6.0 SUMMARY AND CONCLUSIONS 

This chapter summarizes the major findings from the review of the April 2009 draft

Nevada regional haze SIP. The findings are listed with respect to the major questions identified 

for this review. 

 

1. Does the SIP sufficiently allow for known and planned future growth of air emission 

sources in Nevada and neighboring states, in particular coal-fired electrical generating 

units (EGUs)? 

 

• Future growth in coal-fired EGUs appears to be underrepresented in the 2018 emission 

inventory projections contained in the draft Nevada regional haze SIP. If the proposed

Ely Energy Center and White Pine Power Projects are included, the 2018 emissions 

projections appear to be low by about 5,700 tpy for SO2 emissions and 6,200 tpy for 

NOx emissions. Recently, developers for the Ely and White Pine Projects have 

announced that these projects will not go forward in the immediate future. However, as 

of early May 2009, the air permit applications being processed at NDEP for both Ely 

and White Pine appear to remain active. The Ely and White Pine Projects need to be 

part of Nevada’s SIP planning process until such time that the air permit applications

are formally withdrawn. At IPP Unit 3 (within 300 km of Jarbidge), these emissions 

appear to be part of the 2018 WRAP regional emission projections and as such are 

included as part of Nevada’s SIP planning process. However, NDEP should 

acknowledge that IPP is part of the regional inventory within their SIP. 

 

• There are inconsistencies between the emissions listed in the 2018 emissions inventory 

for the Nevada regional haze SIP and allowable emissions established by NDEP air 

quality permits for several sources, i.e. TS Power Plant and White Pine Power Project. 

The 2018 emission inventory projections in the regional haze SIP need to be accurate if 

one is to rely on the results of any modeling to demonstrate whether “reasonable further 

progress” has been achieved. 

 

• The proposed Toquop Energy Project near Mesquite is not explicitly listed in the 2018 

emissions inventory, but these emissions are relatively close to the emissions assigned 

to an “unnamed” coal-fired EGU. Although the emissions from the unnamed plant

match with the Toquop Project, the resulting visibility impact projections for 2018 

depend also on how the “unnamed” plant was incorporated into the 2018 visibility 

modeling. Based on the proposed location for Toquop, it is expected that this plant will 

potentially affect regional haze at Zion National Park, Bryce Canyon National Park, 

and Grand Canyon National Park. The projections of 2018 visibility at these areas 

appear to be in error as the future Toquop emissions were not properly represented in 

the 2018 modeling. 

 

• The April 2009 Nevada SIP does not include future emissions from the Power County 

Advanced Energy Center, which was recently issued a permit by the Idaho Department 

of Environmental Quality for a site near American Falls, ID. This project could have 

the potential to impact visibility at the Jarbidge Wilderness. 

D-125 
 

2. Does the SIP contain adequate measures under Best Available Retrofit Technology 

(BART) for “BART-eligible” emission units under jurisdiction of the NDEP? 

 

• The proposed SO2 BART emission rate for Reid Gardner Units 1, 2, and 3 would 

actually allow for an increase in SO2 emissions above the baseline. By allowing for an

emissions increase, the Nevada SIP is inconsistent with the regulatory intent of BART. 

It is proposed that Nevada rectify this error by establishing a “two-tiered” BART limit 

for SO2 emissions at Reid Gardner. The current proposed BART limit could be applied 

to a short-term (i.e., 1-hour) averaging time, while a more stringent limit could be 

established based on a 30-day rolling average. This would allow for short periods of 

higher emissions which appear to be present based on historical data, but would also 

require that the company operate the Reid Gardner SO2 control systems in a manner

consistent with their historical practice. Based on the WRAP 2018 emission 

projections, Reid Gardner already achieves SO2 emissions in the range of 0.03 to 0.04 

lb/MMBtu, so the 30-day rolling average BART limit needs to be in this range to 

prevent any future degradation of the local and regional visibility conditions. 

 

• The proposed NOx BART limit for Reid Gardner Unit 3 is higher at 0.28 lb/MMBtu 

compared to the proposed NOx limit of 0.20 lb/MMBtu for Units 1 and 2. The draft SIP 

does not provide an adequate explanation or justification for why Unit 3 requires a 

higher NOx emission rate for BART. 

 

• The SIP explains that selective catalytic reduction (SCR) was evaluated for potential 

application as BART at Reid Gardner, but rejected based on cost considerations. 

However, it does not appear that NDEP conducted a critical evaluation of the SCR 

costs supplied by NV Energy and instead has accepted the company’s costs “at face 

value.” If cost is to be used as part of the decision to reject SCR as BART for Reid

Gardner, the company’s SCR cost estimates need to be properly vetted. 

 

• The control efficiency used by Nevada in evaluating SCR for Reid Gardner appears to 

be underestimated. In other situations where SCR was reviewed under BART, the postSCR NOx emission rate is consistently 0.07 lb/MMBtu. At Reid Gardner, the proposed 

post-SCR emissions rate ranged from 0.083 to 0.098 lb/MMBtu. The draft SIP does not 

explain why 0.07 lb/MMBtu cannot be achieved using SCR at Reid Gardner. If the 

draft SIP applied a more realistic post-SCR emission rate, the cost evaluation for SCR 

at Reid Gardner would also be more favorable. 

 

• The post-BART modeling for Reid Gardner shows no significant improvement in 

visibility at nearby Class I areas. The lack of improvement in the post-BART modeling 

may reflect an inaccurate emissions inventory that failed to account for changes in the 

post-BART emissions proposed at Reid Gardner. If so, the inventory needs to be 

corrected and accurate modeling performed at Reid Gardner in order to meet the 

procedural requirements of the SIP. On the other hand, if the Reid Gardner inventory is 

accurate, then the modeling indicates a failure of the draft SIP to craft a BART proposal 

D-126 
that contains any meaningful emissions reductions and associated visibility 

improvement. If a more appropriate BART emission limit were established at Reid 

Gardner, it is believed that the post-BART modeling would show visibility 

improvement at Grand Canyon and other nearby Class I areas. 

 

• Even after application of BART technologies at Mohave and Reid Gardner, the postBART visibility modeling continues to show that emissions from Mohave and Reid 

Gardner would continue to “cause or contribute” to visibility impairment at nearby 

Class I areas, including Grand Canyon National Park. If these modeling results are 

accurate, Nevada should consider more stringent BART emission levels that further 

reduce or eliminate visibility impairment caused by these sources and even consider 

emission reductions that are “beyond BART” as have other states where BART has 

proven to be ineffective at providing the emission reductions needed to achieve 

“reasonable further progress” toward the national visibility goal. 

 

3. Does the SIP adequately address and mitigate Nevada’s contribution to visibility 

impairment at Class I areas outside of Nevada, in particular National Parks in the 

southwestern United States that are presently known to be adversely impacted by Nevada 

emissions (i.e., Zion, Bryce Canyon, and Grand Canyon National Parks)? 

• Regional modeling using the 2018 WRAP inventory projections show that visibility at

Grand Canyon, Zion, and Bryce Canyon National Parks will not achieve the Uniform 

Rate of Progress (URP) goals and that the “glide path” for visibility improvement to 

natural conditions by 2064 will not be achieved without additional emission reductions. 

This finding occurs even without considering that future growth from Nevada coal-fired 

EGUs appears to be significantly underrepresented in the 2018 inventory. Given that 

source emissions from within Nevada are shown to “cause and contribute” to visibility

impairment at Class I areas outside of the state after 2018, Nevada needs to revisit its 

draft regional haze SIP and craft an emissions reduction plan that helps achieve the 

URP goals at Class I areas outside of Nevada. Achieving the national visibility goal and 

meeting the 2018 URP milestones will require aggressive actions from all states in the 

region, including Nevada. Nevada has established BART emission limits in the draft 

SIP that fail to provide meaningful improvement in visibility conditions and that 

continue to show Nevada’s emissions sources will “cause and contribute” to visibility 

impairment. These findings demonstrate that Nevada’s draft regional haze SIP as 

written fails to meet its primary objective of providing the initial step toward meeting 

the national visibility goal. 

D-127 
7.0 REFERENCES 

1. Clean Air Act, Section 169A. 

 

2. Stationary Sources Joint Forum, Western Regional Air Partnership, information available at 

www.wrapair.org 

 

3. Air Quality Modeling Forum, Western Regional Air Partnership, information available at 

www.wrapair.org 

 

4. Director’s Review and Preliminary Determination of Permit Issuance for Toquop Energy 

LLC, Toquop Energy Project; Nevada Division of Environmental Protection, December 17, 

2007. 

 

5. Director’s Review and Preliminary Determination of Permit Issuance for Sierra Pacific 

Resources Company, Ely Energy Center; Nevada Division of Environmental Protection, October 

29, 2007. 

 

6. Business Wire; February 9, 2009, available at http://investors.nvenergy.com 

 

7. Class I Application Review for White Pine Energy Associates LLC, White Pine Energy 

Station; Nevada Division of Environmental Protection, December 28, 2006. 

 

8. Las Vegas Sun, March 5, 2009, available at www.lasvegassun.com 

 

9. Class I Air Quality Operating Permit No. AP4911-1349; Nevada Division of Environmental 

Protection. 

 

10. Sevier Power Company, LLC; http://sevierpower.com 

 

11. Conditional Extension of Approval Order #DAQE-AN0327010-04; Utah Department of 

Environmental Quality; April 25, 2008. 

 

12. WRAP 2018 Base Case (Version I) Emissions Inventory, available at www.wrapair.org 

 

13. Sourcewatch; www.sourcewatch.org 

 

14. Statement of Basis, Southeast Idaho Energy LLC/Power County Advanced Energy Center, 

Idaho Department of Environmental Quality. 

 

15. WRAP 2018 Point Source Emissions-Pivot Tables; available at www.wrapair.org 

 

16. Revised Nevada Division of Environmental Protection BART Determination Review of NV 

Energy’s Reid Gardner Generating Station Units 1, 2, and 3; April 15, 2009. 

D-128 
 

17. Regional Haze Regulations and Guidelines for Best Available Retrofit Technology (BART) 

Determinations; Final Rule; Federal Register July 6, 2005. 

 

18. WRAP 2018 Preliminary Reasonable Progress Emissions Inventory – Final, Revised; 

Prepared for WRAP by Eastern Research Group, June 18, 2007. 

 

19. WRAP Regional BART Status; March 27, 2009, available at www.wrapair.org 

 

20. DEQ BART Report for the Boardman Power Plant; Oregon Department of Environmental 

Quality, Updated December 19, 2008. 

 

21. National Park Service comment letter on Nevada’s draft regional haze State Implementation 

Plan, March 6, 2009. 

 

22. BART Analysis for Reid Gardner Station Unit 1; Prepared by CM2MHill for NV Energy, 

Inc.; Revised October 2008. 

 

23. State of Kansas Air Quality State Implementation Plan, Regional Haze, July 15, 2008 

(Draft). 

 

Additional Data Sources Considered 

Nevada Division of Environmental Protection, Bureau of Air Quality Planning, General 

information on April 2009 draft regional haze State Implementation Plan; available at

http://ndep.nv.gov/baqp/planning.html 

 

 

 

 

D-129 
 

 

 

ATTACHMENT 1 

 

 

 

 

Information on Author: D. Howard Gebhart 

 

 

D-130 
D-131 
Previous Service as Expert Witness 

Mr. Gebhart has not served as an expert witness at trial in the most recent four years. 

 

Mr. Gebhart did serve as an expert witness in a recent arbitration case: 

 

• Adkins Energy, LLC v. Lurgi PSI, Inc. v. Ronning Engineering Company, Inc. 

American Arbitration Association, Case No. 51 198 Y 00300 05. 

 

Mr. Gebhart has served as an expert witness in two recent administrative hearings: 

 

• Appeal of Air Quality Permit # 1756 Issued to Vulcan Materials Company. Hearing 

before the Albuquerque – Bernalillo County Air Quality Control Board. 

 

• Hearing on Air Quality Permit for Western Water & Power Production, LLC, Proposed 

Estancia Biomass Power Generation Plant. Hearing before State of New Mexico 

Secretary of Environment, Case AQCA 06-42(P).

Mr. Gebhart was retained as an expert witness in two other cases involving an appeal of 

an air quality permit. Both cases were settled prior to any hearing or trial. 

 

• Stanley R. Atherton, David B. Gooch, and Mark A. Hertel et al v. Abengoa Bioenergy 

of Indiana. Appeal of Air Quality Permit 129-23484-00050 issued by the Indiana 

Department of Environmental Management. 

 

• Coshocton County Citizens for a Safe Community et al v. Koncelik et al. Appeal of air 

quality permit for Coshocton Ethanol LLC, Coshocton, OH. ERAC Case Nos. 165768-

72 and 99773. 

 

 

Publications

 

 Mr. Gebhart has not authored any peer-reviewed publications in the last four years. 

D-132 
SECTION D.2.2.4.3 

NEVADA’S RESPONSE 

(to Conservation Organizations’ Comment Letter) 

D-133 
D-134 
2.2.4.3 Nevada’s Response 

NDEP received written comments via email and FAX from a group of NGOs regarding 

Nevada’s draft regional haze SIP on May 20, 2009. Attached to the NGO letter and included in 

the comments by reference is a report by D. Howard Gebhart of Air Resources Specialists, Inc. 

prepared for the Western Resource Advocates and National Parks Conservation Association 

titled Technical Review of Draft Nevada State Implementation Plan for Regional Haze (April 

2009) Expert Report (Tech Review). The Tech Review is a support document for issues 

summarized in the NGO comments. 

The NGO comments focus on 5 main areas: the FLM consultation process, the projected 2018 

emission inventory, the BART determination for Reid Gardner Generating Station, reasonable 

progress for Class I areas in adjacent states, and inclusion of specific sources in the projected 

2018 emission inventory. The NGO comments are reproduced below in italics, while NDEP’s 

responses are in plain text. The NGOs listed five specific comments with bullets under some

comments. NDEP has not identified any specific comments in the Tech Review and, as such, 

has not responded specifically to items contained therein. 

NGO General Comment:

Below is a summary of comments on the Nevada Draft RH SIP. For a full description of our 

comments, please refer to the Technical Review, which is attached hereto. 

NDEP Response:

As indicated above, Nevada has reviewed the Tech Review and determined that all of the 

significant comments in the Tech Review are well summarized in the NGO comment letter. 

Therefore, NDEP has used the Tech Review to assist in understanding the NGO comments, but 

has only responded to the items presented in the NGO letter. 

NGO Comment 1: 

1. The public notice for the RH SIP fails to contain evidence that the State of Nevada has met in 

person with the Federal land managers for the affected Class I areas as is required by 42 U.S.C. 

§ 7491(d). In addition, the public notice for the Nevada RH SIP fails to contain a summary of the 

conclusions and recommendations of the Federal land manager as is required by 42 U.S.C. § 

7491(d). 

NDEP Response:

NDEP has fully engaged the Federal Land Manager (FLM) community through participation in 

the regional planning process, requesting review and comment on draft BART determinations 

beginning October 2008, providing a draft SIP for FLM review in early January 2009, and 

responding to initial FLM comments on April 17, 2009. This process is in full agreement with 

an August 1, 2006 letter from the FLMs (signed by Sandra V. Silva, USFWS and Christine L. 

Shaver, NPS) to the individual states outlining the regional haze consultation process with the 

FLM agencies. Mr. Bruce Polkowsky, primary Department of Interior contact for regional haze, 

supports Nevada’s position (June 4, 2009 phone call between Bruce Polkowsky and Frank 

Forsgren, NDEP) that we have met our FLM consultation requirements and stated FLMs 

D-135 
typically do not require any “in person” consultation (August 22, 2008 phone call between Bruce 

Polkowsky and Adele Malone, NDEP). 

In addition, NDEP included our response to FLM comments as Appendix C in our public review

draft RH SIP dated April 2009. The Notice of Public Comment Period Beginning April 17, 2009 

and a Public Hearing on May 20, 2009 provides a link to the draft SIP, including Appendix C, 

which summarizes and responds to FLM comments on Nevada’s draft RH SIP. Therefore, the 

public notice does provide a summary of FLM comments by reference. 

This comment relates only to the consultation and public notice process and does not affect the 

conclusions and recommendations NDEP presents in Nevada’s RH SIP. No changes were made 

to the SIP as a result of this comment. 

NGO Comment 2: 

2. The RH SIP does not sufficiently allow for known and planned future growth of air emission 

sources in Nevada and neighboring states, in particular coal-fired electrical generating units 

(EGUs). 

NDEP Response:

Each of the following four bulleted comments will be responded to individually. However, some

background on the development of regional emission inventories is necessary to address these 

comments. 

Nevada has fully participated in the regional planning process though our involvement with 

WRAP forums and workgroups, including the Emissions Forum and Stationary Sources Joint 

Forum. The emissions inventories relied upon by the WRAP and member states were developed 

by consultants under the direction of these forums through a consensus-based process. The 

inventory development methodologies were utilized for all WRAP states’ inventories. The 

inventories utilized by WRAP and the member states are deemed by most observers to be the 

most robust and accurate available. 

Two emissions scenarios were developed by WRAP, a baseline scenario and a projected 

scenario. The regional haze baseline period includes years 2000 through 2004, and is 

represented by 2002, while the projected inventories denote 2018 emissions. The year 2018 was 

selected as it represents the first milestone date for demonstrating reasonable progress. 

The base case 2018 projected emission inventory was initially developed during 2005 by Eastern 

Research Group, Inc. (ERG). WRAP Point and Area Source Emissions Projections for the 2018 

Base Case Inventory, Version 114, prepared by ERG, documents the development of the 2018 

base case emission inventory. ERG refined the 2018 preliminary reasonable progress emission 

inventory in early 2007 as documented in Technical Memorandum WRAP 2018 Preliminary 

Reasonable Progress Emissions Inventory – Final, Revised15. 

 

14 Available at http://wrapair.org/forums/ssjf/documents/eictts/docs/WRAP_2018_EI-Version_1-

Report_Jan2006.pdf 15 Available at http://wrapair.org/forums/ssjf/documents/eictts/Projections/PRP18_EI_tech%20memo_061607.pdf

D-136 
The growth analysis utilized for development of the projected inventory identified future EGUs 

needed in order to meet projected electricity demand in 2018. The basis of the projected 

electricity demand is the Energy Information Administration’s (EIA) annual 2018 energy 

projections for four electricity market module regions representing the WRAP region. The base 

case 2018 inventory (base18b) used the EIA projections released in 2005, while the preliminary 

reasonable progress inventory (PRP18a) utilized projections released in 2007. 

WRAP assumed a typical future coal-fired EGU has a capacity of 500 MW and operates at 

BACT levels with a capacity threshold of 0.85. WRAP then estimated that 18 typical coal-fired 

EGUs will need to be built prior to 2018 to meet projected demand. The future coal-fired EGUs 

were allocated based upon current state-level capacity (i.e., sum of existing, under construction, 

and permitted). The EGUs were then allocated to specific counties based on announced plans to 

build coal-fired EGUs. 

Based on a long history of permitting EGUs in Nevada, the Nevada Bureau of Air Pollution 

Control (BAPC) expected that not all permit applications would result in operating EGUs. 

Therefore, BAPC deemed that two coal-fired EGUs were either being permitted or under 

construction for the purposes of the projected inventory, the 200 MW Northern Nevada Energy 

(Newmont) facility (referred in the NGO comments as the TS Power Plant) and the 1500 MW

White Pine Energy Association (LS Power) facility. In addition to the permitted or under 

construction EGUs, the 2018 inventory projected one 500 MW coal-fired EGU in Nevada to 

meet anticipated electricity demand growth. 

The three proposed coal-fired EGUs included in the 2018 projected emission inventory are 

shown in Table 3-5 of Nevada’s RH SIP as: Future Coal EGU (Newmont – Northern Nevada 

Energy), Future Coal EGU (White Pine Energy Association/LS Power), and Future Coal EGU 

(A). 

Although Nevada has several valid applications for operating permits to construct EGUs, only 

one EGU in Nevada, Northern Nevada Energy, has been granted an operating permit to construct 

in the last few years. In addition, the White Pine Power Project does not yet have an approved 

operating permit to construct. NDEP cancelled the public comment period and hearing for this 

permit action as a result of an announcement by White Pine Energy Associates, LLC16 that the 

plans to build the White Pine Energy Station have been indefinitely postponed. Ely Energy 

Center’s permit application has also been indefinitely postponed by NV Energy17. For this very 

reason, proposed permit activities are not, as a matter of course, explicitly included in projected 

emission inventories. 

This comment acknowledges the fact that projected emissions inventories become outdated as 

soon as they are completed. However, Nevada deems the emissions inventories as accurate and 

representative of 2018 emissions as possible. No changes to Nevada’s RH SIP were made as a 

result of this comment. 

 

16 http://lspower.com/News/newsArticle030509.htm 17 http://investors.nvenergy.com/phoenix.zhtml?c=117698&p=irol-newsArticle&ID=1254617&highlight=

D-137 
NGO Comment 2, 1st bullet: 

• Future growth in coal-fired EGUs appears to be underrepresented in the 2018 emission 

inventory projections contained in the draft Nevada regional haze SIP. If the proposed Ely 

Energy Center and White Pine Power Projects are included, the 2018 emissions projections 

appear to be low by about 5,700 tpy for SO2 emissions and 6,200 tpy for NOx emissions. 

NDEP has issued draft PSD permits for both the Ely Energy Center and White Pine power 

plants. As of early May 2009, the draft PSD permits have not been terminated by NDEP nor 

have the air permit applications been withdrawn by the applicants. Accordingly, the Ely and 

White Pine Projects need to be part of Nevada’s SIP planning process. 

NDEP Response:

As discussed above, the 2018 EGU inventory is based on projected electricity demand. The 

demand side suggested that not all permit applications would result in operating EGUs, as did 

BAPC’s permitting experience with EGUs. Therefore, only one of the two proposed coal-fired 

EGUs in White Pine County was included in the 2018 emission inventory. Note that the permit 

applications for both the Ely Energy Center and White Pine Energy Association have been 

indefinitely postponed by the applicants, although the permit applications have not been 

withdrawn. In addition, Southern California Edison18 has announced a decision to decommission 

the Mohave Generating Station and remove the generating facility from the site. 

Therefore, since emissions from the Mohave Generating Station and proposed White Pine 

project are included in the 2018 emission inventory (PRP18a), the inventory actually overrepresents 2018 emissions from coal-fired EGUs in Nevada. 

NDEP also notes that although the EIA energy projections suggest additional generating capacity 

will be required in the future, the electrical infrastructure has absorbed the reduction in

generating capacity in Nevada (in part due to the suspension of activities at the Mohave 

Generating Station at the end of 2005) and elsewhere without significant problem. NDEP 

anticipates renewable energy projects will provide substantial generating capacity to meet future 

electrical demand in Nevada. 

No changes were made to the SIP in response to this comment. 

NGO Comment 2, 2nd bullet: 

• There are inconsistencies between the emissions listed in the 2018 emissions inventory for 

the Nevada regional haze SIP and allowable emissions established by NDEP air quality 

permits for several sources. For example, the proposed emissions from the TS Power Plant 

and White Pine Power Project are underestimated in the RH SIP inventory. 

NDEP Response: 

The TS Power Plant Operating Permit to Construct application was revised August 2007, and the 

first source tests were conducted April 2008. A complete Class I application was recently 

submitted to the Nevada BAPC by the facility. The White Pine Power Project operating permit 

to construct application was revised in December 2006. Note that the White Pine Power Project 

has been indefinitely postponed, as noted above. 

 

18 http://www.edison.com/pressroom/pr.asp?bu=&year=0&id=7234

D-138 
The base case 2018 emission inventory was prepared in 2005 and the preliminary reasonable 

progress inventory was revised in early 2007. The emissions listed in these inventories represent 

NDEP’s best estimate at the time the inventories were prepared. No changes were made to the 

SIP in response to this comment. 

NGO Comment 2, 3rd bullet: 

• The proposed Toquop Energy Project near Mesquite is not explicitly listed in the 2018 

emissions inventory, but these emissions are relatively close to the emissions assigned to an 

“unnamed” coal-fired EGU. Although the emissions from the unnamed plant are similar to 

those of the Toquop Project, the resulting visibility impact projections for 2018 depend also 

on how the “unnamed” plant was incorporated into the 2018 visibility modeling. Based on 

the proposed location for Toquop, it is expected that this plant will potentially affect 

regional haze at Zion National Park, Bryce Canyon National Park, and Grand Canyon 

National Park. The projections of 2018 visibility at these areas are in error if the future 

Toquop emissions are not properly represented in the 2108 modeling. 

NDEP Response: 

Future Coal EGU (A) identified and discussed under the NGO comment above, may be 

considered as an emissions surrogate for the proposed Toquop Energy Project. The Toquop 

Energy Project has applied for and NDEP has issued a draft operating permit to construct for 

public comment. As of September 4, 2009 NDEP is in the process of responding to public 

comment and has not yet issued an operating permit to construct. 

The rational for projecting future EGUs has been described above in Nevada’s responses to NGO 

comments. NDEP acknowledges that Future Coal EGU (A) was not located in immediate 

proximity to the proposed Toquop Energy Project, which may slightly effect the 2018 visibility 

projection if the Toquop Energy Project is, in fact, built as proposed. However, recall that Future 

Coal EGU (A) is only a placeholder to account for emissions resulting from increased electrical 

demand in 2018. 

In addition, Nevada BAPC’s Class I Application Review for Toquop Energy, LLC dated 

December 21, 2007 summarizes the results of the visibility analysis conducted as part of the 

permit application process, as follows: 

“7.9.4 Visibility Analysis 

Regional haze modeling was conducted with CALPUFF using the FLAG guidance for Bryce 

Canyon National Park, Grand Canyon National Park, Zion National Park, Capitol Reef 

National Park and Sycamore Canyon Wilderness. In addition, regional haze modeling results 

have been provided for Lake Mead National Recreation Area using the FLAG guidance. The 

regional haze modeling results are presented in Table 7.5 below. As indicated, the regional 

haze modeling results using the FLAG guidance have no days above a 5% change in 

extinction at any Class I area during any year modeled. Therefore, according to the FLAG 

guidance, the proposed Toquop project does not have a significant regional haze impact and 

no further modeling is required. 

D-139 
TABLE 7.5 – Regional Haze Modeling Results - FLAG (2003 – 2005)

2003 2004 2005

Days > N%

∆Bext

Days > N%

∆Bext

Days > N%

∆Bext

Class I 

Area 

5% 10%

MAX%

∆Bext

 1

5% 10%

MAX%

∆Bext

1

5% 10%

MAX%

∆Bext 

1

MVISBK=2, FLAG Background, 2-km Grid

Capitol 

Reef 0 0 3.04 0 0 1.42 0 0 2.17

Sycamore 

Canyon

0 0 1.69 0 0 1.01 0 0 1.22

MVISBK=2, FLAG Background, 500-m Grid

Bryce 

Canyon

0 0 4.03 0 0 0.91 0 0 1.85

Grand 

Canyon

0 0 2.75 0 0 4.33 0 0 3.32

Zion 0 0 4.70 0 0 1.95 0 0 4.61

NOTES: 1 ∆Bext = change in atmospheric light condition. ”

Therefore, the proposed Toquop Energy Project has been fully reviewed for its potential 

visibility impacts at nearby Class I areas and it has been determined that the project does not 

have significant visibility impacts at the Class I areas within 300 km of the proposed project. No 

changes were made to the SIP in response to this comment. 

NGO Comment 2, 4th bullet: 

• The April 2009 Nevada SIP does not include future emissions from the Power County 

Advanced Energy Center, which was recently issued a permit by the Idaho Department of 

Environmental Quality for a site near American Falls, ID. This project could have the 

potential to impact visibility at the Jarbidge Wilderness. 

NDEP Response: 

As stated earlier in our response to NGO comments, the base case 2018 projected emission 

inventory (base18b) was initially developed during 2005 and the refined 2018 preliminary 

reasonable progress emission inventory (PRP18a) in early 2007. Idaho Department of 

Environmental Quality issued a Permit to Construct for the Southeast Idaho Energy Power 

County Advance Energy Center project February 10, 2009, well after the 2018 projected 

emission inventories used in Nevada’s RH SIP were completed. In spite of this timing, it is each 

state’s decision and responsibility to ensure that the WRAP’s projected 2018 emission inventory 

for its sources is accurate and complete. Nevada has no role in how Idaho reports the emissions 

from this proposed project. 

Finally, the project was evaluated by the Idaho Department of Environmental Quality and the 

FLM community for potential impacts to sensitive Class I areas as a major source under 

Prevention of Significant Deterioration (PSD) regulations and the project was found to have 

negligible impact on the nearest Class I area, Craters of the Moon, located 70 km from the 

project site. The FLMs determined that a more detailed Class I visibility analysis was not 

D-140