within the State are not preventing Nevada from achieving its reasonable progress goal) and 

deems its 2009 RH SIP adequate to ensure reasonable progress towards the national visibility goal 

for sulfate and nitrate resulting from anthropogenic emissions. 

No changes were made to the Progress Report as a result of this NGO comment.

NGO Comment 3: NDEP Must Revise Its Assessment of Contribution to Visibility Impairment at 

Class I Areas Impacted by its Sources to Be Based on the WRAP’s Revised Modeling with its 2018 

PRPb Emissions Projections.

This NGO comment contends that Nevada’s assessment of its sources’ impacts on Class I areas 

outside Nevada is based on erroneous source appointment modeling, which in turn is based on an 

outdated PRP18a emissions projection. The NGO comments go on to suggest that Nevada’s 

conclusions regarding emissions reductions should be informed not by the 2008 inventory data, but 

by the 2011 NEI and more recent CAMD data. Further, the NGO comments suggest that emissions 

reductions in Nevada may not account for Nevada’s portion of impairment in some Class I areas,

and Nevada must revise its analysis of Nevada’s impacts on out-of-state Class I areas.
Nevada Regional Haze 5-Year Progress Report, November 2014

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NDEP Response: A comprehensive review of the Nevada regional haze SIP and Progress Report 

and the WRAP’s modeling efforts that supported Nevada’s regional haze submissions belie this 

comment. 

Modeling Assessment

Table 4-3 and Table 4-4 of the 2009 RH SIP present Nevada’s contributions to light extinction at 

Class I areas in the five states adjacent to Nevada based on the WRAP’s source apportionment 

modeling. Sections 1.3.2.2, 1.3.3.2 and 4.3 of the 2009 RH SIP describe the modeling framework 

and emissions scenarios utilized for this modeling effort by the WRAP, which relied on the Plan02c 

and Base18b emission inventories. To the NDEP’s knowledge, there has been no indication by any 

party that this source apportionment modeling is erroneous or not fully acceptable. This is the most 

comprehensive and current regional haze source apportionment data available for the WRAP 

region. 

Table 7-6 of the 2009 RH SIP provides a summary of visibility impairment at nearby Class I areas 

and Nevada’s emissions reductions, which the NGO comments suggest is based on erroneous 

modeling. However, as noted in Section 7.9.3.2 of the 2009 RH SIP, the information in the table is 

based on monitored baseline light extinction (2000-2004), the uniform rate of progress for 2018 

(i.e., the glideslope value for 2018), and Nevada’s contributions to sulfate and nitrate based on the 

WRAP’s source apportionment modeling. Nevada’s emission reduction share is calculated by 

multiplying the extinction reduction needed at any given Class I area by the 2018 pollutant 

contribution by Nevada. Nevada’s share is independent of the WRAP’s corrected visibility 

modeling. 

Emissions Assessment

The NGOs suggest that the analysis should be informed by 2011 NEI data and recent CAMD data, 

but later acknowledge that the NDEP did present and evaluate both 2011 NEI and CAMD data 

through 2013. Tables 5-5 and 5-7 of the Progress Report compare 2002 baseline emissions as 

represented by the Plan02d inventory and 2008 progress period emissions as represented by 

WestJump2008. However, Tables 5-6 and 5-8 present 2011 NEI data from the major anthropogenic 

source categories (point, on-road mobile and off-road mobile) and show further reductions in SO2

and NOx emissions from 2008 to 2011. In addition, Table 3-2 and Figure 3-1 of the report present 

CAMD data through 2013 for annual EGU emissions. Figures 3-2 through 3-7 present SO2 and 

NOx CAMD data for specific EGUs through 2013. The 2011 NEI and recent CAMD emissions

data have been evaluated by the NDEP and further support Nevada’s emission reduction 

conclusions, contrary to statements in the NGO comments. 

Out of State Impact Assessment

The NGO comments suggest that the significant emissions reductions in Nevada may not account 

for Nevada’s portion of impairment at out-of-state Class I areas and use the Sawtooth Wilderness 

Area as an example. Baseline nitrate extinction at the Sawtooth Wilderness Area is better than the 

natural conditions estimate (0.63 Mm-1for baseline and 0.65 Mm-1for natural conditions), so the 

extinction reduction needed and Nevada’s emissions reduction share are both negative in Table 7-6 

of the 2009 RH SIP. The NDEP notes that Table 7-6 shows that Nevada’s emission reduction share 

is 0.5 percent for sulfate while the difference between the Base02d and PRP18a inventories is 33.0 
Nevada Regional Haze 5-Year Progress Report, November 2014

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percent for SO2 and 16.6 percent for NOx. Table 5-5 of the Progress Report shows state-wide SO2 

emission reductions of 75 percent between 2002 and 2008 with additional reductions shown in 

Table 5-6 between 2008 and 2011. Table 5-7 shows state-wide NOx emissions reductions of 26 

percent between 2002 and 2008, which are slightly offset by the emissions growth shown in Table 

5-8 between 2008 and 2011. The percentage reductions in Nevada’s NOx and SO2 emissions are 

much greater than Nevada’s emissions reduction share presented in Table 7-6 of the 2009 RH SIP.

Figure 6 below shows the annual worst days monitoring data for the Sawtooth Wilderness Area 

with 5-year rolling averages, natural conditions, and the glideslopes for each species. This figure 

demonstrates that visibility impairment due to sulfate and nitrate are not preventing reasonable 

progress at the Sawtooth Wilderness Area, even though this site is not achieving the uniform rate of 

progress for sulfate and nitrate as shown by Figure 7. Figure 6 shows particulate organic matter

(resulting from fire emissions) is the principle driver of visibility impairment at this Class I area. 

Figure 6. Baseline and Five-Year Rolling Averages of Worst Days Visibility Conditions at the 

Sawtooth Wilderness Area.
Nevada Regional Haze 5-Year Progress Report, November 2014

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Figure 7. Baseline and Five-Year Rolling Averages of Worst Days Sulfate and Nitrate 

Visibility Impacts at the Sawtooth Wilderness Area.

Figure 8 and Figure 9 show the regional as well as the WRAP source region and source type 

contributions to modeled sulfate and nitrate respectively at the Sawtooth Wilderness Area. These 

Figures show how little Nevada emissions sources contribute to visibility impairment at the 

Sawtooth Wilderness Area.
Nevada Regional Haze 5-Year Progress Report, November 2014

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Figure 8. Contributions to Modeled Sulfate Concentrations at the Sawtooth Wilderness Area 

on the Worst Days
Nevada Regional Haze 5-Year Progress Report, November 2014

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Figure 9. Contributions to Modeled Nitrate Concentrations at the Sawtooth Wilderness Area 

on the Worst Days

In summary, WRAP visibility modeling based on the PRP18b emission inventory has no bearing on 

the NDEP’s assessment of Nevada’s contribution to visibility impairment at Class I areas impacted 

by Nevada emission sources. The NDEP’s emissions reductions conclusions are based on the most 

recent commonly available emissions data as represented by the WestJump2008, 2011 NEI, and 

CAMD data through 2013, as requested by the NGO comments. Nevada’s emission reductions far 

exceed Nevada’s contributions to visibility impairment at Class I areas impacted by Nevada 

sources. Emissions from Nevada are not impeding reasonable progress at the Sawtooth Wilderness 

Area or other out-of-state Class I areas. 

The NDEP has not revised its determination regarding the adequacy of its plan with respect to 

Nevada’s impacts on out-of-state Class I areas based on this comment, and no changes were made 

to the Progress Report. 

NGO Comment 4: NDEP Must Revise Its Proposed Progress Report to Meet §51.308(g)(2) and 

§51.308(g)(4). 
Nevada Regional Haze 5-Year Progress Report, November 2014

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The NGOs comment that the Progress Report fails to detail the specific reductions achieved through 

the implementation of the enforceable measures required by the SIP and request that Nevada 

include such estimates and revise its assessment of the adequacy of its SIP on this basis. They 

question whether the significant decrease in SO2 and NOx emissions from EGUs is due to 

enforceable measures and point to the increase in 2013 SO2 and NOx emissions at Reid Gardner and 

NOx emissions at Fort Churchill (Progress Report Figures 3-2, 3-3 and 3-7) as support. They 

further comment that the use of 2011 NEI data in Chapter Five is not a sufficient basis for 

evaluating the most recent emissions trends in Nevada. They request the NDEP discuss the EGU 

emissions from USEPA’s CAMD database in Chapter Five as well as Chapter Three of the report 

and also use in-state inventories and Title V reporting from 2008 to at least 2012 to discuss 

emission trends. Finally, the NGOs suggest that to the extent the NDEP is relying on measures not 

included in the 2009 RH SIP to meet its reasonable progress goal, using SB 123 as an example, it 

should adopt those requirements as enforceable measures in its regional haze SIP.

NDEP Response: The 2009 RH SIP requires the implementation of BART as a major enforceable 

control measure for the first planning period, 2008 - 2018. All applicable BART requirements have 

been adopted and incorporated into the Nevada Administrative Code, approved by USEPA into 

Nevada’s applicable SIP and are enforceable by the State and USEPA. Chapters Two and Three of

the Progress Report discuss BART implementation. Table 2-3 of the report details the status of 

BART implementation in Nevada, showing that all BART control measures will be installed and 

operating by January 1, 2015 with the exception of NOx controls at Reid Gardner, which has a 

compliance date of June 30, 2016. Thus, since the controls have not been fully implemented at this 

time, specific reductions are not yet fully realized. Chapter Five of the 2009 RH SIP, specifically 

Tables 5-4, 5-5, 5-6 and associated text, provide expected emissions reductions following full 

implementation of BART controls. Section 3.4.2 of the Progress Report notes that NV Energy 

plans to shut down Units 1 through 4 at Reid Gardner and specifies associated emissions reductions.

Chapter Three of the Progress Report discusses the most recent CAMD EGU emissions data 

through 2013. The fact that there is a small increase in EGU emissions from 2012 to 2013 is 

diminished by the overall steady decline in EGU emissions, with the exception of increased 

emissions at Tracy and Fort Churchill during the Energy Crisis of 2000-2001. Indeed, electrical 

generation demand varies across fleet facilities and could account for the increased emissions in 

2013. The NDEP finds the NGOs’ speculation that the miniscule increase in 2013 may indicate that 

the control measures included in the 2009 RH SIP may be inadequate is unsubstantiated. 

Chapter Five of the Progress Report includes 2011 NEI Nevada point and mobile source emissions 

in Tables 5-6, 5-8, and 5-11 for SO2, NOx, and VOC, respectively. 2012 NEI data was not used 

because it only includes the larger point source data and does not include mobile source data. Thus, 

it would not provide a complete picture of emissions in Nevada. In addition, 2012 in-state 

emissions data was neither quality checked nor available at the time of preparation of the Progress 

Report. Thus, the WestJump2008 and 2011 NEI inventories provide the most recent data available 

to the NDEP at the time of the Progress Report. The next SIP submission is expected to include 

new modeling results using the most current available emissions data for use in assessing the 

adequacy of Nevada’s SIP.
Nevada Regional Haze 5-Year Progress Report, November 2014

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Lastly, the NGOs suggest Nevada adopt SB123 as an enforceable measure of its regional haze SIP. 

The NDEP as part of its reasonable progress update reviewed all available sources of emission 

reductions and planned control measures. The NDEP maintains that it is appropriate to include an 

assessment of the impact of all emissions reduction measures occurring since the 2009 RH SIP was 

adopted. The NDEP did not, however, rely on the emission reductions in SB123 in making its 

determination that Nevada is making adequate progress overall in improving visibility. It is 

unnecessary to incorporate SB123 in to the Nevada SIP. 

No revisions have been made to the Progress Report as a result of this comment.
Nevada Regional Haze 5-Year Progress Report, November 2014

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D.2.2 Sierra Club-National Parks Conservation Association Comment Letter
Nevada Regional Haze 5-Year Progress Report, November 2014

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Nevada Regional Haze 5-Year Progress Report, November 2014

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The NGO comment letter was accompanied by three exhibits. Because of the length of the exhibits, 

the NDEP has not included them in this appendix, but is providing links to these documents on the 

internet.

1. Correction of WRAP region Plan02d CMAQ visibility modeling results on TSS for Regional 

Haze Planning. April 27, 2011. The final version of the document is available at 

http://vista.cira.colostate.edu/TSS/Planning/InformationExchange.aspx (See Revised Plan 02d 

CMAQ Modeling Results (June 2011), last viewed 11/10/2014)

2. WRAP PRP18b Emissions Inventory – Revised Point and Area Source Projections. April 29, 

2009. Technical Memorandum from Marty Wolf and Paula Fields, Eastern Research Group, to 

the WRAP staff. http://www.wrapair.org/forums/ssjf/documents/Pivot_Tables/2009-

04x_Final_PRP18b_memo_4-29.pdf (last viewed 11/10/2014)

3. Summary of WRAP RMC BART Modeling for Nevada. Draft#7. April 24, 2007. 

http://www.ndep.nv.gov/baqp/planmodeling/docs/NV_Bart_summary_v7_Apr24_2007.doc

These exhibits are also available on request from the NDEP Bureau of Air Quality Planning at 901 

South Stewart Street, Carson City, Nevada 89701 or 775-687-9349.