### Nevada Regional Haze 5

- Year Progress Report, November 2014

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# APPENDIX C

Federal Land Management Agency

Comments and Nevada’s Responses

### Nevada Regional Haze 5

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### Nevada Regional Haze 5

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## Appendix C

Federal Land Management Agency Comments

and Nevada’s Response s

September 15 , 2014

On June 16, 2014

, p ursuant to 40 C

. F

. R

. 51.308(i)(2), t he Nevada Division of Environmental

Protection (NDEP) provided the Federal Land Managers with a draft Regional Haze 5

- Year

Progress Report (Report ) for a 60

- day review. The NDEP received comment letters from:

 T he Unit ed States Department of the Interior National Parks Service (NPS) on August 15,

2014.

 T he United States Department of Agriculture Forest Service (USFS) on August 29, 2014

Nevada replied to the NPS on September 1 2

, 2014 with the responses presented below

. The

responses are organized by Report chapter ; if a chapter is not listed below, there were no

comments

. The USFS letter had no comments that required a response. C op ies of t he NPS and

USFS comment letter s follow the set of comments and responses below

.

NPS Comments

CHAPTER FOUR

COMMENT 1 : Tab l e 4

- 2 and 4

- 3 do not show the same deciview values for 2007

- 2011 and 2008

-

2012. Please check.



### RESPONSE: The value for the 2008

- 2012 worst days has been corrected from the 2012 annual

average to the 2008

- 2012 5

- year average in Table 4

- 3. The 2007

- 2011 values are correct in

Table 4

- 3. The values in Table 4

- 2 were confirmed as correct.

CHAPTER FIVE

COMMENT 2 : Section 

### 5.4, p. 

### 5

- 8. Please add in the introductory se c tion that the t a b l e s compare

fire inventorie s for one year, 2008, to t h e five

- year average for 2000

- 2004. This point i s made on

p. 

### 5

- 16 under di s c u s s ion of volatile organic carbon

, but it i s relevant to e v er y pollutant and every

inventory se c tor.



### RESPONSE: Text was added to Section 5.4, p 5

- 8, not ing that fire emissions from only a single

year (2008) were used for the 2008 DEASCO 3 

### study , which was used as the data source for fire

emissions in developing the WestJump2008 inventory. It is noted that t his results in a

somewhat misleading compar ison w ith the baseline period , which used a 5

- year average from

2000

- 2004.

### Nevada Regional Haze 5

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COMMENT 3 : Section 

### 5. 5 .8 Coarse M

a s s

. Please make the connection that coarse m a ss has

the second g r e a t e s t contribution to visibility impairment on t h e 20% worst visibility da y s at

Jarbi d g e W A. Anthropogenic coarse m a ss i s projected to incre a se in t h e 2008 in v e n tory;

p o s s ibly d u e to inc r

eas e d activity and/or changes in inventory m e tho d s. These data t o ge t her

s u g ge s t that NDEP should c o n s i d e r control options for anthropogenic s o ur c es of c o a rse mass

the 2018 revisions to N

ev a da 's r e g ional h a ze pla n

.



### RESPONSE: The point that coarse mass i s the second greatest contributor to visibility

impairment on the 20% worst visibility days at Jarbidge WA is made in Chapter Four,

Assessment of Visibilit y Conditions, Sections 4.1 and 4.4 , as well as Section 1.3 of the

introductory chapter. Chapter Five is rather a straightforward analysis tracking the

changes in emissions of visibility impairing pollutants over the last five years and does not

discuss th e relative impacts of the pollutants at Jarbidge . While it is true that

anthropogenic coarse mass emissions are projected to increase in the 2008 inventory, these

increases may in large part be due to changes in inventory development methodologies

rather than actual increases, a s noted in Chapter Five. Interestingly, examination of county

level data in the WestJump2008 inventory for coarse mass indicates that over 60 % of

these emissions are in Clark County

.

In the 2018 SIP revision , the NDEP will cons ider all appropriate control scenarios for

anthropogenic sources of coarse mass emissions. A sentence has been added to the

Executive Summary indicating that the NDEP will re

- evaluate sources of visibility

impairment in the 2018 SIP revision and revise it s strategy, as appropriate.

CHAPTER SIX

COMMENT 4 : Chapter 6: The WRAP 2002 and 2018 modeling included particulate s o u r ce

apportionment analyses that demo n s trated Nevada ' s contribution to visibility im p a irment at Class I

areas in neighboring states and o ther s tat e s' c o ntributio n s at Jarbidge WA

. Summarizing th e se

data woul d assist in demo n s trating that Nevada i s reducing i t s contribution to neighboring states

and would provide context for t h e dis c u s s io n s of c o ntro l s in Idaho and Oregon.



### RESPONSE: The ND EP added a new summary of other states’ contributions to visibility

impairment measured at JARB1 in S ection 6.3 to provide additional context for the discussion

of BART implementation in Idaho and Oregon. The text describes the sulfate and nitrate

contrib utions to visibility impairment at JARB1 based on the particulate source apportionment

modeling conducted by the WRAP for the original RH SIPs. The NDEP also added a new

section to Chapter 6 providing a discussion of Nevada’s contributions to other Class I areas

based on the source apportionment modeling results to assist with the demonstration that

Nevada is reducing its contributions to neighboring states

, including a summary of emissions

reductions from Nevada sources between 2002 and 2008.

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## National Park Service Comment Letter

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## U.S. Forest Service Comment Letter