STAT E O F N EVA DA 

Department of Conservation & Natural Resources 

N E V A D A ■ DIVISION oF 

ENVIRONMENTAL PROTECTION DIVISION OF ENVIRONMENTAL PROTECTION 

protecting the future for generations 

November 18, 2009 

Laura Yoshii 

Acting Regional Administrator 

OAR-1, USEPA Region IX 

75 Hawthorne Street 

Jim Gibbons, Governor 

Allen Biaggi, Director 

Leo M. Drozdoff P.E., Administrator 

San Francisco, CA 94105 

RE: SUBMITTAL OF NEVADA'S REGIONAL HAZE STATE IMPLEMENTATION PLAN 

Dear Ms. Yoshii: 

On behalf of Governor Gibbons, as his appointed designee, this letter transmits to you two hard 

copies of the Nevada Regional Haze State Implementation Plan (RH SIP or SIP) and one 

compact disc. Additionally, the RH SIP may be viewed on the Nevada Division of 

Environmental Protection's (NDEP) website at httP://ndep.nv. ogv/baqp/planmodeling/rhaze.html . 

The SIP is submitted pursuant to 40 CFR 51 section 308, "Regional haze program requirements." 

NDEP requests approval of the RH SIP into the Nevada State implementation plan. 

The RH SIP satisfies the criteria of 40 CFR § 51.308. The SIP was properly noticed and 

presented at the Public Hearing on May 20, 2009, conducted by NDEP. Under the authority in 

Nevada Revised Statutes 44513.205 and Nevada Administrative Code 44513.053, the 

Administrator of NDEP has the authority to adopt and submit state implementation plans to the 

U.S. Environmental Protection Agency (USEPA) (see Appendix D, section 1.4). 

Evidence of compliance with the consultation and public review processes required for the RH 

SIP is presented in Appendix A, Nevada BART Regulation, Appendix C, Federal Land 

Management Agency Comments and Nevada's Response and Appendix D, Evidence of Public 

Participation; Public Comments and Nevada's Responses. Copies of all formal comments on the 

SIP received by NDEP and NDEP's response to those comments appear in Appendices C and D. 

We would like to point out that the SIP is based on data and analyses that existed as of January 5, 

2009, when we provided the federal land managers with their consultation review draft of the 

SIP, with one exception. The exception is that we used more recent data in support of lowering 

the S02 best available retrofit technology (BART) emission limits at NV Energy's Reid Gardner 

Generating Station. The re-evaluation of the BART requirements at Reid Gardner was done in 

response to public comments received during the public review period. (See NDEP's response 

to USEPA comment 2 in Appendix D for details.) This change to the BART limits requires a 

regulatory amendment, which NDEP has drafted and forwarded to the State Environmental 

Commission for presentation at their December 9, 2009 Hearing. A copy of the amendment is 

included in Appendix A. NDEP will submit the adopted regulation to USEPA when it becomes 

effective. 

oakatit 

901 S. Stewart Street, Suite 4001 . Carson City, Nevada 89701 . p: 775.687.4670 . f: 775.687.5856 . www.ndep.nv.gov 

printed on recycled paper 
Laura Yoshii, Acting Regional Administrator Page 2 

November 18, 2009 

NDEP is aware that an update of the 2018 modeling scenarios for regional haze planning in the 

Western Regional Air Partnership (WRAP) region was completed in July 2009, after the cut off 

date for incorporating new information into Nevada's SIP. NDEP has reviewed this most 

recent WRAP modeling effort and notes that it supports the conclusions and recommendations 

presented in the SIP. 

In conjunction with Nevada's RH SIP submittal, NDEP is providing a summary of comments 

received during the public comment period (attached). In the summary, NDEP has included 

statements and/or discussion of general or recurring commenter concerns from Nevada's 

viewpoint, including: 

• Nevada's perspective; 

• No increase in S02 emissions from Reid Gardner; 

• Nevada's progress toward the national visibility goal; 

• The relationship between BART and the regional haze rule; 

• Philosophical differences; 

• FLM comments regarding costs and control efficiencies; 

• FLM emphasis on visibility improvement in BART process; and 

• FLM emphasis on $/dv measure of cost effectiveness. 

The enclosed RH SIP presents Nevada's reasonable progress goals, calculations of baseline and 

natural visibility conditions, Nevada's long-term strategy for regional haze, monitoring strategy 

and other implementation plan requirements and BART requirements for addressing regional 

haze visibility impairment in accordance with the requirements of 40 CFR § 51.308. NDEP 

urges USEPA to provide timely review and approval of Nevada's RH SIP taking into account the 

signif cant progress toward meeting the national visibility goals that Nevada's SIP demonstrates. 

If you should have any questions about this submittal or require additional clarification, you may 

contact Greg Remer, Chief, Bureau of Air Quality Planning at (775) 687-9359. 

Si rely, 

~ 

c 

Leo M. Drozd 

Administrator 

Enclosures 

cc: Robin Reedy, Chief of Staff, Office of the Governor 

Allen Biaggi, Director, DCNR 

Colleen Cripps, Deputy Administrator, NDEP 

Greg Remer, Chief, Bureau of Air Quality Planning, NDEP 

Michael Elges, Chief, Bureau of Air Pollution Control, NDEP 

Tom Webb, Air Division, EPA Region IX AIR-2 

Eleanor Kaplan, Air Division, EPA Region IX AIR-2 

Dennis Ransel, Chief, Planning Manager, Clark County DAQEM 

Andrew Goodrich, Director, Air Quality Management Division, Washoe County DHD 

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