NEVADA REGIONAL HAZE 

5-YEAR PROGRESS REPORT

To Satisfy

Sections 308(g), (h) and (i)

of the Regional Haze Rule

(40 CFR § 51.308)

State of Nevada

Division of Environmental Protection

901 South Stewart Street, Suite 4001

Carson City, Nevada 89701

NOVEMBER 18, 2014
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NOTE TO READERS

Nevada’s Regional Haze 5-Year Progress Report was developed for submittal to the U.S. 

Environmental Protection Agency under Section 308 of the Regional Haze Rule (40 CFR § 

51.308) as a revision to the applicable Nevada state implementation plan (SIP). 40 CFR § 

51.308(g) requires periodic reports every five years after the initial regional haze SIP was 

submitted. This report satisfies the first 5-year progress report requirement. The report is based 

on data that existed as of March 1, 2014. 

Nevada’s Regional Haze 5-Year Progress Report and related documents can be found on the 

following website: http://ndep.nv.gov/baqp/planmodeling/rhaze.html. Western Regional Air 

Partnership (WRAP) reports and documents can be found on the following websites: 

http://www.wrapair2.org/ or at the WRAP TSS website: http://vista.cira.colostate.edu/tss/.

Nevada has chosen to link to websites on the internet for many references cited in this report. 

We have backed up these links by putting electronic copies of reference documents on the 

Nevada Division of Environmental Protection’s (NDEP) server. If any of the links in this 

document do not work for you, you may contact the NDEP Bureau of Air Quality Planning at 

901 South Stewart Street, Suite 4001, Carson City, Nevada 89701 or by telephone at 775-687-

9349 for assistance.

ACKNOWLEDGEMENTS 

This document was written by the following staff of the NDEP, Bureau of Air Quality Planning:

Principal Authors

Frank Forsgren

Brenda Harpring

Adele Malone, Supervisor

Contributing Staff

Patricia Bobo

Reviewers

Jasmine Mehta, Chief, Bureau Air Quality Planning

Rob Bamford, Chief, Bureau Air Pollution Control

The supporting technical information in this plan was assembled with the assistance of the 

WRAP and their consultants.
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Nevada Regional Haze 5-Year Progress Report, November 2014

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EXECUTIVE SUMMARY

In 1977, Congress amended the Clean Air Act (CAA) to establish 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 Nevada, one area was designated: the Jarbidge Wilderness Area 

(Jarbidge WA) in the northeast corner of the state.

On July 1, 1999, the U.S. Environmental Protection Agency (USEPA) adopted the Regional 

Haze Rule (RHR). The RHR 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 Nevada Regional Haze State Implementation Plan (2009 RH 

SIP), which addressed the initial planning period in the federal rule (2008 to 2018), was 

submitted to the USEPA on November 18, 2009. A comprehensive SIP revision is due on July 

1, 2018 and every ten years thereafter.

USEPA’s regional haze regulations also include provisions for 5-year progress reports. These 

progress reports must provide an assessment of whether the approved SIP is being implemented 

appropriately and whether reasonable visibility progress is being achieved consistent with the 

projected visibility improvement in the SIP. The requirements for these reports are found in Title 

40 of the Code of Federal Regulations (CFR) Part 51 Sections 308 (g) and (h). Requirements for 

state and federal land manager (FLM) coordination are found in Part 51 Section 308 (i).

As discussed in the introductory chapter of this report, in Nevada nearly three-quarters of the 

visibility-impairing pollutants come from natural sources. Emission inventory data for the 

baseline period show that sulfur dioxide, oxides of nitrogen and coarse mass (dust) are the 

predominant anthropogenic pollutants in Nevada. For sulfur dioxide, 97 percent of the emissions 

statewide came from anthropogenic sources; for oxides of nitrogen, 86 percent were 

anthropogenic; and for coarse mass, 38 percent were anthropogenic. Nevada’s long-term strategy 

for the first planning period focused on sulfur dioxide and nitrogen dioxide because they were 

the predominant anthropogenic pollutants and because of the controllable nature of these 

emissions. This report, therefore, focuses on the status of sulfur dioxide and nitrogen dioxide 

control measures and progress toward Nevada’s 2018 visibility improvement goal.

Nevada continues to reduce emissions of the key visibility impairing pollutants. Point source 

emissions of sulfur dioxide alone decreased by 78 percent from the baseline inventory to the 
Nevada Regional Haze 5-Year Progress Report, November 2014

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2008 progress period inventory. Point source emissions of oxides of nitrogen decreased by over 

50 percent between the baseline and progress period inventories. 

Although natural wildfire smoke and windblown dust persist as the strongest drivers of reduced 

visibility on worst days at the Jarbidge WA, Nevada’s strategies for reducing sulfur dioxide and 

oxides of nitrogen have lowered sulfate and nitrate particle concentrations at the Jarbidge WA. 

Monitored light extinction1due to both sulfate and nitrate has decreased between the baseline 

and progress periods for both the worst days and the best days. Trend analyses of the period 

2000 to 2012 for the Jarbidge WA show that visibility impairment due to sulfate and nitrate 

extinction is decreasing through time for both the worst and best days. Thus, the long-term 

strategy embraced in the 2009 SIP is working to reduce emissions to reach the reasonable 

progress goals for 2018, as required. In the comprehensive 2018 SIP revision, Nevada will 

evaluate sources of visibility impairment at Jarbidge WA and revise its long-term strategy for the 

2018-2028 planning period, as appropriate.

Since the development of the 2018 emissions inventory for the 2009 RH SIP submittal, 

additional State and federal regulations and actions have been imposed on various source sectors. 

These additional mandates will help ensure that reasonable progress goals are attained on or 

before 2018. In addition, the 2018 emissions projections included a coal-fired power plant that 

has since ceased operations and been decommissioned, and three proposed power plants whose 

permit applications have been withdrawn. These actions have led to substantial reductions in the 

actual and projected emissions of anthropogenic visibility-impairing pollutants from Nevada 

sources and will further ensure that reasonable progress goals are attained on or before 2018. 

Finally, as discussed in Chapter Two, all of the facilities in Nevada that are subject to best 

available retrofit technology (BART) requirements are on schedule to meet those requirements 

by the State or federal implementation plan compliance dates.

Reducing haze is a regional effort and Nevada continues to work with the other western states 

and the federal land managers to plan for the required 2018 revision of its RH SIP. The states are 

focusing on strategies for continued reduction of controllable emissions. Quantification of the 

impacts of wildfire smoke and other sources beyond State regulatory jurisdiction will continue 

for the purposes of defining the burden these sources place on achieving visibility goals.

As evidenced by reductions in all of the controllable anthropogenic point source emissions that 

contribute to haze in Nevada and the concurrent downward trend of sulfate and nitrate light 

extinction at the Jarbidge WA monitor, Nevada determines the current regional haze plan 

strategies are adequate for Nevada to meet its 2018 visibility improvement goals. Based on an 

analysis of Nevada’s contribution to visibility impairment at nearby Class I areas, discussed in 

Chapters One and Six, and consultation with neighboring states, Nevada further concludes that 

 

1Light extinction, or the impairment of visibility, occurs due to particles and gases that reflect and absorb light. For 

a more complete description, see Chapter One of the 2009 RH SIP.
Nevada Regional Haze 5-Year Progress Report, November 2014

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emissions from Nevada sources are not impeding progress at any out-of-state Class I areas. 

Therefore, no further controls are necessary. In accordance with the requirements of the RHR, 

the Nevada Division of Environmental Protection (NDEP) hereby submits a negative declaration 

that no further substantive revision of the 2009 RH SIP is warranted at this time in order to 

achieve the 2018 reasonable progress goals for visibility improvement and emissions reductions.
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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CONTENTS

EXECUTIVE SUMMARY..................................................................................... i

ACRONYMS, ABBREVIATIONS AND TERMS.............................................viii

LIST OF TABLES.................................................................................................. x

LIST OF FIGURES............................................................................................... xi

CHAPTER ONE: INTRODUCTION

1.1 Clean Air Act Requirements for Addressing Regional Haze .................................1-2

1.2 Requirements for Periodic Reports and Premises ..................................................1-3

1.3 Class I Areas in Nevada and Nearby ......................................................................1-4

CHAPTER TWO: STATUS OF IMPLEMENTATION OF CONTROL 

MEASURES

2.1 Status Summary ....................................................................................................... 2-2

2.2 Nature of the Visibility Problem in Nevada............................................................. 2-2

2.3 Federal Programs .................................................................................................... 2-3

2.4 State Measures other than BART ........................................................................... 2-6

2.5 Review of BART Determinations ......................................................................... 2-10

CHAPTER THREE: SUMMARY OF EMISSION REDUCTIONS ACHEIVED

3.1 Status Summary ...................................................................................................... 3-2

3.2 Overall NOx and SO2 Emission Reductions ............................................................ 3-2

3.3 NOx and SO2 Emission Reductions from Federal Programs ................................... 3-2

3.4 EGU NOx and SO2 Emission Reductions due to State Measures other than BART3-3

CHAPTER FOUR: JARBIDGE: ASSESSMENT OF VISIBILITY CONDITIONS

4.1 Status Summary ....................................................................................................... 4-2

4.2 Visibility Conditions................................................................................................ 4-3

4.3 Current Visibility Conditions .................................................................................. 4-3

4.4 Differences between Current and Baseline Conditions ........................................... 4-4

4.5 Changes in Visibility Impairment ......................................................................... 4-13
Nevada Regional Haze 5-Year Progress Report, November 2014

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CONTENTS - Continued

4.6 Visibility Trends ................................................................................................... 4-15

4.7 Effects of Outliers.................................................................................................. 4-19

CHAPTER FIVE: CHANGES IN EMISSIONS: ALL SOURCES WITHIN THE 

STATE

5.1 Status Summary ....................................................................................................... 5-2

5.2 Baseline and Progress Periods for Tracking Emission Changes.............................. 5-2

5.3 Emissions from the 2002 Baseline Period .............................................................. 5-5

5.4 Emissions from the 2008 Progress Period ............................................................... 5-7

5.5 Emission Differences between the Baseline and Progress Periods ......................... 5-9

CHAPTER SIX: ASSESSMENT OF CHANGES IMPEDING VISIBILITY 

PROGRESS

6.1 Status Summary ....................................................................................................... 6-2

6.2 Significant Emission Changes within Nevada ........................................................ 6-2

6.3 Non-Nevada Sources Impacting the Jarbidge Wilderness Area............................... 6-4

6.4 Nevada’s Impacts on Nearby Class I Areas............................................................. 6-6

CHAPTER SEVEN: ASSESSMENT OF CURRENT SIP STRATEGY FOR 

MEETING REASONABLE PROGRESS GOALS

7.1 Status Summary ...................................................................................................... 7-2

7.2 Requirements .......................................................................................................... 7-2

7.3 Emissions Analysis ................................................................................................. 7-3

7.4 Visibility Analysis .................................................................................................. 7-3

7.5 Conclusions ............................................................................................................. 7-4

CHAPTER EIGHT: ASSESSMENT OF CURRENT MONITORING 

STRATEGY

8.1 Assessment .............................................................................................................. 8-2

CHAPTER NINE: DETERMINATION OF ADEQUACY, PROCEDURAL 

REQUIREMENTS AND CONCLUSIONS

9.1 Determination of Adequacy .................................................................................... 9-2

9.2 Procedural Requirements ........................................................................................ 9-3

9.3 Conclusions ............................................................................................................. 9-4
Nevada Regional Haze 5-Year Progress Report, November 2014

vii

CONTENTS - Continued

REFERENCES

APPENDIX A: Western Regional Air Partnership Regional Haze Rule Reasonable Progress 

Summary Report, June 28, 2013. Section 6.8 Nevada.

APPENDIX B: Supporting Documentation

1. Letters and News Releases

2. NDEP Findings and Orders

3. Public Utilities Commission of Nevada (PUCN)

APPENDIX C: Federal Land Management Agency Comments and Nevada’s Responses

APPENDIX D: Evidence of Public Participation; Public Comments and Nevada’s Responses
Nevada Regional Haze 5-Year Progress Report, November 2014

viii

Acronyms, Abbreviations and Terms

2009 RH SIP Nevada Regional Haze State Implementation Plan, October 2009

BART Best available retrofit technology

Bext Light-extinction coefficient, expressed in units of Mm-1

Boardman PGE Boardman Power Plant (Oregon)

CAA Clean Air Act

CAMD Clean Air Market Division

CFR Code of Federal Regulations

CM Coarse mass

DEASCO3 Deterministic and Empirical Assessment of Smoke’s Contribution to Ozone 

dv deciview

EC Elemental carbon

EGU Electrical generating unit

ERG Eastern Research Group 

FWS Fish and Wildlife Service

g/bhp-hr Gram per brake horsepower-hour

IMPROVE Interagency Monitoring of Protected Environments

Jarbidge WA Jarbidge Wilderness Area

LNB Low NOx burners

Mm-1Inverse megameters

MM5 Meteorological Mesoscale 5

MW Mega watts

NAAQS National ambient air quality standards

NDEP Nevada Division of Environmental Protection

NEI National Emission Inventory

NH3 Ammonia

Nitrate(s) Ammonium nitrate(s)

NO2 Nitrogen dioxide

NOx Oxides of nitrogen

NPS National Park Service

PM Particulate matter

POA Primary organic aerosol

POM Particulate organic matter

ppb Parts per billion 

ppm Parts per million

Reid Gardner Reid Gardner Generating Station

RH Regional Haze

RH SIP Regional Haze State Implementation Plan

RHR Regional Haze Rule

RPG Reasonable progress goal

RPOs Regional planning organization

SIP State Implementation Plan

SO2 Sulfur dioxide

SOx Sulfur oxides
Nevada Regional Haze 5-Year Progress Report, November 2014

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Sulfate(s) Ammonium sulfate(s)

tpy Tons per year

TSD Technical Support Document

TSS WRAP Technical Support System

USDOI U.S. Department of the Interior

USEPA U.S. Environmental Protection Agency

USFS U.S. Forest Service

VIEWS Visibility Information Exchange Web System

VOC Volatile organic carbon

VMT Vehicle miles traveled

WRAP Western Regional Air Partnership

WRAP TSD Western Regional Air Partnership Regional Haze Rule Reasonable Progress 

Summary Report, June 2013
Nevada Regional Haze 5-Year Progress Report, November 2014

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List of Tables

Table 2-1 New and Proposed Generation Plants in Nevada as of December 2013

Table 2-2 Nonattainment Areas: Redesignation Status as of August 2014

Table 2-3 BART Implementation Status

Table 3-1 Proposed 2018 EGUs and Current Permit Activity (shading indicates the project 

was withdrawn)

Table 3-2 Nevada Acid Rain CAMD Data – Annual EGU Emissions of SO2 and NOx

Table 4-1 Current Planning Period Annual Visibility Conditions and 5-Year Annual 

Averages for the Worst and Best Days Measured at JARB1

Table 4-2 5-Year Annual Average Baseline and Current Visibility Conditions for 

Successive 5-Year Planning Periods for the Worst and Best Days Measured at 

JARB1

Table 4-3 Five-Year Rolling Annual Average Haze Index for Baseline and Successive 

Planning Periods Measured at JARB1 (deciview)

Table 4-4 Average Visibility Conditions by Species for the Successive 5-Year Progress 

Periods at JARB1 

Table 4-5 Change in Aerosol Light Extinction by Species from 2000-2004 Baseline Period 

to Each Successive 5-Year Progress Period Measured at JARB1

Table 4-6 2018 Reasonable Progress Goal Summary for JARB1

Table 5-1 Comparison of 2002, 2008 and 2018 Emission Inventories for All Visibility 

Impairing Pollutants

Table 5-2 Anthropogenic and Natural Source Categories

Table 5-3 Pollutants, Aerosol Species and Major Sources

Table 5-4 Emissions from Plan02d Baseline Inventory in Tons

Table 5-5 Sulfur Dioxide Emissions by Category

Table 5-6 SO2 NEI Emissions (2008 and 2011)

Table 5-7 Oxides of Nitrogen Emissions by Category

Table 5-8 NOx NEI Emissions (2008 and 2011)

Table 5-9 Ammonia Emissions by Category

Table 5-10 Volatile Organic Compound Emissions by Category

Table 5-11 VOC NEI Emissions (2008 and 2011)

Table 5-12 Primary Organic Aerosol Emissions by Category

Table 5-13 Elemental Carbon Emissions by Category

Table 5-14 Fine Soil Emissions by Category

Table 5-15 Coarse Mass Emissions by Category

Table 6-1 Actual Emissions (tpy) for Nevada Point Sources 2002, 2005, 2008, 2011, 2012

Table 6-2 Comparison of Projected 2018 and Actual 2011 Emissions from BART Facilities

in Idaho and Oregon
Nevada Regional Haze 5-Year Progress Report, November 2014

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List of Figures

Figure 1-1 Location Map Showing Mandatory Class I Areas in the WRAP Region

Figure 3-1 EGU Emissions of SO2 and NOx Reported in the CAMD Acid Rain Database 

between 1995 and 2013

Figure 3-2 CAMD Acid Rain Database SO2 EGU Emissions for Reid Gardner 1995 – 2013

Figure 3-3 CAMD Acid Rain Database NOx EGU Emissions for Reid Gardner 1995 – 2013

Figure 3-4 CAMD Acid Rain Database SO2 EGU Emissions at Tracy 1995 – 2013

Figure 3-5 CAMD Acid Rain Database NOx EGU Emissions at Tracy 1995 – 2013

Figure 3-6 CAMD Acid Rain Database SO2 EGU Emissions at Fort Churchill 1995 – 2013

Figure 3-7 CAMD Acid Rain Database NOx EGU Emissions at Fort Churchill 1995 - 2013

Figure 4-1 Worst Days: Annual Haze Index with 5-Year Baseline Average and 5-Year 

Rolling Averages (deciview)

Figure 4-2 Best Days: Annual Haze Index with 5-Year Baseline Average and 5-Year Rolling 

Averages (deciview)

Figure 4-3 Worst Days: Average Annual Visibility Conditions at JARB1 Expressed in 

Deciviews and Speciated Light Extinction (Mm-1)

Figure 4-4 Best Days: Average Annual Visibility Conditions at JARB1 Expressed in 

Deciviews and Speciated Light Extinction (Mm-1)

Figure 4-5 Worst Days: Five-Year Average Speciated Light Extinction for Baseline and 

Successive 5-Year Planning Periods Measured at JARB1

Figure 4-6 Best Days: Five-Year Average Speciated Light Extinction for Baseline and 

Successive 5-Year Planning Periods Measured at JARB1

Figure 4-7 Worst Days: Change in 5-Year Average Light Extinction between Baseline and 

Successive Planning Periods Measured at JARB1

Figure 4-8 Best Days: Change in 5-Year Average Light Extinction between Baseline and 

Successive Planning Periods Measured at JARB1

Figure 4-9 Uniform Rate of Progress Glidepath for the Jarbidge Wilderness Area

Figure 4-10 Worst Days: Annual Visibility Conditions Measured at JARB1 for the Current 

Progress Period

Figure 4-11 Best Days: Annual Visibility Conditions Measured at JARB1 for the Current 

Progress Period

Figure 4-12 Annual Average Sulfate Light Extinction and Trends

Figure 4-13 Rolling Five-Year Average Sulfate Light Extinction and Trends

Figure 4-14 Annual Average Nitrate Light Extinction and Trends

Figure 4-15 Rolling Five-Year Average Nitrate Light Extinction and Trends

Figure 4-16 2005 Nitrate and Sulfate Monitor Data for the Jarbidge WA, Nevada

Figure 4-17 2005 Nitrate and Sulfate Monitor Data for the Mount Hood WA, Washington

Figure 4-18 2005 Nitrate and Sulfate Monitor Data for Great Sand Dunes NM, Colorado

Figure 4-19 Annual Average Nitrate Light Extinction and Trends, Substituted Data

Figure 4-20 Rolling Five-Year Annual Average Nitrate Light Extinction and Trends, 

Substituted Data

Figure 5-1 2002 and 2008 Sulfur Dioxide Emissions and Differences by Source Category

Figure 5-2 2002 and 2008 Oxides of Nitrogen Emissions and Differences by Source 

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

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Figure 5-3 2008 and 2008 Ammonia Emissions and Differences by Source Category

Figure 5-4 2002 and 2008 Volatile Organic Compounds Emissions and Differences by 

Source Category

Figure 5-5 2002 and 2008 Primary Organic Aerosol Emissions and Differences by Source 

Category

Figure 5-6 2002 and 2008 Elemental Carbon Emissions and Differences by Source Category

Figure 5-7 2002 and 2008 Fine Soil Emissions and Differences by Source Category

Figure 5-8 2002 and 2008 Coarse Mass Emissions and Differences by Source Category

Figure 6-1 Worst Days for Baseline and Rolling 5-Year Averages Speciated Light Extinction 

through Planning Period Measured at JARB1

Figure 6-2 Best Days for Baseline and Rolling 5-Year Averages Speciated Light Extinction 

through Planning Period Measured at JARB1

Figure 8-1 Jarbidge Wilderness Area and Vicinity