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APPENDIX C

Federal Land Management Agency 

Comments and Nevada’s Responses
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Appendix C

Federal Land Management Agency Comments

and Nevada’s Responses

September 15, 2014

On June 16, 2014, pursuant to 40 C.F.R. 51.308(i)(2), the 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:

 The United States Department of the Interior National Parks Service (NPS) on August 15, 

2014.

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

Nevada replied to the NPS on September 12, 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. Copies of the NPS and 

USFS comment letters follow the set of comments and responses below.

NPS Comments

CHAPTER FOUR

COMMENT 1: Table 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 section that the tables compare

fire inventories for one year, 2008, to the five-year average for 2000-2004. This point is made on

p. 5-16 under discussion of volatile organic carbon, but it is relevant to every pollutant and every

inventory sector.

RESPONSE: Text was added to Section 5.4, p 5-8, noting that fire emissions from only a single 

year (2008) were used for the 2008 DEASCO3 study, which was used as the data source for fire 

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

somewhat misleading comparison with the baseline period, which used a 5-year average from 

2000-2004.
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COMMENT 3: Section 5.5.8 Coarse Mass. Please make the connection that coarse mass has

the second greatest contribution to visibility impairment on the 20% worst visibility days at

Jarbidge WA. Anthropogenic coarse mass is projected to increase in the 2008 inventory;

possibly due to increased activity and/or changes in inventory methods. These data together

suggest that NDEP should consider control options for anthropogenic sources of coarse mass

the 2018 revisions to Nevada's regional haze plan.

RESPONSE: The point that coarse mass is the second greatest contributor to visibility 

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

Assessment of Visibility 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 the 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, as 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 consider 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 its strategy, as appropriate.

CHAPTER SIX

COMMENT 4: Chapter 6: The WRAP 2002 and 2018 modeling included particulate source

apportionment analyses that demonstrated Nevada's contribution to visibility impairment at Class I 

areas in neighboring states and other states' contributions at Jarbidge WA. Summarizing these

data would assist in demonstrating that Nevada is reducing its contribution to neighboring states

and would provide context for the discussions of controls in Idaho and Oregon.

RESPONSE: The NDEP added a new summary of other states’ contributions to visibility 

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

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

contributions 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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-Year Progress Report, November 2014

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U.S. Forest Service Comment Letter