## Technical Support Document

For the Review of the

New Mexico State Implementation Plan Regional Haze Section

309(g) SIP submittal

Prepared and Reviewed by:

Michael Feldman Brian Tomasovic

May 2012ii 

### T ABLE OF 

### C ONTENTS

I. Relationship of this TSD to our Proposal .................................................................................... 5

II. Background to Regional Haze .................................................................................................... 6

III. Evaluation of State Submittal ............................................................................................ ..... 10

A. Identification of Affected Class I Areas: 40 CFR 51.308(d) ............................................... 10
B. Reasonable Progress Goals Development ............................................................................ 12 B.1. Establishment of Reasonable Progress Goals: 40 CFR 51.308(d)(1) ............................ 12 B.2. Reasonable Progress Goals Four Fact or Analysis: 40 CFR 51.308(d)(1)(i)(A) ............ 14 B.3. Uniform Rate of Progress Determination: 40 CFR 51.308(d)(1)(i)(B) ......................... 16 B.4 Analysis of Reasonable Progress Goal: 40 CFR 51.308(d)(1)(ii)-(iii) ........................... 17 B.5 Reasonable Progress State Consultation: 40 CFR 51.308(d)(1)(iv) ............................... 23 B.6 Reasonable Progress Goal To Be Consid ered by Administrator: 40 CFR 51.308(d)(1)(v)

.............................................................................................................................. ................. 24 B.7 Reasonable Progress Goal Minimum: 40 CFR 51.308(d)(1)(vi) .................................... 24
C. Baseline and Natural Visibility Conditions .......................................................................... 25 C.1. Calculation of Baseline C onditions: 40 CFR 51.308(d)(2)(i) ........................................ 25 C.2. Calculation of Natural Visibility Conditions: 40 CFR 51.308(d)(2)(iii) ....................... 29
D. Long Term Strategy: 40 CFR 51.308(d)(3) .......................................................................... 31 D.1 Long Term Strategy State C onsultation: 40 CF R 51.308(d)(3)(i) .................................. 32 D.2 Share of Reductions in Other States ’ Progress Goals: 40 CFR 51.308(d)(3)(ii) ............ 33 D.3 Technical Basis for the Long Term St rategy: 40 CFR 51.308(d)(3)(iii) – (iv) .............. 34 D.3.a Emissions Inventory ................................................................................................. 35 D.3.a.i New Mexico’s 20 02 Emission Inventory ........................................................... 35 D.3.a.ii New Mexico’s 2018 Emission Inventory .......................................................... 36 D.3.b. Visibility Projection Modeling................................................................................ 38 D.3.c Sources of Visibility Impairme nt in New Mexico Class I Areas ............................. 39 D.3.c.i Sources of Visibility Impa irment in Bandelier Wilderness ................................ 43 D.3.c.ii Sources of Visibility Impairment in Bosque del Apache National Wildlife Refuge ........................................................................................................................ .... 45 D.3.c.iii Sources of Visibility Impairment in Carlsbad Caverns National Park ............. 48 D.3.c.iv Sources of Visibility Im pairment in Gila Wilderness ...................................... 50 D.3.c.v Sources of Visibility Impairment in Pecos Wilderness and Wheeler Peak Wilderness .................................................................................................................... .. 52 D.3.c.vi Sources of Visibility Impa irment in Salt Creek Wilderness ............................ 54 D.3.c.vii Sources of Visibility Impairment in White Mountain Wilderness .................. 57 D.3.d New Mexico’s Contributions to Visibility Impairment at Class I areas in Other States ........................................................................................................................ .......... 60iii D.4 Consideration of Long Term Stra tegy Factors: 40 CFR 51.308(d)(3)(v) ....................... 61 D.4.a Emission reductions due to ongoing ai r pollution control programs, including measures to address reasonably attr ibutable visibility impairment ................................... 62 D.4.b Measures to mitigate the impacts of construction activities .................................... 63 D.4.c Emissions limitations and schedules for compliance to achieve the reasonable progress goal ...................................................................................................................... 64 D.4.d Source retirement and replacement schedules ......................................................... 64 D.4.e Smoke management techniques for agricu ltural and forestry management purposes including plans as currently exist within the State for these purposes .............................. 64 D.4.f Enforceability of emissions limitations and control measures ................................. 65 D.4.g The anticipated net effect on visibility due to projected changes in point, area, and mobile source emissions over the period addressed by the long-term strategy. ................ 65 D.5 Our Conclusion on New Mexi co’s Long Term Strategy ................................................ 66
E. Monitoring Strategy/Other SIP Re quirements: 40 CFR 51.308(d)(4) ................................. 66
F. Best Available Retrofit Technology (BART) Requirements: 40 CFR 51.308(e) ................. 69 F.1. BART Eligible Source Identification: 40 CFR 51.308(e)(1)(i) ..................................... 69 F.2 BART Sources Exempted Due to Modeling Waivers ..................................................... 71 F.3. BART Five Factor Determinat ion: 40 CFR 51.308(e)(1)(ii)(A)-(B) ............................ 75 F.3.a New Mexico’s PM BART Determination for the SJGS ........................................... 76 F.4. De Minimis BART: 40 CFR 51.308(e)(1)(ii)(C) ........................................................... 78 F.5. Design, Equipment, or Work Pr actice BART: 40 CFR 51.308(e)(1)(iii) ...................... 78 F.6. Installation of BART: 40 CFR 51.308(e)(1)(iv) – (v) .................................................... 79 F.7 CAIR for BART: 40 CFR 51.308(e)(2)-(3) .................................................................... 79 F.8 CAIR for BART : 40 CFR 51.308(e)(4) .......................................................................... 80 F.9. Reasonable Progress and BART: 40 CFR 51.308(e)(5)................................................. 80 F.10. BART Exemptions: 40 CFR 51.308(e)(6) ................................................................... 80iv 

### T ABLES Table 1 - Percent of the WRAP contribution due to New Mexico emissions at Class I areas in surrounding states. ........................................................................................................... ............. 12 Table 2 - Reasonable Progress Goals for 20% Wors t Days and 20% Best Days for New Mexico Class I Areas ................................................................................................................. ................ 13 Table 3 - URP, RPG and Years to Natural Conditions for 20% worst days ................................. 17 Table 4 -WRAP Area Source SO2 Emissions (tpy) ..................................................................... 21 Table 5 – Comparison of Bernalillo County Emission Estimates to WRAP ................................ 22

Table 6 - Baseline Conditions fo r 20% Worst and 20% Best Day s

.............................................. 28

Table 7 - 2064 Natural Conditions Goal for 20% Worst and Best Days ...................................... 29 Table 8- Baseline and Natural Visibility C onditions at New Mexico’s Class I Areas ................. 31

Table 9 - New Mexico’s 2002 Emissions I nventory (including Bernalillo County) ................... 35

Table 10 - New Mexico’s 2018 Emissions Inve ntory (including Bernalillo County) .................. 36 Table 11 - Change (tpy) in New Mexico Emi ssions from 2002 to 2018 (including Bernalillo County) ....................................................................................................................... .................. 37 Table 12 - Net Change (%) in New Mexico Em issions from 2002 to 2018 (including Bernalillo County) ....................................................................................................................... .................. 37 Table 13 - Percentage of Light Extinction on 20% Worst Days During the Baseline Period ...... 40 Table 14 - Percentage of Nitrat e Contribution to Visibility Im pairment During Baseline for the 20% Worst Days ................................................................................................................ ........... 41 Table 15 - Percentage Sulfate Contribution to Visibility Impairment During Baseline for 20% Worst Days.................................................................................................................................... 41

Table 16 - Percent Contribution to Sulfate a nd Nitrate on the 20% wo rst days at Bandelier Wilderness..................................................................................................................... ................ 44

Table 17 - Percent Contribution to Sulfate and Nitrate on the 20% worst days at Bosque del Apache ........................................................................................................................ .................. 47

Table 18 - Percent Contribution to Sulfate and Nitrate on the 20% worst days at Carlsbad Caverns ....................................................................................................................... .................. 49

Table 19 - Percent Contribution to Sulfate and N itrate on the 20% worst days at Gila Wilderness

............................................................................................................................... ........................ 51

Table 20 - Percent Contribution to Sulfate and N itrate on the 20% worst days at Pecos/Wheeler Park .......................................................................................................................... ..................... 53

Table 21 - Percent Contribution to Sulfate and Nitrate on the 20% worst days at Salt Creek ..... 55

Table 22 - Percent Contribution to Sulfate and N itrate on the 20% worst days at White Mountain

............................................................................................................................... ........................ 58

Table 23 - IMPROVE Monitors in New Mexico .......................................................................... 68v 

### F IGURES Figure 1 - Map of Class I Areas ...................................................................................................... 7 Figure 2 - Location of the Class I Areas in New Mexico ............................................................... 8 Figure 3 - Map of Regional Plan ning Organization Boundaries .................................................... 9 Figure 4 – Sulfur Oxide Emissions by County for 2002 and 2018 ............................................... 21 Figure 5 – OMC and EC Emissions Aff ecting New Mexico’s Class I Areas .............................. 43 Figure 6 - Regional Contributions to Sulfate on 20% worst days at Bandelier Wilderness ......... 45 Figure 7 - Contributions to sulfate from area s ources on 20% worst days at Bandelier Wilderness

............................................................................................................................... ........................ 45 Figure 8 - Regional Contributions to Sulfate on 20% worst days at Bosque del Apache ............ 47 Figure 9 - Contributions to sulfate from area s ources on 20% worst days at Bosque del Apache 48 Figure 10 - Regional Contributions to Sulfate on 20% worst da ys at Carlsbad Caverns ............. 50 Figure 11 - Contributions to sulfate from area s ources on 20% worst days at Carlsbad Caverns 50 Figure 12 - Regional Contributi ons to Sulfate on 20% worst days at Gila Wilderness ................ 52 Figure 13 - Contributions to Sulfate from Area S ources on 20% worst days at Gila Wilderness 52 Figure 14 - Regional Contributions to Sulfate on 20% worst days at Pecos/Wheeler Park ......... 54 Figure 15 - Contributions to Sulfate from Area Sources on 20% worst days at Pecos/Wheeler Park .......................................................................................................................... ..................... 54 Figure 16 - Regional Contributions to Sulf ate on 20% worst days at Salt Creek ......................... 56 Figure 17 - Contributions to Sulfate from Area Sources on 20% worst days at Salt Creek ......... 56 Figure 18 - Regional Contribu tions to Nitrate on 20% wo rst days at Salt Creek ......................... 57 Figure 19 - Source Region/Type C ontributions to Nitrate on 20% worst days at Salt Creek ...... 57 Figure 20 - Regional Contributi ons to Sulfate on 20% worst days at White Mountain ............... 59 Figure 21 - Contributions to Sulfate from Area Sources on 20% worst days at White Mountain 59 Figure 22 - Regional Contributi ons to Nitrate on 20% worst days at White Mountain ............... 60 Figure 23 - Source Region/Type C ontributions to Nitrate on 20% worst days at White Mountain

............................................................................................................................... ........................ 60vi 

### A PPENDICES

Appendix A. Technical Support Document fo r Technical Products Pr epared by the Western Regional Air Partnership (WRAP) in Support of Western Regional Haze Plans, February 28, 2011 Appendix B. Review of Companion Rule s to New Mexico’s Regional Haze State Implementation Plan5 New Mexico Regional Haze Technical Support Document (TSD)

I. Relationship of this TSD to our Proposal

EPA is proposing to approve New Mexico State Implementation Plan (SIP) revisions submitted on July 5, 2011, and December 1, 2003, by the Governor of New Mexico addressing the regional haze requirements for the mandatory Class I areas under 40 CFR 51.309 and a separate submittal for the regional haze requirements under 40 CFR 51.309(g). EPA is not proposing any action on one component of the July 5, 2011 submittal, namely the NOx BART determination for the San Juan Generating Station (SJGS).

Our review of the 309 RH SIP submittal is supported by the review of companion regulations—regulations that th e RH SIP references and relies upon, that have also been submitted for SIP approval. Specifically, New Mexico submitted 20.2.81 NMAC, Western Backstop Sulfur Dioxide Trading Program, after initial adoption, on December 1, 2003, and thereafter submitted revisions with the State’s RH 309 SIP on July 5, 2011. We are proposing to fully approve 20.2.81 NMAC. We are also proposi ng to fully approve the following additional companion regulations: 20.2.65 NMAC, Smoke Management and 20.2.60 NMAC Open Burning , both—after their initial adoption—subm itted on December 1, 2003; and July 5, 2011 submitted revisions to 20.2.73.300.F NMAC, a subprovi sion of a previously approved rule that pertains to the “ Emission tracking requirements for sulfur dioxide emission inventories .” 1 These rules are also discussed in the notice for this actio n when they are relevant to our analysis of New Mexico’s RH 309 SIP submittal.

This TSD contains two a ppendices that support the propos al. Appendix A to this TSD contains a report describing our review of the emission inventory development and photochemical visibility modeling, performed by the WRAP. Appe ndix B to this TSD contains the analyses of the companion rules.

The 309(g) SIP submittal reviewed in this do cument serves as a supplement to NMED’s 309 SIP submittal. To comply with the requirements of 40 CFR 51.309(g), the State of New Mexico must submit a demonstration of reasona ble progress for the mandatory Class I Federal areas other than the 16 Class I areas covered by the GCVTC. The implementation plan must demonstrate the expected visibility conditions for the most and least impaired days at the additional Class I areas based on emission projections from the long-term strategies in the implementation plan. The implementation plan mu st contain provisions establishing reasonable

1 We previously approved 20.2.73 NMAC, including 20.2.73.300 NMAC, through our action at 75 FR 48860 (August 12, 2010). The state undertook other revisions of 20.2.73 NMAC in 2008, but they have not been submitted and they are unrelated to the minor revisions submitted for review in the 2011 SIP submission.6 progress goals and additional measures necessary to demonstrate reasonable progress for the additional Federal Class I areas. The RH SIP must address regiona l haze in each additional Class I area located within the State and in each additional Class I area located outside the State which may be affected by emissions from within the State. 40 CFR 51.309(g) requires that these provisions comply with 40 CFR 51.308(d)(1) through (4). In a ddition, pursuant to 40 CFR 51.309(d)(4)(vii), a section 309 SIP must contain a ny necessary long term strategies and BART requirements for PM and NOx. Any such BART provisions may be submitted pursuant to 40 CFR 51.308(e). Our Federal Register notice provide s details of our review and proposed decision regarding the additional requirements of 51.309 addressed in NMED’s 309 SIP submittal. Appendix B to this TSD contains our review of the companion rules referenced and relied upon by the NM RH 309 SIP submittal.

This TSD is not meant to be a complete rationale for the proposal. It merely provides additional information for some of the technical aspects of the basis for this proposal when needed. In some of the non-technical areas, the Fe deral Register notice provides more detail than does this TSD. Also, this TSD evaluates the requirements of section 51.308(d)(1)-(4) and 51.308(e) in the order in which they appear in that regulation, whereas our Federal Register notice groups the requirements into related areas so the concepts can be understood more easily. In this regard, the TSD can serve as a checklist of whether the requirements have been addressed. Lastly, the TSD attempts to refer the reader to the specific portions of the New Mexico RH 309(g) SIP submittal that we relied upon for our analysis of particular portions of section 51.309(g) and 51.309(d)(4)(vii).

This document often uses language such as, "we find ” or other similar phrases that on the surface would suggest a final dete rmination has been made. Howe ver, all aspects of the TSD should be considered to be pa rt of our proposal and are subj ect to change based on comments and other information received during the public comment period.

II. Background to Regional Haze

In Section 169A of the 1977 Amendments to the Clean Air Act (CAA), Congress set forth a program for protecting visibility in Fede ral Class I areas which calls for the “prevention of any future, and the remedying of any existing, impairment of vi sibility in mandatory Federal Class I areas which impairment results from manmade air pollution.” Congress adopted the visibility provisions to protec t visibility in 156 Federal Cla ss I areas, which include certain national parks, memorial parks, and wilderness areas over a certain size, and all international parks. These areas are define d at 40 CFR 81.400, are listed by State at 40 CFR 81.401-81.437, and are depicted in Figure 1. The nine Class I areas within New Mexico, are depicted in Figure 2. The San Pedro Parks Wilderness Area is one of the 16 Class I areas located on the Colorado7 Plateau. The requirements to address regional ha ze visibility impairment at these 16 Class I areas are established in 51.309 and are discus sed further in New Me xico’s Section 309 SIP submittal.

Figure 1 - Map of Class I Areas8 Figure 2 - Location of the Class I Areas in New Mexico

On December 2, 1980, we promulgated regulati ons to address visibility impairment that is “reasonably attributable ” to a single source or small group of sources. (45 FR 80084) These regulations represented the first phase in addre ssing visibility impairment and deferred action on regional haze that emanates from a variety of sources until monitoring, modeling and scientific knowledge about the relationships between polluta nts and visibility impairment improved.

In the 1990 Amendments to the CAA, Congre ss added Section 169B and called on us to issue Regional Haze rules. The RH rule that we promulgated on July 1, 1999 (64 FR 35713) revised the existing visibility regulations to integrate provisions addressing regional haze visibility impairment and establish a comprehensive visibility protection program for Federal Class I areas. These regulations represented the se cond phase in addressing visibility impairment. States were required to submit st ate implementation plans (SIPs) to us that set out each state’s plan for complying with the RH Rule, including consultation and coordination with other states and with Federal Land Managers (F LMs). States were required to submit a Regional Haze SIP to us within three years after the date of desi gnation of areas under th e National Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM 2.5 ). We promulgated PM 2.59 designations on December 17, 2004, and thus, regional haze SIPs were to be submitted to us by December 17, 2007, which is also sp ecified at 40 CFR 51.308(b).

The RH rule addressed the combined visibility effects of various pollution sources over a wide geographic region. Conseque ntly, all 50 states, including those without Class I areas, Washington, D.C., and the Virgin Islands, were required to submit Region al Haze SIPs (40 CFR 51.300(b)(3)). We designated five Regional Planning Organizations (RPOs) to assist with the coordination and cooperation needed to address the visibility issue, as shown by Figure 3.

Figure 3 - Map of Regional Plan ning Organization Boundaries

New Mexico, through the NMED joined st ate air agencies from Alaska, Arizona, California, Colorado, Hawaii, Idaho, Montana, New Mexico, North Da kota, Oregon, South Dakota, Utah, Washington, and Wyoming in fo rming the WRAP, in 1997 to implement the Grand Canyon Visibility Transport Co mmission’s recommendations to EPA 2 . WRAP also includes federally recognized Indian tribes located within the geogr aphic boundaries of its

2 Recommendations for Improving Western Vistas, Report of the Grand Canyon Visibility Transport Commission to the EPA, June 1996. Available at: http://www .wrapair.org/WRAP/repor ts/GCVTCFinal.PDF10 member states. The State of New Mexico and its agency, the NMED, chose to participate in the WRAP to develop the technical analyses needed to fulfill the requirements of the RH Rule.

III. Evaluation of State Submittal

In evaluating the New Mexico RH 309(g) SIP submittal, we reviewed all the parts of the document (excluding the NOx BART determination) , including the body of the SIP itself, and all appendices. In addition, we dr ew upon the following additional documents that may not have been specifically discussed in our TSD and/or the Federal Register publication(s) of our decision:

1. 40 CFR Part 51. 2. Appendix V to 40 CFR Part 51. 3. The “BART Guidelines ” in Appendix Y to Part 51—Guidelines for BART Determinations Under the Regional Haze Rule, 70 FR 39104, July 6, 2005. 4. Guidance for Tracking Progress Under the Regional Haze Rule, EPA-454/B-03-004, September, 2003. 5. Guidance for Demonstrating Atta inment of Air Quality Goals for PM 2.5 and Regional Haze, January 2, 2001. 6. Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule, EPA- 454/B-03-005, September 2003. 7. The “Baseline Memo,” which is entitled, “2002 Base Year Emi ssion Inventory SIP Planning: 8-Hour Ozone, PM2.5 and Re gional Haze Programs, da ted 11/18/2002, from Lydia Wegman to the Regional Air Directors. ” 8. Guidance for Setting Reasonable Progress Goals Under the Re gional Haze Program, dated June 1, 2007. 9. Visibility Monitoring Guid ance, EPA-454/R-99-003, June 1999. 10. Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air Quality Standards (NAA QS) and Regional Haze Regulations, EPA-454/R-05- 001, dated August, 2005. 11. Interim Air Quality Policy on Wildland and Prescribed Fires, April 23, 1998.

A. Identification of Affected Class I Areas: 40 CFR 51.308(d)

New Mexico must address regional haze in each additional mandatory Class I Federal area located within it and in each mandatory Clas s I Federal area located outside it which may be affected by emissions from within it.11 State Submittal: Chapter 3 and Section 12.2

The NMED is responsible for developing the Regional Haze SIP for New Mexico and submitting it to the New Mexico Environmental Im provement Board for approval. The State of New Mexico has nine federal Class I areas with in its borders. These are Bandelier Wilderness Area, Bosque del Apache National Wildlife Ref uge, Carlsbad Caverns National Park, Gila Wilderness, Pecos Wilderness, Salt Creek Wilderness, Wheeler Park Wilderness, White Mountain Wilderness and San Pedro Parks Wilder ness Area, which NMED has identified in its SIP. The San Pedro Parks Wilderness Area is one of the 16 Class I areas located on the Colorado Plateau. The requirements to address re gional haze visibility impairment at these 16 Class I areas are established in 51.309 and are discussed furthe r in New Mexico’s Section 309 SIP submittal.

NMED also determined that New Mexico emi ssions have a potential to impact visibility at Class I areas outside of New Mexico. New Mexico used baseline visibility data along with WRAP baseline modeling results to estimate Ne w Mexico’s emissions impact on neighboring state’s Class I areas. Section 12.2 of the NM RH 309(g) SIP submittal presents the contribution of New Mexico sources to nitrate and sulfate on the 20% worst days at the Class I areas in Colorado, Arizona, Nevada, Utah, Wyoming and Texas. New Mexico emissions are responsible for up to 60% of the nitrate and 43% of the sulf ate at individual Class I areas in neighboring states on the 20% worst visibility days during th e baseline period. The hi ghest impact from New Mexico sources at other State’s Class I area s occurs at Mesa Verde National Park and Weminuche Wilderness for both sulfate and nitrate.

Evaluation :

Table 1 below identifies the Class I area in each nearby state with the highest impact from New Mexico emissions for both nitrate and sulfate during the baseline period as found in Section 12.2 of the NM RH 309(g) SIP submittal. The percen tages shown are the percent of the total WRAP contribution to visibility impairment due to nitr ate or sulfate emissions in New Mexico. We note that some errors were discovered in section 12.2 a nd are corrected here based on data available at the WRAP Technical Support System (TSS) 3 . The highest impacts from New Mexico sources are found at the Class I areas near the San Juan Generating Station (SJGS). As discussed in the FIP ( Approval and Promulgation of Implem entation Plans; New Mexico; Federal Implementation Plan for Interstate Transport of Po llution Affecting Visibil ity and Best Available Retrofit Technology Determination , 76 FR 52388), the SJGS has signi ficant impacts on visibility conditions at a large number of surrounding Class I areas. Emissions reductions as a result of

3 WRAP technical products are available at http://vista.cira.colostate.edu/tss/12 implementation of NOx BART and the recent ad option of a permit limit of 0.15 lb/MMBtu for SO 2 , will lead to significant improvement in visibility conditions and a significant decrease in New Mexico’s contributions to vi sibility impairment at the Cla ss I areas in surrounding states by 2018

Table 1 - Percent of the WRAP contribution due to New Mexico em issions at Class I areas in surrounding states.

State Nitrate Sulfate

Most impacted Class I

area NM’s Contribution on the 20% worst days Most impacted Class I

area NM’s Contribution on the 20% worst days Arizona Petrified Forest 21% Chiricahua 11% Colorado Mesa Verde 60% Mesa Verde 43% Nevada Jarbridge 0% Jarbridge 1%

Utah Canyonlands 18% 4 Canyonlands 14%

Texas 5 Carlsbad Canyons/Guadalupe Mountains 15% Carlsbad Canyons/Guadalupe Mountains 4% 6

Wyoming Brooklyn Lake 3% Brooklyn Lake 4%

NMED has identified all the Class I areas with in the state as well as all Class I areas in neighboring states that may be aff ected by emissions from New Mexico.

B. Reasonable Progress Goals Development

B.1. Establishment of Reasonable Progress Goals: 40 CFR 51.308(d)(1)

For each additional mandatory Class I Federal area located within the state, New Mexico must establish goals (expressed in deciviews) that provide for reason able progress towards achieving natural visibility conditions. The reasonable progress goals must provide for an improvement in visibility for the most impaired days over the period of the SIP and ensure no degradation in visibility for the leas t impaired days over the same period.

State Submittal: Chapter 6 and Section 11.3

4 Corrected from 2% in Table 12-5 of the NM RH 309(g) SIP based on data from the WRAP TSS.
5 NM’s contribution to Carlsbad shown is the percenta ge of the combined contribution from WRAP, CENRAP and Mexico.

6 Corrected from 15% in Table 12-13 of the NM RH 309(g) SIP based on data from the WRAP TSS.13 Based on (1) the results of the WRAP CMAQ mo deling, (2) the results of the four-factor analysis of 3 New Mexico refineries and major source categories, and (3) the emission controls on New Mexico’s one BART source and other BART sources in nearby States, the 309(g) SIP submittal establishes reasonable progress goals for the most impaired days for the New Mexico Class I areas.

NMED relied on the 2018 projec ted visibility conditions fr om the WRAP photochemical modeling to establish RPGs for each Class I area. The WRAP’s projections for the 20% best and 20% worst days that represen t the RPGs for the 20% best and 20% worst days for the Class I areas in New Mexico are shown in Table 11-8 of the NM RH 309(g) SIP and reproduced below in Table 2.

Table 2 - Reasonable Progress Goals for 20% Wors t Days and 20% Best Days for New Mexico Class I Areas

Class I area 20% Worst Days 20% Best Days

Baseline

(dv) 2018 Uniform Progress Goal (dv) 2018 RPG (dv) Baseline (dv) 2018 RPG (dv)

Bandelier 12.22 10.83 11.9 4.95 4.89

Bosque del Apache 13.80 12.15 13.59 6.28 6.1

Carlsbad Caverns 17.19 14.73 16.92 5.95 6.12

Gila Wilderness 13.11 11.61 12.99 3.31 3.2
Pecos Wilderness,

Wheeler Park 10.41 9.40 10.23 1.22 1.12

Salt Creek 18.03 15.41 17.31 7 7.84 7.43

White Mountains 13.70 12.09 13.26 3.55 3.41

Evaluation:

The vehicle for ensuring continuing progress towa rds achieving the natural visibility goal is the submission of a series of RH SIPs from the states that establish two RPGs (i.e., two distinct goals, one for the “best” and one for the “w orst” days) for every Class I area for each implementation period. See 70 FR 39104; see also 64 FR 35714. 40 CFR 51.308(d)(1) requires

7 Corrected from 17.07 dv in the NM RH 309 (g) SIP Table 11-8 based on model projections data from the WRAP TSS for Salt Creek based on the PRP18b emission inventory. Model results using the PRP18a emission inventory project visibility impairment at Salt Creek to be 17.07 dv in 2018.14 that the reasonable progress goals must provide for an improvement in visibility for the 20% worst days and ensure no degradation of visibility on the 20% best days.

NMED established reasonable progress goals that show an improvement over baseline conditions on the 20% worst days at all 8 Class I areas. With th e exception of Carlsbad Caverns, all Class I areas also show no degr adation on the 20% best days.

For Carlsbad Caverns, NMED provided modeling data that demonstrat es that significant projected growth in emissions by 2018 from Me xico are responsible for the degradation in visibility conditions on the 20% best days at this Class I area (Sect ion 11.3.3 of the NM RH 309(g) SIP submittal). WRAP visibility modeling results with Mexico emissions held constant 8 from 2002 to 2018 show a slight improvement in vi sibility conditions at Carlsbad Caverns on the 20% best days. Baseline visibi lity conditions for the 20% best days at Carlsbad is 5.9 dv. Projected visibility conditions for 2018 is 6.1 dv using the em ission inventory that includes future growth in Mexican emissions, 9 but decreases to 5.8 dv when Mexico’s emissions are held constant at their 2002 levels. NM ED also provides results of th e Weighted Emissions Potential (WEP) analysis preformed by the WRAP that is based on emissions and residence time, rather than modeling. This analysis shows that the projected 2018 emissions of sulfur dioxide that potentially impact Carlsbad on the 20% best days from Mexico are much greater than emissions from other regions (See figures 11-3 and 11-4 of the submitted NM RH 309(g) SIP). NMED notes that IMPROVE Monitor data for the Ca rlsbad Caverns Class I area, however, shows improvement in visibility conditi ons on the 20% best days since the baseline period. Due to the high level of uncertainty in projected Mexico emissions, the monitored improvement, and the lack of jurisdictional control over these emissions, the submitted 309(g) SIP found this RPG for Carlsbad to be reasonable. We agree with this assessment.

Our analysis of the reasonable progress goals established by New Mexico is discussed in section B.4 below.

B.2. Reasonable Progress Goals Four Fa ctor Analysis: 40 CFR 51.308(d)(1)(i)(A)

Sections 51.309(g) and 51.308( d)(1)(i)(A) require that in establishing a reasonable progress goal for any mandatory Class I Federal area within New Mexico, NMED must consider

8 WRAP PRP18a emissions inventory. See the WRAP Regional Modeling Center - Simulation Specifications for the 2018 Prel iminary Reasonable Progress Simulation version A, prepared: 4/2/2007; Last revised 11/3/2008. Available in the docket for this action and at http://pah.cert.ucr. edu/aqm/308/cmaq.shtml
9 WRAP PRP18b emissions inventory. See the WRAP Regional Modeling Center - Simulation Specifications for the 2018 Prel iminary Reasonable Progress Simulation version B, prepared: 4/29/2009; Last revised 8/11/2009. Available in the docket for this action and at http://pah.cert.ucr. edu/aqm/308/cmaq.shtml15 the costs of compliance, the time necessary for compliance, the energy and non-air quality environmental impacts of compliance, and the rema ining useful life of a ny potentially affected sources, and include a demonstrati on showing how these factors were taken into consideration in selecting the goal.

State Submittal: Section 11.2, Appendix E, Appendix F

For SO 2, the State of New Mexico has addressed visibility impairment associated with this pollutant under the separate 309 SIP submitted to EPA. New Mexico’s participation in the SO 2 emissions milestone and backstop trading program will result in reductions in SO 2 emissions.

The WRAP hired EC/R Incorporated (EC/R) , headquartered in Chapel Hill, North Carolina, to complete the four factor analys is for specific source types throughout the WRAP region (Appendix E of the NM RH 309(g) SIP). The WRAP identified source categories of major emission sources for the WRAP states fo r analysis: Reciprocal Internal Combustion Engines and Turbines; Oil and Gas Explorati on and Production Field Operations; Natural Gas Processing Operations; Industrial Boilers; Cement Kilns; Sulfur ic Acid Manufacturing Plants; Pulp and Paper Lime Kilns; and Oil Refineri es. NMED did not identify any additional reductions in their evaluation of the WRAP anal ysis. In the RH 309(g) SIP submittal, NMED commits to conduct further research to eval uate non-BART sources for possible emission controls and retrofits for the next Plan update in 2013. 10

In addition, NMED also requested an additiona l analysis be done on specific sources in New Mexico. EC/R completed a four factor an alysis for three specific sources in New Mexico (Appendix F of the NM RH 309(g) SIP). Control measures for SO2 and NOx were evaluated for these selected sources in New Mexico.

The following facilities and emission sources in New Mexico we re evaluated: • Navajo Refining Co., Artesia Refinery – Fluid Catalytic Cracking Unit (FCCU) #1, catalyst regeneration and process heater; • Western Refining Southwest, Bloomfield Refinery – FCCU #1, catalyst regeneration and process heater; and • Western Refining Southwest, Ga llup Refinery – CO Boiler Unit #1

After evaluation of the four factors (Section 11.2.3 of the NM RH 309(g) SIP), the 309(g) SIP submittal includes a determination that due to th e controls currently installed at the FCCU at the Artesia Refinery and the low level of emissi ons, additional controls at this source are

10 For example, New Mexico is evaluating and testing control strategies for emissions associated with oil and gas exploration and production to incorporate in future SIP updates. Control options for ozone are being evaluated simultaneously and the State believes that many co-benefits from controlling emissions for ozone will supplement the regional haze program.16 unnecessary at this time. The Bloomfield Refine ry has been in suspended operations since November 2009. The Bloomfield FCCU is subject to NOx and SO 2 reductions according to the Catalyst Additive Program required by an Amended Stipulation and Final Order (AFSO) 11 as the result of an enforcement action. The 309(g) SIP submittal includes a determination that additional controls to address regional haze are not n ecessary at this source at this time due to the stringent emission limits already required by th e Catalyst Additive Program. The FCCU at the Gallup Refinery is also subject to the Catalyst Additive Program and was required to decrease FCCU NOx to 20 ppmvd and SO 2 to 25 ppmvd (both at 0% O2) by December 31, 2010. The boiler will meet an emission ra te of 0.04 lb/MMBtu after modifications including Low-NOx burners. The 309(g) SIP submittal includes a determina tion that additional controls at this source to address regional haze are unnecess ary at this time due to the stringent emission limits already required by the Catalyst Additive Program.

Evaluation :

The submitted 309(g) SIP includes an analysis th at considered the four statutory factors under 40 CFR 51.308(d)(1)(i)(A) to ev aluate the potential of c ontrolling certain sources or source categories for addressing visibility imp acts from man-made sources within its borders. The submitted 309(g) four factor analysis supports a finding of having met the general requirements under 40 CFR 51.308(d)(1)(i)(A).

B.3. Uniform Rate of Progress Determ ination: 40 CFR 51.308(d)(1)(i)(B)

In establishing a reasonable progress goal fo r any mandatory Class I Federal area within the State, New Mexico must analyze and determine the rate of progress need ed to attain natural visibility conditions by the year 2064. To calcu late this rate of progr ess, New Mexico must compare baseline visibility conditions to natural visibility conditions in the mandatory Federal Class I area and determine the uniform rate of vi sibility improvement (measured in deciviews) that would need to be maintained during each im plementation period in or der to attain natural visibility conditions by 2064.

State Submittal: Section 6.5

See Sections III.C.1 – C.2 of this TSD for a discussion on NMED’s calculations of baseline and natural visibility conditions. To cal culate the rate of progr ess needed to attain natural visibility conditions by the year 2064, also known as the Uniform Rate of Progress (URP), NMED compared baseline visibility conditions to natura l visibility conditions for the eight additional Class I areas and determined the linear rate of visi bility improvement (in deciviews) that would have to be maintained during each implementati on period in order to

11 NMED Stipulation and Final Order No. AQCA 02-09 (CO) and No. AQCA 05-22(CO), August 2, 200517 attain natural visibility conditi ons by 2064. The URP for each Class I area is shown in Table 6-6 of the NM RH 309(g) SIP and reproduced belo w in Table 3. A comparison of the 2018 RPG and the 2018 uniform rate of progress goal for 2018 is included in Table 2, above. NMED’s RPGs establish a slower rate of progress than the UR P for each Class I area. NMED has calculated the number of years it would take to attain natural visibility cond itions under the rate of progress selected by the State as reasonable, as shown in Table 3 below.

Table 3 - URP, RPG and Years to Natural Conditions for 20% worst days

Class I area Baseline (dv) Projected 2018 (RPG) Natural Conditions Uniform Rate of Progress

(dv/yr) Rate of Improvement

under RPG Years to Natural Conditions

Bandelier 12.22 11.9 6.26 0.099 0.0229 261

Bosque del Apache 13.80 13.59 6.73 0.118 0.0150 397

Carlsbad Caverns 17.19 16.93 6.65 0.176 0.0186 321

Gila Wilderness 13.11 12.99 6.66 0.108 0.0086 695

Pecos Wilderness,

Wheeler Park 10.41 10.23 6.08 0.072 0.0129 464

Salt Creek 18.03 17.33 6.81 0.187 0.0500 119

White Mountains 13.70 13.27 6.8 0.115 0.307 194

Evaluation:

We agree that NMED has analyzed and determin ed the rate of progress needed to attain natural visibility conditions by the year 2064. NMED construc ted the URP consistent with the requirements of the RH Rule and our 2003 Trac king Progress Guidance by plotting a straight graphical line from the baseline level of vi sibility impairment for 2000-2004 to the level of visibility conditions representing no anthropoge nic impairment in 2064. NMED has calculated this rate of progress, and compared baseline vi sibility conditions to natural visibility conditions and determined the URP needed to be maintained during each implementation period in order to attain natural visibility cond itions by 2064 for each Class I area in New Mexico. The submittal supports a finding that New Mexi co has appropriately calculate d the URP and satisfied the requirement in section 51.308(d)(1)(i)(B).

B.4 Analysis of Reasonable Progre ss Goal: 40 CFR 51.308(d)(1)(ii)-(iii)18 For the period of the SIP, if New Mexico establishes a reasonable progress goal that provides for a slower rate of improvement in visi bility than the rate th at would be needed to attain natural conditions by 2064, it must demonstrate, based on the factors in section 51.308(d)(1)(i)(A), that the rate of progress for th e SIP to attain natural conditions by 2064 is not reasonable; and that the progress goal adopted by it is reasonable. New Mexico must provide to the public for review as part of its SIP an assessment of the numb er of years it would take to attain natural conditi ons if visibility improvement continues at the rate of progr ess selected by it as reasonable.

In determining whether New Mexico’ goal for visibility improvement provides for reasonable progress towards natural visibility conditions, the Administrator will evaluate the demonstrations developed by it pursuant to Section 51.308(d)(1)(i) and (d)(1)(ii).

State Submittal: Chapter 6 and Section 11.3

Table 2, above, shows New Mexico’s RPGs for the 20% best and 20% worst days for 2018. NMED has calculated the numb er of years it would take to attain natural visibility conditions under the rate or progr ess selected by the State as r easonable, as shown in Table 3 above.

Sections 11.3.1 through 11.3.7 present NMED’s evaluation and demonstration that the established RPG at each Class I area is reasonable.

Based on (1) the results of the WRAP CMAQ mo deling, (2) the results of the four-factor analysis of 3 New Mexico refineries and major source categories, and (3) the emission controls on New Mexico’s one BART source and other BART sources in nearby States, the 309(g) SIP submittal establishes reasonable progress goals for the most impaired days for the New Mexico Class I areas. New Mexico believes the reason able progress goals it established for the New Mexico Class I areas on the 20% worst days are reasonable, and that it is not reasonable to achieve the glide path in 2018. In support of this conclusion, Ne w Mexico includes a discussion of the pollutant contributions and the sources of visibil ity impairment at each Class I area and compares the RPGs to the URP goal on a polluta nt specific basis (see Section 11.3 of the NM RH 309(g) SIP). The factors that New Mexico cons idered are summarized as: 1) For all of New Mexico’s Class I areas, the contribution to visibility impairment from organic mass carbon (OMC) and/or coarse mass (CM) from natural sour ces that cannot be controlled is significant. Section III.D.3 below discusses the sources of visi bility impairment at each Class I area and the percent contribution from OMC and CM; 2) Sources outside the modeling domain and in Mexico contribute significantly to nitrate and sulf ate at New Mexico’s Class I areas. Sources in Mexico are not under the control of New Mexico and are projected to increase by 2018. This increase restricts the amount of pr ogress achievable, particularly at those Class I areas located in19 Southern New Mexico. Section III.D.3 below discu sses the sources of visi bility impairment at each Class I area and the percent contribution from Mexico and out side the modeling domain; 3) Controls on oil and gas emission sources are being evaluated and are anticip ated to be in place over the next ten years. These emission reductions will allow for increased improvement in visibility conditions at those Class I areas located near oil and gas production regions in the State; and 4) Reductions due to NOx BART will further improve visibility at Class I areas.

Evaluation:

We evaluated the analysis provided by NMED along with the WRAP modeling results, WRAP emission inventories and other information in examining the RPGs established by NMED. We preliminarily reach the following conclusions:

• NMED’s analysis demonstrates that the predominant pollutants that affect the State’s ability to meet the URP goals are OMC, CM and sulfate (SO4). OMC and CM emissions are primarily from natura lly occurring wildfires and wind-blown dust. Figure 11-12 of the NM RH 309(g) SIP submittal identifies the source categories that contribute to emissions of OMC and CM that impact the State’s Class I areas. Over 70% of OMC emissions are due to natural fires. More than 65% of CM emissions are from wind-b lown dust. The State has developed Natural Event Action Plans that include measures to address anthropogenic sources of windblown dust during high wind events. However, windblown dust emissions that are both directly associat ed with anthropogenic activities and are controllable have a minimal effect on visi bility at New Mexico’s Class I areas compared to other sources of windblown dust. Because the State has limited ability to control these s ources of visibility impairment, OMC and CM emissions will continue to impact visibility at New Mexico’s Class I areas and limit the visibility improvement achievable duri ng the planning period. Because of the difficulty and uncertainty in estimating emissions of windblown dust and the limited ability to control these emissi ons, windblown dust emissions are held constant from 2002 to 2018. Other sources of CM including fugitive dust and road dust emissions are projected to in crease by 2018, however, these increases contribute to only a 4% incr ease in total CM emissions in 2018. We also note that because visibility modeling performance for CM was poor, projected CM visibility impacts for 2018 were kept at 2002 levels. 12

12 All CM relative response factors (RRF) were set to a va lue of 1 when projecting course matter visibility impacts to the future year 2018, regardless of the future year m odeling results. For more information see our review of the technical products developed by the WRAP that is available as Technical Support Document for Technical Products Prepared by the Western Regional Air Partnership (WRAP) in Support of Western Regional Haze Plans , EPA Regions 6, 8, 9, and 10, February 28, 2011, Appendix A to this TSD.20 • In addressing visibility impairment due to sulfate emissions we analyzed the emission inventories developed by the WR AP. We note that New Mexico seeks approval for participation in the SO 2 emissions milestone and backstop trading program that applies to all stationary sources that em it greater than 100 tpy of SO 2 and will result in emission reductions of SO 2 between 2002 and 2018. Our analysis of the WRAP emission inventor ies used in the photochemical modeling to project visibility conditions revealed an overe stimation of area source SO 2 emissions from New Mexico. In particular , emissions for Bernalillo County were much higher than current emissions and em ission trends would suggest (Figure 4). WRAP emission projections include a 200% increase in New Mexico’s statewide area source SO 2 emissions (Table 4), primarily in Bernalillo County, while no other WRAP state is projected to have an increase in area source SO 2 emissions greater than 50%. Bernalillo County emi ssion estimates reported to the National Emission Inventory are much lower th an those in the 2002 WRAP emission inventory and show a trend of decreasi ng emissions from 2002 to 2008, as shown in Table 5. In development of the 20 18 emission projections, WRAP used the EPA model EGAS to estimate growth for some area sources. This model can over predict area source growth by using a simple multiplier and does not take into account additional regulatory requirements, both federal a nd state, in the analysis. This over prediction in area source SO 2 emissions in New Mexico in the 2018 WRAP modeling results in overall less m odeled visibility improvement than would be anticipated with the much lower rate of growth in emissions anticipated by 2018 and overestimates the contribution of New Mexico emissions to visibility impairment at Class I areas in 2018. Furthermore, these SO 2 emissions are also overestimated in the 2002 emission inventor y and leads to an overestimate of the contribution of New Mexico emissions to vi sibility impairment at Class I areas in 2002. Detailed information on the source apportionment modeling for SO 2 area source emission at each Class I area can be found below in Section III.D.3.21 Figure 4 – Sulfur Oxide Emissions by County for 2002 and 2018

Table 4 -WRAP Area Source SO2 Emissions (tpy) 2002 2018 growth Percent growth

AZ 3043.95 3899.98 856.03 28%

CA 10090.03 10712.93 622.9 6%

CO 6533.08 7644.26 1111.18 17%

ID 3279.58 3538.76 259.18 8%

MT 3236.47 3580.16 343.69 11%

ND 5556.82 5995.12 438.3 8%

NM 5433.49 16285.02 10851.53 200%

NV 13037.35 14280.3 1242.95 10%

OR 10308.39 8889.35 -1419.04 -14%
SD 1197.93 1788.52 590.59 49%

UT 3449.09 3596.65 147.56 4%

WA 8077.2 9399.32 1322.12 16%

WY 16874.26 23331.12 6456.86 38%22 Table 5 – Comparison of Bernalillo County Emission Estimates to WRAP Bernalillo County Emissions 13 WRAP emissions 2002 2005 2008 2002 2018 NOx 24930.6 23231.3 13570.9 33856.36 26878.08 SO2 1574.9 1594.9 261.1 4996.01 14073.54

• Contributions of NOx and SO2 from Mexi co point sources are also significant and are anticipated to increase by 201 8. These emissions are not under the jurisdiction of NMED and will limit the rate of progress achievable on the 20% worst days. For the 20% best days, growth in emissions from Mexico results in a slight projected degradation in visibility conditions at the Carlsbad Caverns Class I area. We note that monitored data shows that visibil ity conditions have improved at this area from the baseline period.

• The San Juan Generating Station is by far the largest point source of NOx and SO 2 emissions under NMED jurisdiction. Due to reductions required by the consent decree and by the implementation of BART, significant reductions in SO 2 and NOx emissions from 2002 values will occur. Implementation of NOx BART will result in more reductions than those included in the WRAP 2018 modeling. The FIP limits NOx emissions to 0.05 lb /MMBtu, resulting in an approximate 83% reduction in NOx from the emission limit the facility is currently complying with (0.3 lb/MMBtu). We note th at NMED’s submitted NOx BART determination though not under review for th is proposal and not legally effective unless it is approved would require contro l rates below the future year projected NOx emissions for the source developed in the WRAP consultation process. The reductions at the SJGS achieved in compliance with the existing federal implementation plan or anticipated due to any other future-approved NOx BART determination consistent with the RH R requirements will result in greater visibility improvements than projected in the WRAP visibility modeling relied upon to establish the reasonable progre ss goals included in the 309(g) SIP submittal. Through the WRAP consultation process, New Mexico provided the anticipated future year projected NOx emissions from the SJGS to be 0.27 lb/MMBtu for units 1 and 3 and 0.28 lb/ MMBtu for units 2 and 4. These values were used in the 2018 emission invent ory and the WRAP modeling used to determine the RPGs. Consequently, imple mentation of NOx BART at the SJGS will result in greater reasonable progress than is anticipated in the analysis included in the NM RH 309(g) SIP submittal.

• In addition to NOx BART at SJGS, NOx reductions at another large power plant within the State (Four Corners Power Plant) that lies on tribal lands, outside of the

13 Appendix 2010-B of the City of Albuquerque – Bernalillo Co unty Regional Haze SIP submittal23 jurisdiction of NMED, are anticipated as the result of a BART determination that is part of a FIP. These two BART determ inations represent significant reductions in NOx emissions at the largest emi ssion sources within the State.

Based on the above considerations, we would agree with New Mexico’s conclusion that it is not reasonable to meet the uniform rate of progress for its Class I areas, and we recommend approval of New Mexico’s analys is and reasonable progress goals . There is sufficient support to determine that no further contro ls are warranted to meet the requirements of 40 CFR 308(d)(1). In setting its RPGs for its Class I areas for th e 20% worst days, New Mexico relied on certain NOx emission reductions at the SJGS that may underestimate the reduc tions to be achieved. NOx BART is an element of the long term strate gy necessary to achieve the reasonable progress goals. Whether the existing federal implementati on plan or another future-approved NOx BART determination consistent with the RHR requirement s is in place, we expect the state to include any corrections and updates to emission reductions in its next Regional Haze SIP with updated modeling to quantify the visibi lity improvement that result s from all emission reduction measures in place by 2018.

B.5 Reasonable Progress State Cons ultation : 40 CFR 51.308(d)(1)(iv)

In developing each reasonable progress goal, New Mexico must consult with those States which may reasonably be anticipated to cause or contribute to visibili ty impairment in the mandatory Class I Federal area. In any situ ation in which New Mexi co cannot agree with another such State or group of States that a goal provides for reasonable progress, New Mexico must describe in its submittal the actions taken to resolve the disagreeme nt. The Administrator will take this information, if available, into acco unt in determining whether its goal for visibility improvement provides for reasonable progr ess towards natural visibility conditions.

State Submittal:

NMED relied on the WRAP as its main vehicle for facilitating collaboration with FLMs and other states in developing its RH 309 SI P. NMED was able to use WRAP generated products, such as regional photochemical modeling results and visibility projections, and source apportionment modeling to assist in identifying nei ghboring states’ contributions to the visibility impairment at New Mexico’s Class I areas. Th e technical analyses a nd emission inventories developed by the WRAP are documented in the WRAP TSD and available online at the WRAP Technical Support System. 14,15

14 http://vista.cira.colostate.edu/tss/24 New Mexico consulted through the WRAP, a nd relied on the technical tools, policy documents, and other products that all Western stat es used to develop thei r regional haze plans. The WRAP Implementation Work Group was one of the primary collaboration mechanisms. All the states relied upon similar emission inventorie s, results from source apportionment studies and BART modeling, review of IM PROVE monitoring data, existi ng state smoke management programs, and other information in assessing th e extent to which each state contributes to visibility impairment in other states’ Class I areas. 40 CFR 51.308(d)(3 )(ii) of the Regional Haze Rule requires a state to demonstrate that its regional haze plan includes all measures necessary to obtain its fair sh are of emission reductions needed to meet reasonable progress goals. Based on the consultation describe d above, New Mexico identified no major contributions that supported developing new in terstate strategies, mitigation measures, or emission reduction obligations. New Mexico dete rmined that the implementation of BART and other existing measures in state regional haze pl ans were sufficient for the states to meet the reasonable progress goals for their Class I areas, a nd that future consultation would address any new strategies or measures needed, and all stat es participating in the consultations agreed.

Evaluation:

The submitted SIP supports a finding that Ne w Mexico has satisfied the requirement under sections 51.309(g) and 51.308(d)(1)( iv) to consult with other st ates that may reasonably be anticipated to cause or contribu te to visibility impairment at New Mexico’s Class I areas.

B.6 Reasonable Progress Goal To Be Consid ered by Administra tor: 40 CFR 51.308(d)(1)(v)

The language under Section 51.308(d)(1)(v), “The reasonable progre ss goals established by the State are not directly enforceable but will be considered by the Administrator in evaluating the adequacy of the measures in th e SIP to achieve the pr ogress goal adopted by the State,” is a statement relating to our review of RH SIPs. Since it does not require a response from the state, it is not separately evaluated here.

B.7 Reasonable Progress Goal Min imum: 40 CFR 51.308(d)(1)(vi)

15 Technical Support Document for Technical Products Prepared by the Western Regional Air Partnership (WRAP) in Support of Western Regional Haze Plans , EPA Regions 6, 8, 9, and 10, February 28, 2011, Appendix A to this TSD.25 New Mexico may not adopt a reasonable prog ress goal that represen ts less visibility improvement than is expected to result from im plementation of other requirements of the CAA during the applicable planning period.

State Submittal: Chapter 9

The RPGs established by New Mexico ar e based on WRAP 2018 m odeling projections. The modeling projections conducted by WRAP contai n projections of the visibility conditions that are anticipated to be realized at each Class I area between the 2002 base year and the 2018 future year. These projections are based on an assessment of the visibility improvements associated with local, State, and federal control pr ograms that are either curre ntly in effect or will take effect with mandated future-year emi ssion reduction schedules, as well as on BART emission limitations established to date.

Evaluation:

NMED’s RPGs are based on the visibility improvement predicted by WRAP’s modeling projections to take place between the baseli ne year and 2018. Since WRAPS’s 2018 modeling projections are based on local, St ate, and federal control programs that are either currently in effect or with mandated future-year emission re duction schedules, NMED’s RPGs represent at least as much visibility improvement as is expe cted to result from implementation requirements of the CAA during the applicable planning peri od. The submittal supports a finding that New Mexico has met this requirement.

C. Baseline and Natural Visibility Conditions

Note: 40 CFR 51.308(d)(2) (ii) is not applicable si nce this SIP was submitted after 2003, and 40 CFR 51.308(d)(2)(iv)(B ) is not applicable since this is the first SIP period.

C.1. Calculation of Baseline Co nditions: 40 C FR 51.308(d)(2)(i)

For each additional mandatory Class I Federal area located within New Mexico, the State must determine the baseline visibility conditions for the most impaired and least impaired days. The period for establishing baseline visibility conditions is 2000 to 2004. Baseline visibility conditions must be calculated, using available monitoring data, by establishing the average degree of visibility impairment for the most and least impaired days for each calendar year from 2000 to 2004. The baseline visibility conditions are the average of these annual values. For mandatory Class I Federal areas without ons ite monitoring data for 2000–2004, New Mexico26 must establish baseline values using the most representative available monitoring data for 2000– 2004, in consultation with the Admini strator or his or her designee.

State Submittal: Section 4.1, 6.1 and 6.3

Section 4.1 of the NM RH 309g SIP provide s an overview of the IMPROVE network, describes the metrics used to describe visibil ity impairment, and details the revised IMPROVE equation utilized to estimate light extinction.

Baseline conditions represent visibility for the best and worst days at the time the regional haze program is established. Ba seline conditions are calculated using multiyear averaging of the 20 percent of monitored days wi th the highest (most impaired, or worst days) and the 20 percent of monitored days with the lowest (least impaired, or best days) light extinction values, expressed in deciviews (dv), for the years 2000 through 2004. The RHR establishes the deciview (dv) as the principal metric for measuring visibility. See 70 FR 39104. A deciview is a uniform measure of light extinct ion caused by regional haze. This visibility metric expresses uniform changes in the degree of haze in terms of common increments across the entire range of visibility conditions, from pristine to extremely hazy conditions. The deciview scale approaches zero for no visibility degradation and increases as visibility is degraded. The deciview scale was designed simila r to the decibel scale for sound, so that equal changes in deciview are equally perceptible. The deciview is a useful measure for tracking progress in improving visibility, b ecause each deciview change is an equal incremental change in visibility perceived by the human eye. Most people can detect a change in visibility of one deciview. Common current values in the west are 15 to 20 dv; common current values in the east are 25 to 30 dv. Visibility is also sometimes e xpressed in terms of the visual range, which is the greatest distance, in kilometers or miles, at which a dark object can just be distinguished against the sky.

The baseline is the starting point for this regional haze submittal, against which progress toward the national visibility goal is measure d. NMED calculated its baseline conditions in accordance with our 2003 Natural Visibility Guidance, 16 as required by the RHR. The baseline condition calculation begins w ith the calculation of light extinction, using the IMPROVE equation. The IMPROVE equation sums the light ex tinction resulting from individual pollutants, such as sulfates and nitrates.

In 2005, the IMPROVE Steering Committee made recommendations for a refined equation that modifies the terms of the original equation to account for the most recent data. The

16 Guidance for Estimating Natural Vi sibility Conditions Under the Regiona l Haze Program, EPA-454/B-03-005, September 2003.27 purpose of this refinement is to provide more accura te estimates of the various factors that affect the calculation of light extinction. The new IMPROVE equation estimates additive extinction coefficients for each of several chemical constituents of partic ulate matter: sulfurous, nitrate, organic carbonaceous, elemental “ light-absorbing” carbonaceous, fine soil, chlorine or chloride, and coarse matter. The equation also account s for Rayleigh scattering of light and for deliquescence on sulfurous, nitrate, and chlorine or chloride partic ulates with an estimate of particle-bound water as a function of relative humidity. It reflects the most recent review of the science 17 and it accounts for the effect of particle size distribution on light extinction efficiency of sulfate, nitrate, and organic carbon. It also adjusts the mass multiplier for organic carbon (particulate organic matter) by increasing it from 1.4 to 1.8. New terms are added to the equation to account for light extinction by sea salt and li ght absorption by gaseous nitrogen dioxide. Sitespecific values are used for Rayleigh scattering (s cattering of light due to atmospheric gases) to account for the site-specific effects of elevati on and temperature. Separate relative humidity enhancement factors are used for small and larg e size distributions of ammonium sulfate and ammonium nitrate and for sea salt. The terms for the remaining contributors, elemental carbon (light-absorbing carbon), fine soil, and coarse ma ss terms, do not change between the original and new IMPROVE equations.

As with the natural visi bility conditions cal culation, NMED chose to use the new IMPROVE equation. The choice between use of th e old or the new equation for calculating the visibility metrics for each Class I area is made by the state in which the Class I area is located. NMED has chosen to use this new equation fo r calculating both the baseline and natural visibility conditions because it takes into acc ount the most recent revi ew of the science and because it is recommended by the IMPROVE Steering Committee.

New Mexico has established baseline visibility for the best and worst visibility days for each additional Class I area using on-site data fr om the IMPROVE monitoring sites. A five-year average (2000-2004) was calculated for each value (both best and worst). The calculations were made in accordance with 40 CFR 51.308(d)(2) and EPA's Guidance for Tracking Progress Under the Regional Haze Rule (EPA-454/B-03- 004, Se ptember 2003). Monitors for Bandelier, Guadalupe Mountains (representativ e of Carlsbad), and Gila Wilderness were installed between

17 Information regarding the science behind the revised IMPROVE equation can be found in numerous published papers. See for example: Hand, J.L., and Malm, W.C., 2006, Review of the IMPROVE Equation for Estimating Ambient Light Extinction Coefficients - Final Report . March 2006. Prepared for Interagency Monitoring of Protected Visual Environments (IMPROVE), Co lorado State University, Cooperativ e Institute for Research in the Atmosphere, Fort Collins, Colorado. http://vista.cira.colostate.edu/improve/publicatio ns/GrayLit/016_IMPROVEeqR eview/IMPROVEeqReview.htm ; and Pitchford, Marc., 2006 , Natural Haze Levels II: Application of th e New IMPROVE Algorithm to Natural Species Concentrations Estimates . Final Report of the Natural Haze Levels II Committee to the RPO Monitoring/Data Analysis Workgroup. September 2006 http://vista.cira.colostate. edu/improve/Publications/GrayLit/029_Nat uralCondII/naturalhaz elevelsIIrenatu.ppt28 1988 and 1994. New monitors were established at Bosque del Apache, Salt Creek and Wheeler Peak (representative of both Wheeler Peak and Pecos Wilderness) in mid-2000. The monitor at White Mountain Wilderness began operation in early 2002. The calculated baselines are based on the available data at each IM PROVE site over the 2000-2004 period.

NMED calculated the baseline by first summi ng the light extinction (where the extinction coefficient is expressed in Mm-1) for sulfate, nitrate, organic carbonaceous, elemental “lightabsorbing” carbonaceous, fine soil, chlorine or chloride, and coarse matter, using the following equation:

β ext = β ext S + β ext NO3 + β ext organic + β ext elemental + β ext Soil + β ext coars e+ β ext Cl + β ext Rayleigh

NMED then converted the total light extinc tion values to deciviews (dv), using the Haze Index (HI) equation:

HI (dv) = 10 ln[ β ext/(10 Mm -1 )]

Table 6 (Taken from Table 6-1 of the NM RH 309g SIP) shows th e baseline conditions for each IMPROVE monitor site in New Mexico.

Table 6 - Baseline Conditions fo r 20% W orst and 20% Best Day s

Mandatory Federal Class I Area IMPROVE Monitor Baseline Conditions for 20% Worst Visibility Days (dv) Baseline Conditions for 20% Best Visibility Days (dv)
Bandelier Wilderness BAND1 12.22 4.95 Bosque del Apache NWR BOAP1 13.8 6.28

Carlsbad Caverns NP GUMO1 17.19 5.95 Gila Wilderness GICL1 13.11 3.31 Pecos Wilderness, Wheeler Peak Wilderness WHPE1 10.41 1.22

Salt Creek Wilderness SACR1 18.03 7.84 White Mountain Wilderness WHIT1 13.7 3.55

Evaluation:

The submittal supports a finding that NMED adequa tely utilized the data at their disposal and adequately calculated baseline conditions for the eight additional Class I areas in New Mexico.29 C.2. Calculation of Natural Visibili ty Conditions: 40 CFR 51.308(d)(2)(iii)

For each additional mandatory Class I Federa l area located within the State, the State must determine the natural visibility conditions for the most impaired and least impaired days. Natural visibility conditions must be calculated by estimating the degree of visibility impairment existing under natural conditions for the most impaired and least impaired days, based on available monitoring information and appr opriate data analysis techniques.

State Submittal: Section 6.4

Natural background visibility, as define d in our natural visibility guidance ( Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule;EPA-454/B-03-005, September 2003) , is estimated by calculating the expected light extinction using default estimates of natural concentrations of fine particle co mponents adjusted by site-specific estimates of humidity. The natural condition for each Class I ar ea represents the visibility goal expressed in deciviews for the 20% worst visibility days and th e 20% best visibility da ys that would exist if there were no naturally or anthropogenic impairment. The 20% worst days natural conditions correspond to the visibility goals for each Class I area to be reached by 2064 [40 CFR 51.308(d)(iii)].

As documented in the natural visibility guida nce, we allow states to use “refined” or alternative approaches to 2003 EPA guidance to estimate the values that characterize the natural visibility conditions of Class I ar eas. One alternative approach is to develop and justify the use of alternative estimates of natural c oncentrations of fine particle co mponents. Another alternative is to use the new IMPROVE equation. The purpose of this refinement to the original IMPROVE equation is to provide more accurate estimates of th e various factors that a ffect the calculation of light extinction.

As with the calculation of baseline conditions, NMED chose to use the new IMPROVE equation as the basis for its refined estimate becau se it takes into account the most recent review of the science and because it is recommended by the IMPROVE Steering Committee, combined with the default estimates for the natural conditio ns. Table 7 below (taken from Table 6-3 of the NM RH 309(g) SIP) shows the natural visibility condition goals for the 20% worst and 20% best days.

Table 7 - 2064 Natural Conditions Go al for 20% W orst and Best Days

Mandatory Federal Class I Area IMPROVE Monitor 2064 Natural Conditions for 20% Worst Visibility Days (dv) 2064 Natural Conditions for 20% Best Visibility Days (dv)
Bandelier Wilderness BAND1 6.26 1.29 Bosque del Apache NWR BOAP1 6.73 2.1630 Carlsbad Caverns NP GUMO1 6.65 0.99 Gila Wilderness GICL1 6.66 0.52 Pecos Wilderness, Wheeler Peak Wilderness WHPE1 6.08 -0.57

Salt Creek Wilderness SACR1 6.81 2.12 White Mountain Wilderness WHIT1 6.8 0.66

Evaluation: /The submittal supports a finding that New Mexico has met this requirement.

C.3. Natural Visibility Impairment: 40 CFR 51.308(d)(2)(iv)(A)

For the first SIP addressing the requirements of 51.308(d) and (e) of this section, New Mexico must calculate the number of decivi ews by which baseline conditions exceed natural visibility conditions for the most im paired and least impaired days.

State Submittal: Table 6-5

As discussed in section III.C.1 and C.2 of this TSD, NMED calculated the baseline and natural conditions on the 20%worst days and 20% best days. The amount of visibility impairment can be calculated by subtracting th e natural visibility condition values from the baseline values.

As displayed in Table 6-5 of the NM RH 309(g) SIP and recreated below as table 8, NMED calculated the number of deciviews by which baseline conditions exceed natural visibility conditions for the most impaired (20% worst) days a nd the least impaired (20% best) days for each Class I area31 Table 8- Baseline and Natural Visibility Conditions at New Mexico’s Class I Areas

Class I area IMPROVE Monitor 2064 Natural Visibility Conditions (dv) Baseline Visibility Conditions (dv) Difference (dv)

20% Worst Days 20% Best Days 20% Worst Days 20% Best Days 20% Worst Days 20% Best Days

Bandelier BAND1 6.26 1.29 12.22 4.95 5.96 3.66

Bosque del Apache BOAP1 6.73 2.16 13.80 6.28 7.07 4.12

Carlsbad Caverns GUMO1 6.65 0.99 17.19 5.95 10.54 4.96

Gila Wilderness GICL1 6.66 0.52 13.11 3.31 6.45 2.79

Pecos Wilderness,

Wheeler Park WHPE1 6.08 -0.57 18 10.41 1.22 4.33 1.79

Salt Creek SACR1 6.81 2.12 18.03 7.84 11.22 5.72

White Mountains WHIT1 6.8 0.66 13.70 3.55 6.90 2.89

Evaluation: The submittal supports a finding that New Mexico has met this requirement.

D. Long Term Strategy: 40 CFR 51.308(d)(3)

New Mexico, as with each State listed in section 51. 300(b )(3), must submit a long-term strategy that addresses regional haze visibility impairment for each additional mandatory Class I Federal area within the state and for each mandatory Class I Federal area located outside the state which may be affected by emissions from within the state. The long-term strategy must include enforceable emissions limitations, compliance sc hedules, and other measures as necessary to achieve the reasonable progress goals established by States ha ving mandatory Federal Class I

areas.

State Submittal: Chapter 12

The LTS is a compilation of state-specific control measures relied on by New Mexico for achieving its RPGs. New Mexico LTS for the first implementation period addresses the emissions reductions from federal, state, and local controls that take effect in the state from the end of the baseline period starting in 2004 until 2018. The New Mexico LTS was developed by NMED, in coordination with the WRAP RP O, through an evaluation of the following

18 Negative deciview values correspond to total extinction less than 10 Mm -1 , and can occur in areas of high elevation with lower Rayleigh Scattering, WHPE 1 is located at an el evation of 11,000 ft32 components: (1) construction of a WRAP 2002 baseline emission inventory; (2) construction of a WRAP 2018 projected emissi on inventory, including reductions from WRAP member state controls required or expect ed under federal and state regul ations (including BART); (3) modeling to determine visibility improvement and apportion individual state contributions; (4) state consultation; and (5) application of the LTS factors. The State’s deta iled long-term strategy is included in Chapter 12 of the NM RH 309(g) SIP.

Evaluation:

Our evaluation regarding whether the New Me xico submission supports a finding that it has met the long term strategy requirements under section 51.308(d)(3) is discussed under section III.D.1-D.4.

D.1 Long Term Strategy State Cons ultation: 40 CFR 51.308(d)(3)(i)

Where New Mexico has emissions that are reasonably anticipated to contribute to visibility impairment in any mandatory Class I Fede ral area located in another State or States, it must consult with the other State(s) in orde r to develop coordinate d emission management strategies. New Mexico must c onsult with any other State havi ng emissions that are reasonably anticipated to contribute to visibi lity impairment in any mandatory Class I Federal area within it.

State Submittal: Chapter 2, Chapter 12

As in the development of New Mexico’s re asonable progress goals for its Class I areas, NMED used the WRAP as its main vehicle for facilitating collaborati on with FLMs and other states in satisfying its LTS consultation requ irement. This helped NMED and other state environmental agencies analyze emission a pportionments at Class I areas and develop coordinated RH SIP strategies.

NMED’s consultations with other states ar e described in section III.B.5 above. As already discussed elsewhere, NM neither reque sted additional emission reductions from other states, nor made a commitment to other stat es for additional emission reductions beyond the coordinated emission management strategies de veloped through the WRAP consultation process and factored in the WRAP’s 2018 visibility pr ojections using photochemical grid modeling. New Mexico determined that the implementation of BART and other existing measures in state regional haze plans were sufficient for the states to meet the reasonable progress goals for their Class I areas, and that future consultation would address any new strategies or measures needed. All states participating in NM’s consulta tion process agreed with this decision.33 Evaluation:

The submittal supports a finding that New Mexi co satisfies the consultation requirements of 40 CFR 51.308(d)(3)(i).

D.2 Share of Reductions in Other States’ Progress Goals: 40 CFR 51.308(d)(3)(ii)

Where New Mexico causes or contributes to impairment in a mandatory Class I Federal area, it must demonstrate that it has included in it s SIP all measures necessary to obtain its share of the emission reductions needed to meet the progress goal for the area. If New Mexico has participated in a regional planning process, it must ensure it has included all measures needed to achieve its apportionment of emission reduction ob ligations agreed upon through that process.

State Submittal: Chapter 2, Chapter 12

In developing its Regional Haze SIP and RPGs, New Mexico and potentially impacted states collaborated through the WRAP. New Me xico developed its RH Plans and RPGs based on WRAP modeling. New Mexico consulted through the WRAP, and relied on the technical tools, policy documents, and other products that all West ern states used to de velop their regional haze plans. The WRAP Implementation Work Gr oup was one of the primary collaboration mechanisms. All the states relied upon simila r emission inventories, results from source apportionment studies and BART modeling, review of IMPROVE m onitoring data, existing state smoke management programs, and other informati on in assessing the extent to which each state contributes to visibility impairment in other states’ Class I areas. Based on the consultation described above, New Mexico identified no major contributions that supported developing new interstate strategies, mitigation measures, or emission reduction obligations. New Mexico determined that the implementation of BART an d other existing measures in state regional haze plans were sufficient for the states to meet the reasonable progress goals for their Class I areas, and that future consultation woul d address any new strategies or measures needed, and all states participating in the consultations agreed.

Evaluation:

As we state in the RHR, 19 New Mexico’s commitments to participate in the WRAP bind it to secure emission reductions agre ed to as a result of that proce ss, unless it proposes a separate process and performs its consultations on th e basis of that process. See 64 FR 35735.

19 64 FR 35735.34 While States are not bound by the results of a regional planning effort, nor can the content of their SIPs be dictated by a regi onal planning body, we expect that a coordinated regional effort will likely produce results the States will find beneficial in developing their regional haze implementation plans. Any State c hoosing not to follow the recommendations of a regional body would need to provide a specific technical basis that its strategy nonetheless provides for reasonable progress based on the stat utory factors. At the same time, we cannot require States to participate in regional planning efforts if th e State prefers to develop a longterm strategy on its own. We note that any State that acts alone in this regard must conduct the necessary technical support to ju stify their apportionment, which generally will require regional inventories and a regional modeling analysis. A dditionally, any such State must consult with other States before submitting its long-term strategy to EPA.

Consequently, because New Mexico accepted and incorporated the WRAP-developed visibility modeling into its RH SIPs, and th e 2011 submitted RH SIP proposes controls more stringent than those assumed in the modeling, Ne w Mexico satisfied the Regional Haze Rule’s requirements for including controls in the SIP sufficient to address the relevant requirements of the Regional Haze Rule related to impacts on Cla ss I areas in other states. The submittal, in conjunction with the NOx BART determination u nder the FIP or any replacement that may be approved as being consistent with Regional H aze Rule, supports a finding that the requirements of section 51.308(d)(3)(ii) have been met.

D.3 Technical Basis for the Long Term Strategy: 40 CFR 51.308(d )(3)(iii) – (iv)

New Mexico m ust document the technical basis, including modeling, monitoring and emissions information, on which the State is rely ing to determine its a pportionment of emission reduction obligations necessary for achieving r easonable progress in each mandatory Class I Federal area it affects. It may meet this requirement by relying on technical analyses developed by the regional planning organi zation and approved by all State participants. New Mexico must identify the baseline emissions inventor y on which its strategies are based.

New Mexico must also identify all anthr opogenic sources of visibility impairment considered by the State in developing its long -term strategy. It should consider major and minor stationary sources, mobile sour ces, and area sources. New Mexico addressed these requirements by relying on technical analyses developed by its RPO, WRAP and approved by all state participants, as described below. The followi ng discussion of emission inventories for the 2002 base and 2018 future year, 2002 and 2018 photochemi cal modeling results, a nd our review of the35 results is a summary of the work that was done and our conclusions. A detailed review of the technical products developed by the WRAP is available as Appendix A to this TSD 20

.
D.3.a Emissions Inventory

State Submittal: Chapter 8, Appendix A

The em issions inventory used in the RH technical analyses was developed by WRAP with assistance from New Mexico using approv ed EPA methods. Emissions within New Mexico are both naturally occurring and man-made. Tw o primary sources of naturally occurring emissions in New Mexico include wildfires a nd windblown dust. An em issions inventory for each visibility impairing pollutant was develo ped by WRAP for New Mexico for the baseline year 2002 and for 2018, which is the first reasonab le progress milestone. NMED and the WRAP developed an emission inventory for anthropogenic sources (point, stationa ry area, mobile, road dust, prescribed and agricultural fire) as well as other sources for the baseline year of 2002. See Chapter 8 and Appendix A of the NM RH 309(g) SIP submittal and Appendix A of this TSD for details on how the 2002 emissions inventory was constructed. The 2018 emissions inventory was then developed by projecting the 2002 emissions to 2018 and applying reductions expected from federal and state regulations affecting the emi ssions of the visibility -impairing pollutants NO x , SO 2, , volatile organic compounds (VOCs), primar y organic aerosol (POA), elemental Carbon (EC), fine particulate matter (Soil – PM 2.5 ), CM, and ammonia (NH 3 ).

D.3.a.i New Mexico’s 2002 Emission Inventory

New Mexico 2002 emissions inventor y is summarized in Table 9:

Table 9 - New Mexico’s 2002 Emissions I nventory (including Bernalillo County)

Source Category SO 2 NOx VOCs POA EC Soil CM NH3
Point 37918 100398 17574 978 13 1180 2286 75
Anthro Fire 94 3396 608 682 123 87 105 75
Natural Fire 2729 8613 18846 16272 3293 1223 5400 1875 Biogenic 0 42139 1016487 0 0 0 0 0
Area 5433 25140 49010 2529 301 2821 695 29959
WRAP Area O&G 250 56210 224268 0 0 0 0 0
On-Road Mobile 2066 67835 38768 653 756 0 403 2132
Off-Road Mobile 3846 45311 13580 563 1526 0 0 26
Road Dust 4 1 0 114 9 1305 11074 0

20 Technical Support Document for Tech nical Products Prepared by the Wester n Regional Air Partnership (WRAP) in Support of Western Regional Haze Plans, February 28, 201136 Fugitive Dust 6 7 0 360 24 6751 51533 0
Wind Blown Dust 0 0 0 0 0 16399 147589 0
Total 52347 346050 1379410 22151 6046 29765 219086 34141

D.3.a.ii New Mexico’s 2018 Emission Inventory

In general, NMED used a combination of our Economic Growth Analysis System (EGAS 5), our mobile emissions factor model (MOBILE 6), our off-road emissions factor model (NONROAD), and the Integrated Planning Mode l (IPM) for electric generating units in constructing its 2018 emission inventory. More sp ecifically, the WRAP developed emissions for a number inventory source classifications: point, area, non-road and on-ro ad mobile sources, biogenic sources, anthropogenic and natural fire, road and fugitive dust, and area oil and gas emissions. The WRAP used its 2002 emission inve ntory, described above, to project emissions forward to 2018. Reductions expected from federa l and state regulations were included in the inventory. See Chapter 8 of the NM RH 309(g) SI P and Appendix A of our TSD for more details on how the 2018 emissions inventory was constr ucted. The WRAP 2018 Base Case emission inventory (referred to as the Ba se18b emission inventory) reflects growth plus all controls “on the books” as of December 2004. The WRAP 201 8 Preliminary Reasonable Progress Case (referred to as the PRP18b emission inventory) re flects refined growth estim ates, all controls “on the books” as of 2007, and includes presumptive or known SO 2 BART controls. Emission inventory data summarized be low is based on the PRP18b emi ssion inventory. New Mexico’s 2018 emissions inventory (including Bernalillo County emissions) is summarized in Table 10. Tables 11 and 12 summarize the projected change in emissions from 2002 to 2018 in the WRAP emission inventories.

Table 10 - New Mexico’s 2018 Emissions I nventory (including Bernalillo County) Source Category SO 2 NOx VOCs POA EC Soil CM NH3
Point 31,270 73,417 26,308 243 13 1,148 2,142 118 Anthropogenic Fire 72 263 388 442 85 44 63 42
Natural Fire 2,729 8,613 18,846 16,271 3,293 1,223 5,400 1,875 Biogenic 0 42,139 1,016,487 0 0 0 0 0
Area 16,285 33,931 70,566 2,848 374 3,644 1,231 30,233
WRAP Area O&G 12 74,648 267,846 0 0 0 0 0
On-Road Mobile 334 19,746 15,554 656 205 0 464 2,877
Off-Road Mobile 313 28,471 8,942 358 743 0 0 36
Road Dust 6 2 0 153 13 1,751 14,857 0 Fugitive Dust 7 7 0 366 25 7,026 56,533 0
Wind Blown Dust 0 0 0 0 0 16,399 147,589 0
Total 51,028 281,236 1,424,936 21,338 4,750 31,235 228,279 35,18137 Table 11 - Change (tpy) in New Mexico Emi ssions from 2002 to 2018 (including Bernalillo County)

Table 12 - Net Change (%) in New Mexico Em issions from 2002 to 2018 (including Bernalillo County) Source Category SO 2 NOx VOCs POA EC Soil CM NH3
Point -18 -27 50 -75 0 -3 -6 58 Anthropogenic Fire -24 -34 -36 -35 -31 -49 -41 -44
Natural Fire 0 0 0 0 0 0 0 0 Biogenic 0 0 0 0 0 0 0 0
Area 200 35 44 13 24 29 77 1
WRAP Area O&G -95 33 19 0 0 0 0 0
On-Road Mobile -84 -71 -60 0 -73 0 15 35
Off-Road Mobile -92 -37 -35 -36 -51 0 0 38
Road Dust 50 100 0 34 44 34 34 0 Fugitive Dust 18 0 0 2 4 4 10 0
Wind Blown Dust 0 0 0 0 0 0 0 0
Total -3 -19 3 -4 -21 5 4 3

The WRAP and NMED used New Mexico’s and other states’ 2018 emission inventories to construct visibility pr ojection modeling for 2018.

Evaluation:

The submittal supports a determination that New Mexico’s 2002 and 2018 emission inventories are acceptable for the purpose of de veloping the LTS, while no ting that some issues Source Category SO 2 NOx VOCs POA EC Soil CM NH3
Point -6,648 -26,981 8,734 -735 0 -32 -144 43 Anthropogenic Fire -22 -133 -220 -240 -38 -43 -42 -33 Natural Fire 0 0 0 -1 0 0 0 0 Biogenic 0 0 0 0 0 0 0 0
Area 10,852 8,791 21,556 319 73 823 536 274 WRAP Area O&G -238 18,438 43,578 0 0 0 0 0 On-Road Mobile -1,732 -48,089 -23,214 3 -551 0 61 745 Off-Road Mobile -3,533 -16,840 -4,638 -205 -783 0 0 10
Road Dust 2 1 0 39 4 446 3,783 0 Fugitive Dust 1 0 0 6 1 275 5,000 0
Wind Blown Dust 0 0 0 0 0 0 0 0
Total -1,319 -64,814 45,796 -813 -1,296 1,470 9,193 1,04038 have been identified in the emission inventories as discussed a bove in Section B.4 that must be considered when analyzing the results of modeling analysis pr epared using this inventory.

Statewide, total NOx and SO 2 emissions are projected to d ecrease from 2002 levels by 2018. NOx emissions in the 2018 WRAP emission proj ections decrease by 19% primarily due to improvements in mobile sources and reductions at SJGS due to the 2005 consent decree. As discussed above, further reductions in NOx emissions at the largest NOx source in the state, the SJGS, due to implementation of BART are anticipated by 2018.

SO 2 mobile and point source emissions are al so projected to decrease from 2002 to 2018. However, the large increase in area source SO 2 emissions (200%) is much larger than reasonably anticipated (see discussion above in Section B.4 ). Increases in NOx and VOC emissions are anticipated due to expansion of oil and gas prod uction activities in the State. Much of the POA and EC emissions are due to natura l fires that can fluctuate greatly in location and intensity from year to year. The 2018 emission inventory assume s that emissions from natural fires remain constant from 2002 levels. Anthropogenic sources of POA and EC are projected to decrease by 2018.

D.3.b. Visibility Projection Modeling

State Submittal: Chapter 9 and Appendix B

Chapter 9 and Appendix B of the New Mexi co Regional Haze SIP discuss the modeling methods and protocol used by theWRAP and NM ED in developing the assessment. A short summary is provided below:

The WRAP performed modeling for the RH LTS for its member states, including New Mexico. The modeling analysis is a complex technical evaluation thatbegan with selection of the modeling system. The WRAP used (1) th e Mesoscale Meteorological Model (MM5) meteorological model, (2) the Sparse Matrix Operator Kernel Emissions (SMOKE) modeling system to generate hourly gridded speciated em ission inputs, (3) the Community Multiscale Air Quality (CMAQ) photochemical grid model and (4 ) the Comprehensive Air Quality model with extensions (CAMx), as a seconda ry corroborative model. CAMx was also utilized with its Particulate Source Apportionment Technology (PSAT) tool to provide source apportionment for both the baseline and future case visibility modeling.

CMAQ and CAMx modeling of regional haze in the WRAP region for 2002 and 2018 was carried out on a grid of 36x36 kilometer (km) cel ls that covers the co ntinental United States, portions of Canada and Mexico, and portions of the Atlantic a nd Pacific Oceans along the east and west coasts. Selection of a representative period of meteorology is crucial for evaluating39 baseline air quality conditions a nd projecting future changes in air quality due to changes in emissions of visibility-impairing po llutants. An in-depth analysis resulted in the selection of the entire year of 2002 (January 1-December 31) as the best period of meteorology available for conducting the modeling. The WRAP modeling was developed consistent with our guidance. 21

The WRAP examined the model performance of the regional modeling for the areas of interest before determining whether the CMAQ m odel results were suitable for use in the RH assessment of the LTS and for use in the mode ling assessment. The 2002 modeling efforts were used to evaluate air quality/visibility modeling fo r a historical episode—in this case, for calendar year 2002—to demonstrate the suitability of the modeling systems fo r subsequent planning, sensitivity, and emissions control strategy modeling. Model performance evaluation was performed by comparing the output from model simu lations with ambient ai r quality data for the same time period to determine whether the model’s performance was sufficiently accurate to justify using the model for simulating future conditions. Once the WRAP determined the model performance to be acceptable, it used the m odel to determine the 2018 RPGs using the current and future year air quality modeli ng predictions, and compared the RPGs to the URP. The results of this modeling are discussed below.

Evaluation:

A detailed review and discussion of the model selection, modeling protocol, quality assurance, performance evaluation, emission i nventory development and data used in the regional haze analysis can be found in Appendix A to this TSD. 22

D.3.c Sources of Visibility Impairment in New Mexico Class I Areas

State Submittal: Chapter 7 (m onitored data), Chapter 8 (emissions inventory), Chapter 9 (PSAT and WEP results), Chapter 11 (evaluation of RPGs), and Chapter 12 (contributions from other States and areas)

Baseline period monitoring data was used to analyze the contribution of pollutants to light extinction. Table 13 below summarizes the baseline period monitored data found in

21 “Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze,”(EPA-454/B-07-002), April 2007, located at http://www.epa.gov/scram001/guidance/gu ide/final-03-pm-rh-guidance.pdf See also “Emissions Inventory Guidance for Implementa tion of Ozone and Particulate Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations,” August 2005, updated Nove mber 2005 (“our Modeling Guidance ” ), located at http://www.epa.gov/ttnchie1/eidocs/eiguid/index.html, EPA-454/R-05-001

22 Technical Support Document for Tech nical Products Prepared by the Wester n Regional Air Partnership (WRAP) in Support of Western Regional Haze Plans, February 28, 201140 Chapter 7 of the NM RH 309(g) SIP, showing the contribution of each species to visibility impairment at each Class I area on the 20% worst days.

Table 13 - Percentage of Light Extinction on 20% W orst Days During the Baseline Period

Class I area SO4 NO3 OMC EC Soil CM Sea salt
Bandelier 22.33% 8.09% 45.95% 10.03% 3.56% 9.39% 0.65% Bosque del Apache 24.35% 10.39% 26.25% 8.44% 6.17% 21.75% 0.65%
Carlsbad Caverns 33.81% 7.79% 13.73% 2.66% 9.02% 32.79% 0.20%
Gila Wilderness 21.97% 2.87% 50.96% 10.19% 4.78% 8.92% 0.32% Pecos Wilderness, Wheeler Park 23.56% 7.11% 37.33% 9.78% 7.56% 12.44% 2.22%
Salt Creek 31.75% 21.10% 14.26% 4.73% 6.27% 21.86% 0.38%
White Mountains 31.72% 9.06% 27.19% 5.44% 5.74% 20.24% 0.60%

Visibility impairment in Class I areas is the result of local air pollution as well as transport of regional pollution ac ross long distances. In order to determine the significant emission source regions and emission source types contributing to haze in New Mexico’s Class I areas, New Mexico relied upon two source appor tionment analysis techniques developed by the WRAP. The first technique was regional modeli ng using CAMx and the PSAT tool, used for the attribution of sulfate and nitrate sources only. The second technique was the Weighted Emissions Potential (WEP) tool, used for attribution of sources of organic carbon, elemental carbon, PM 2.5 , and PM 10 . The WEP tool is based on emissions and re sidence time, not modeling. PSAT uses the CAMx air quality model to show nitrate-sulfate-ammonia chemistry and apply this chemistry to a system of tracers or ‘‘tags’’ to track the chemical transforma tions, transport, and removal of NOX and SO 2 . These two pollutants are important because they can be significant contributors to visibility impairment and much of the total mass of NOx and SO 2 originates from anthropogenic sources. Therefore, the results from this analys is can be useful in determining contributing sources that may be controllable, both in-sta te and in neighboring st ates. The PSAT results presented below are derived from Section 12.3 of the NM RH 309(g) SIP and the WRAP Technical Support System (TSS) 23 . Tables 14 and 15 show the pe rcent contribution of nitrate and sulfate from the WRAP and other source re gions to modeled visibility impairment on the 20% worst days for 2002. Also shown is the perc entage of the WRAP c ontributions from New Mexico sources. The Central Regional Air Pla nning Association (CENRA P) region includes the states and tribal areas of Nebraska, Kansas, Oklahoma, Texas, Minnesota, Iowa, Missouri, Arkansas, and Louisiana. Some errors were di scovered in the tables of Section 12.3 for the WRAP’s percentage contribution of nitrate of the 20% worst days during the baseline period. Those errors have been corrected in Table 14 below. We note that the 2018 emission inventory used in this analysis (Base18b) is an earlier version that does not include emission reductions due to BART. In New Mexico and surrounding stat es, BART requirements and reductions through

23 WRAP technical products are available at http://vista.cira.colostate.edu/tss/41 the SO 2 emission milestone trading program will result in additional NOx and SO 2 reductions beyond than those assumed in the so urce apportionment modeling.

Table 14 - Percentage of Nitrat e Contribution to Visibility Im pairm ent During Baseline for the 20% Worst Days

Class I area WRAP New Mexico* CENRAP Canada Eastern U.S. Mexico Pacific Off shore Outside Domain Bandelier 71% 24 66% 25 10% 2% 0% 1% 1% 15% Bosque del Apache 61% 61% 26% 3% 0% 1% 1% 8%

Carlsbad Caverns 30% 42% 44% 5% 0% 5% 2% 14% Gila Wilderness 58% 3% 2% 0% 0% 2% 5% 33% Pecos Wilderness, Wheeler Park 57% 64% 28% 3% 2% 1% 1% 8%

Salt Creek 61% 75% 26% 0% 0% 2% 0% 11% White Mountains 40% 38% 36% 4% 0% 2% 2% 16% *New Mexico’s percentage shown in the above table is the percent of the WRAP contribution and not a percent of the total contribution. For example, New Mexico’s nitrate contribution at Bandelier is 66% of the WRAPS contribution of 71%. New Mexico ’s contribution to the total nitrate at Bandelier is 47% (66% of 71%).

Table 15 - Percentage Sulfate Contribution to Visibility Im pairment During Baseline for 20% Worst Days

Class I area WRAP New Mexico* CENRAP Canada Eastern U.S. Mexico Pacific Off shore Outside Domain Bandelier 32% 48% 16% 1% 12% 9% 3% 27% Bosque del Apache 21% 32% 23% 1% 20% 14% 2% 19%

Carlsbad Caverns 5% 29% 28% 2% 43% 10% 1% 11% Gila Wilderness 18% 23% 19% 1% 18% 20% 4% 20% Pecos Wilderness, Wheeler Park 34% 42% 17% 2% 6% 10% 4% 27%

Salt Creek 12% 54% 29% 2% 31% 10% 1% 15% White Mountains 11% 33% 30% 2% 34% 10% 1% 12% *New Mexico’s percentage shown in the above table is the percent of the WRAP contribution and not a percent of the total contribution

WEP is a screening tool that helps to identi fy source regions that have the potential to contribute to haze formation at specific Cla ss I areas. Unlike PSAT, this method does not account for chemistry or deposit ion. The WEP combines emissions inventories, wind patterns,

24 Corrected from 17% in Table 12-4 of the NM RH 309(g) SIP submittal based on data from the WRAP TSS
25 Corrected from 58% in Table 12-5 of the NM RH 309(g) SIP submittal based on data from the WRAP TSS42 and residence times of air masses over each area wh ere emissions occur, to estimate the percent contribution of different pollutants. Like PSAT, the WEP tool compares baseline values (2000– 2004) to 2018 values, to show the improvement e xpected by 2018, for sulfate, nitrate, organic carbon, elemental carbon, PM2.5, and PM10. More information on the WRAP modeling methodologies is available in Appendix A to th is TSD. The PSAT and WEP results presented below are derived from Chapter 9 and 12 of the NM RH 309(g) SIP and the WRAP TSS. Nitrate and sulfate source apportionment data presented below is based on the PSAT modeling results. WEP results of source type and region contributi ons are provided for ot her visibility impairing pollutants.

The submitted long-term strategy modeling also evaluates the sources of OMC and CM emissions. Figure 11-12 of the NM RH 309(g) SIP submittal (included as figure 5 below) identifies the source categories that contribute to emissions of OMC and CM that impact the State’s Class I areas. Over 70% of OMC emissions are due to natu ral fires. More than 65% of CM emissions are from wind-blow n dust. As discussed above, the State has developed Natural Event Action Plans that include measures to address anthropogenic s ources of windblown dust during high wind events. However, windblown dust em issions that are both directly associated with anthropogenic activities and are controllabl e have a minimal effect on visibility at New Mexico’s Class I areas, compared to other so urces of windblown dust. A large portion of EC emissions are also due to natural fires, while m obile emission sources also contribute to the total EC emissions. EC emissions from mobile sour ces are expected to d ecrease significantly by 2018. These pollutants, primarily from natural sources, contribute significantly to visibility impairment in New Mexico.43 Figure 5 – OMC and EC Emissions Aff ecting New Mexico’s Class I Areas

D.3.c.i Sources of Visibility Impa irment in Ba ndelier Wilderness

Visibility impairment at Bandelier in 2002 on the worst 20% days is largely due to OMC and sulfate. OMC emissions ar e primarily from natural fires from NM and AZ. In 2002, the largest contributions of sulfate to Bandelier on the 20% worst days come from sources outside the modeling domain (26%), followed by point s ources in CENRAP states (14%), the Eastern United States (11%), New Mexico (11%), a nd Mexico (8%). New Mexico area sources contribute 2% of the sulfate on these days.

The 2018 projections assume that natural fi re emissions of OMC remain constant between 2002 and 2018. In 2018, visibility impairme nt is still primarily due to OMC from natural fires. New Mexico’s emissions of OM C from anthropogenic fi res are projected to decrease, while emissions from area sources are e xpected to increase. Visi bility impairment due to sulfate is projected to d ecrease by 2018, due to large decreas es in emissions in CENRAP states and the Eastern United States. Sulfate cont ributions to visibility impairment at Bandelier from Mexico will increase from 2002 levels due to increases in emissions from point sources in Mexico. Modeled sulfate contributions from New Mexico increase from 2002 levels due to projected increase in area source emissions in New Mexico. As discussed above, SO 2 emissions from area source emissions in New Mexico, partic ularly in Bernalillo County, are overestimated in the WRAP modeling. Bandelier is located onl y 83 km outside of Bernalillo County and is44 impacted by the WRAP’s large assumed increase in SO 2 emissions. We also note that the PSAT results do not include NOx and SO 2 reductions due to BART and the SO 2 milestone and emissions trading program. We anticipate addi tional visibility improvement in 2018 beyond the modeled visibility conditions due to lower NOx emissions from implementation of the existing federal implementation plan or another future -approved NOx BART determination consistent with the RHR requirements and lower SO 2 area emissions than included in the WRAP 2018 modeling episode used in this analysis. Table 16 shows the per cent contribution (PSAT modeling results) to sulfate and nitrate from the WRAP states, Canada (CAN), Mexico (MEX), Eastern United States (EUS) and outside of the domai n (OD) on the 20% worst days for both 2002 and 2018. Figure 6 shows the regional contributions to su lfate and Figure 7 s hows the area source contributions to sulfate on the 20% worst days.

Table 16 - Percent Contribution to Sulfate a nd N itrate on the 20% wo rst days at Bandelier Wilderness 2002 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM NV PO SD UT WY OD Nat. Fires & Bio. 0% 1% 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 1% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0%

Area 0% 0% 0% 2% 0% 1% 1% 0% 2% 0% 2% 0% 0% 0% 0% Point 7% 1% 1% 14% 1% 11% 8% 0% 11% 1% 1% 0% 1% 1% 0% Outside Domain 26% 2018 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM NV PO SD UT WY OD Nat. Fires & Bio. 0% 1% 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

Area 0% 0% 0% 2% 0% 1% 1% 0% 4% 0% 3% 0% 0% 0% 0% Point 8% 1% 1% 10% 1% 5% 9% 0% 13% 1% 1% 0% 2% 1% 0% Outside Domain 29% 2002 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM NV PO SD UT WY OD Nat. Fires & Bio. 1% 0% 0% 2% 1% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 5% 5% 1% 4% 2% 0% 1% 0% 12% 1% 1% 1% 2% 0% 0%

Area 0% 1% 1% 1% 2% 0% 0% 0% 11% 0% 1% 0% 0% 0% 0% Point 3% 1% 1% 4% 1% 0% 0% 1% 18% 1% 0% 0% 4% 0% 0% Outside Domain 15% 2018 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM NV PO SD UT WY OD Nat. Fires & Bio. 1% 0% 1% 2% 1% 0% 0% 0% 1% 0% 0% 1% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 3% 2% 1% 2% 1% 0% 1% 0% 5% 1% 0% 0% 1% 0% 0%

Area 0% 1% 1% 2% 3% 0% 0% 0% 26% 0% 1% 0% 1% 0% 0% Point 5% 1% 1% 4% 1% 0% 0% 1% 16% 1% 0% 0% 2% 0% 0% Outside Domain 17%45 Figure 6 - Regional Contributions to Sulfate on 20% worst da ys at Bandelier Wilderness

Figure 7 - Contributions to sulfate from area s ources on 20% worst days at Bandelier W ilderness

D.3.c.ii Sources of Visibility Impairment in Bo sque del Apache National Wildlife Refuge

Visibility impairment at Bosque del Apache in 2002 on the worst 20% days is mostly due to OMC, sulfate, CM and nitrate. OMC emission s are primarily from natural fires from NM and AZ. In 2002, the largest contributio ns of sulfate to Bosque del Apache on the 20% worst days come from point sources in CE NRAP states (19%), sources ou tside the modeling domain (18%), point sources in the Eastern United States (18% ), and Mexico (12%). New Mexico point and area sources contribute 4% and 1%, respectively, of the sulfate on these days. CM emissions impacting Bosque del Apache are primarily from windblown dust in New Mexico and neighboring CENRAP states. Contri butions of nitrate are from m obile sources in New Mexico (19%) and CENRAP states (10%) along with c ontributions from New Mexico point sources (8%), CENRAP point sources (9%) a nd New Mexico area sources (7%).

The 2018 projections assume that natural fi re emissions of OMC remain constant between 2002 and 2018. In 2018, visibility impairment is still largely due to OMC from natural fires. New Mexico’s emissions of OMC from anthropogenic fires are projected to decrease, while emissions from area sources are expected to increase. CM emissi ons from windblown dust are held constant from 2002 levels and remain a significant contribution to visibility impairment46 in 2018. Visibility impairment due to sulfate is projected to decreas e by 2018, due to large decreases in emissions in CENRAP states and th e Eastern United States. Sulfate contributions to visibility impairment at Bosque del Apache fr om Mexico will increase from 2002 levels due to increases in emissions from point sources in Mexico. Modeled sulfate contributions from New Mexico increase from 2002 levels due to projected increase in area source emissions in New Mexico. As discussed above, SO 2 emissions from area source emissions in New Mexico, particularly in Bernalillo C ounty, are overestimated in the WR AP modeling. Contributions of nitrate from CENRAP states a nd New Mexico from mobile sour ces are projected to decrease significantly, while contributions from area source emissions, incl uding emissions from oil and gas production in New Mexico are projected to increase. We note that the PSAT results do not include NOx and SO2 reductions due to BART and the SO2 milestone and emissions trading program. We anticipate additiona l visibility improvement in 2018 beyond the modeled visibility conditions due to lower NOx emissions from implementation of the existing federal implementation plan or another future-approved NOx BART determination consistent with the RHR requirements and lower SO2 area emissions than included in the WRAP 2018 modeling episode used in this analysis. Table 17 shows the percent contribution (PSAT modeling results) to sulfate and nitrate on th e 20% worst days for both 2002 and 2018. Figure 8 shows the regional contributions to sulfat e and Figure 9 shows the area s ource contributions to sulfate on the 20% worst days.47 Table 17 - Percent Contribution to Sulfate and Nitrate on the 20% worst days at Bosque del Apache 2002 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM NV PO SD UT WY OD Nat. Fires & Bio. 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 1% 0% 1% 0% 0% 1% 0% 0% 0% 0% 0% 0%

Area 0% 0% 0% 3% 0% 1% 2% 0% 1% 0% 2% 0% 0% 0% 0% Point 5% 1% 1% 19% 1% 18% 12% 0% 4% 1% 1% 0% 1% 1% 0% Outside Domain 19% 2018 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM NV PO SD UT WY OD Nat. Fires & Bio. 1% 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

Area 0% 0% 0% 4% 0% 1% 2% 0% 3% 0% 2% 0% 0% 0% 0% Point 6% 1% 1% 16% 1% 9% 15% 1% 5% 1% 1% 0% 1% 2% 0% Outside Domain 23% 2002 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM NV PO SD UT WY OD Nat. Fires & Bio. 1% 0% 1% 4% 1% 0% 0% 0% 3% 0% 0% 1% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 5% 3% 1% 10% 2% 0% 1% 0% 19% 0% 0% 1% 1% 1% 0%

Area 0% 0% 1% 4% 1% 0% 0% 0% 7% 0% 1% 0% 0% 0% 0% Point 3% 0% 1% 9% 1% 0% 1% 1% 8% 0% 0% 0% 1% 1% 0% Outside Domain 8% 2018 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM NV PO SD UT WY OD Nat. Fires & Bio. 1% 0% 1% 5% 1% 0% 0% 0% 3% 0% 0% 1% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 2% 1% 1% 4% 1% 0% 1% 0% 10% 0% 0% 0% 0% 1% 0%

Area 0% 1% 1% 5% 1% 0% 0% 0% 15% 0% 1% 0% 0% 1% 0% Point 4% 1% 1% 12% 1% 0% 1% 1% 9% 1% 0% 0% 1% 1% 0% Outside Domain 10%

Figure 8 - Regional Contributions to Sulfat e on 20% worst days at Bosque del Apache48 Figure 9 - Contributions to sulfate from area s ources on 20% worst days at Bosque del Apache

D.3.c.iii Sources of Visibility Impairment in C arlsbad Caverns National Park

Visibility impairment at Carl sbad Caverns in 2002 on the wo rst 20% days is largely due to sulfate and CM. The IM PROVE monitoring site for Carlsbad Caverns is located in Guadalupe Mountains National Par k, Texas, south of Carlsbad Caverns National Park. In 2002, the largest contributions of sulfate to Carlsbad Caverns on the 20% worst days came from point sources in the Eastern United St ates (39%), CENRAP states ( 23%), and Mexico (9%). CM emissions impacting Carlsbad Caverns are prim arily from windblown dust in New Mexico and neighboring CENRAP states. WEP results for orga nic carbon indicate that contributions are from area source emissions in CENRAP states an d New Mexico as well as natural fires in New Mexico and Arizona and local New Mexico point sources.

Visibility impairment due to sulfate is projected to decrease by 2018, due to large decreases in point source emissions in CENRAP states and the Eastern United States. Sulfate contributions to visibility impairment at Carl sbad Caverns from Mexico will increase from 2002 levels due to increases in emissions from point so urces. Contributions of nitrate from CENRAP states and New Mexico from mobile sources ar e projected to decrease significantly, while contributions from area source emissions, includ ing emissions from oil and gas production in New Mexico and the CENRAP states are projected to increase. WEP results indicate that point source emissions of organic carbon in New Me xico impacting Carlsbad Caverns decrease significantly by 2018. CM emissions from windblown dust are held constant from 2002 levels and remain a significant contribution to visibi lity impairment in 2018. We note that the PSAT results do not include NOx and SO2 reductions due to BART and the SO2 milestone and emissions trading program. We anticipate additional visibility improvement in 2018 beyond the modeled visibility conditions at Carlsbad Caverns due to lower SO2 area emissions than included in the WRAP 2018 modeling episode used in this analysis . Table 18 shows the percent contribution (PSAT modeling result s) to sulfate and nitrate on the 20% worst days for both 200249 and 2018. Figure 10 shows the regional contributi ons to sulfate and Figure 11 shows the area source contributions to sulf ate on the 20% worst days.

Table 18 - Percent Contribution to Sulfate and N itrate on the 20% worst days at Carlsbad Caverns 2002 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX MT ND NM PO SD WY OD Nat. Fires & Bio. 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 1% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% Area 0% 0% 0% 4% 0% 2% 1% 0% 0% 0% 1% 0% 0% 0% Point 1% 0% 2% 23% 0% 39% 9% 0% 0% 1% 0% 0% 0% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 11% 2018 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX MT ND NM PO SD WY OD Nat. Fires & Bio. 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% Area 0% 0% 0% 5% 0% 3% 1% 0% 0% 0% 1% 0% 0% 0% Point 1% 0% 3% 23% 0% 23% 15% 0% 1% 2% 1% 0% 1% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 16% 2002 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX MT ND NM PO SD WY OD Nat. Fires & Bio. 1% 0% 1% 6% 1% 0% 1% 1% 0% 1% 0% 1% 0% 0% Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 2% 5% 2% 18% 1% 0% 2% 1% 1% 4% 1% 1% 1% 0% Area 0% 1% 1% 7% 0% 0% 1% 0% 0% 3% 1% 0% 0% 0% Point 1% 1% 1% 16% 1% 0% 2% 0% 1% 4% 0% 0% 1% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 14% 2018 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX MT ND NM PO SD WY OD Nat. Fires & Bio. 1% 1% 1% 8% 1% 0% 1% 1% 0% 2% 0% 1% 0% 0% Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 1% 2% 2% 7% 1% 1% 2% 1% 1% 2% 1% 1% 0% 0% Area 0% 1% 1% 9% 1% 1% 1% 0% 0% 6% 2% 0% 0% 0% Point 1% 1% 2% 19% 1% 1% 3% 1% 1% 4% 0% 0% 1% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 17%50 Figure 10 - Regional Contributi ons to Sulfate on 20% worst days at Carlsbad Caverns

Figure 11 - Contributions to sulfate from ar ea sources on 20% worst days at Carlsbad Caverns

D.3.c.iv Sources of Visibility Im pairment in Gila Wilderness

Visibility impairm ent at Gila Wilderness in 2002 on the worst 20% days is largely due to OMC and sulfate. OMC emissions are primarily from natural fires from NM and AZ and contribute to over 50% of the visibility impairme nt at Gila during the base period. In 2002, the largest contributions of sulfate to Gila Wilder ness on the 20% worst days come from sources outside the modeling domain (20%), followed by point sources in the Ea stern United States (17%), Mexico (17%), CENRAP states (16%), an d Arizona(5%). We note th at an error in data retrieval affected initia l results for modeled visibility condi tions at Gila Wilderness in 2002 and indicated that visibility would degrade from 2002 to 2018. 26 This error was corrected and the updated data was included in the NM RH SIP submitted to us.

26 Correction of WRAP region Plan02d CMAQ visibility modeling results on TSS for Regional Haze Planning

– Final Memorandum, June 30, 2011, available at : http://vista.cira.colostate.e du/tss/help/plan02d_rev.pdf51 The 2018 projections assume that natural fi re emissions of OMC remain constant between 2002 and 2018. In 2018, visibility impairme nt is still primarily due to OMC from natural fires. Visibility impairm ent due to sulfate is projected to decrease by 2018, due to large decreases in point source emi ssions in CENRAP states and th e Eastern United States. Sulfate contributions to visibility impairment at Gila from Mexico, Arizona, an d New Mexico increase from 2002 levels due to increases in emissions from point sources. Table 19 shows the percent contribution (PSAT modeling result s) to sulfate and nitrate on the 20% worst days for both 2002 and 2018. Figure 12 shows the regional contributi ons to sulfate and Figure 13 shows the area source contributions to sulf ate on the 20% worst days.

Table 19 - Percent Contribution to Sulfate and N itrate on the 20% worst days at Gila W ilderness

2002 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX NM NV PO UT WY OD Nat. Fires & Bio. 1% 1% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 1% 0% 0% 1% 0% 1% 0% 0% 0% 0% 0% 0% 0% Area 0% 0% 0% 3% 0% 1% 3% 0% 0% 3% 0% 0% 0% Point 5% 1% 1% 16% 1% 17% 17% 2% 1% 1% 1% 1% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 20% 2018 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX NM NV PO UT WY OD Nat. Fires & Bio. 1% 1% 0% 0% 0% 0% 0% 2% 0% 0% 0% 0% 0% Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Area 0% 0% 0% 3% 0% 1% 3% 1% 0% 3% 0% 0% 0% Point 7% 1% 1% 13% 1% 9% 21% 2% 0% 2% 1% 1% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 24% 2002 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX NM NV PO UT WY OD Nat. Fires & Bio. 2% 2% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 20% 23% 0% 0% 0% 0% 2% 0% 2% 2% 0% 0% 0% Area 0% 4% 0% 0% 0% 0% 0% 0% 0% 2% 0% 0% 0% Point 2% 4% 0% 0% 0% 0% 0% 0% 2% 0% 0% 0% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 36% 2018 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX NM NV PO UT WY OD Nat. Fires & Bio. 3% 3% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 10% 13% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Area 3% 5% 0% 0% 0% 0% 0% 0% 0% 3% 0% 0% 0% Point 5% 5% 0% 0% 0% 0% 0% 0% 3% 0% 0% 0% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 50%52 Figure 12 - Regional Contributi ons to Sulfate on 20% worst days at Gila Wilderness

Figure 13 - Contributions to Sulfate from Area Sources on 20% worst days at Gila
W ilderness

D.3.c.v Sources of Visibility Impairment in Pecos Wilderness and Wheeler Pea k Wilderness

Similar to Bandelier, visibility impairment at Pecos/Wheeler Park in 2002 on the worst 20% days is largely due to OMC and sulfate. OMC emissions are primarily from natural fires from NM and AZ. In 2002, the largest contributions of sulfate to Pecos/Wheeler Park on the 20% worst days come from sources outside the mode ling domain (26%), followed by point sources in CENRAP states (15%), Mexico (9%), the East ern United States (6%), and New Mexico (6%). Contributions from New Mexico natural fires ar e 6%. New Mexico area sources contribute 3% of the sulfate on these days.

The 2018 projections assume that natural fire emissions of OMC and SO2 remain constant between 2002 and 2018. In 2018, visibility impairment is still primarily due to OMC from natural fires. New Mexico’s emissions of OMC from anthropogenic fires are projected to decrease, while emissions from area sources are e xpected to increase. Visi bility impairment due to sulfate is projected to decr ease by 2018, due to large decreases in point source emissions in CENRAP states and the Eastern Un ited States. Sulfate contributions to visibility impairment at53 Pecos/Wheeler Park from Mexico will increase fr om 2002 levels due to increases in emissions from point sources in Mexico. Modeled sulfate contributions from New Mexico increase from 2002 levels due to projected increase in area source emissions in New Mexico. As discussed above, SO2 emissions from area source emissions in New Mexico, particularly in Bernalillo County, are overestimated in the WRAP modeling. We also note that the PSAT results do not include NOx and SO2 reductions due to BART and the SO2 milestone and emissions trading program. We anticipate additiona l visibility improvement in 2018 beyond the modeled visibility conditions due to lower NOx emissions from implementation of the existing federal implementation plan or another future-approved NOx BART determination consistent with the RHR requirements and lower SO 2 area emissions than includ ed in the WRAP 2018 modeling episode used in this analysis. Table 20 shows the percent contribution (PSAT modeling results) to sulfate and nitrate on th e 20% worst days for both 2002 and 2018. Figure 14 shows the regional contributions to sulfat e and Figure 15 shows the area sour ce contributions to sulfate on the 20% worst days.

Table 20 - Percent Contribution to Sulfate and N itrate on the 20% worst d ays at Pecos/Wheeler Park 2002 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM NV PO SD UT WY OD Nat. Fires & Bio. 0% 0% 0% 0% 0% 0% 0% 0% 6% 0% 0% 0% 0% 0% 0% Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 1% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% Area 0% 0% 0% 2% 0% 0% 1% 0% 1% 0% 3% 0% 0% 0% 0% Point 6% 1% 2% 15% 2% 6% 9% 1% 6% 2% 1% 0% 1% 1% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 27% 2018 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM NV PO SD UT WY OD Nat. Fires & Bio. 0% 0% 0% 0% 0% 0% 0% 0% 6% 0% 0% 0% 0% 0% 0% Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Area 0% 0% 0% 2% 0% 0% 1% 0% 3% 0% 3% 0% 0% 0% 0% Point 7% 2% 2% 11% 2% 3% 10% 1% 8% 1% 2% 0% 1% 1% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 29% 2002 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM NV PO SD UT WY OD Nat. Fires & Bio. 1% 0% 0% 4% 1% 0% 0% 0% 12% 0% 0% 0% 0% 0% 0% Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 4% 4% 1% 14% 2% 1% 0% 0% 12% 0% 0% 1% 1% 0% 0% Area 0% 0% 1% 4% 1% 0% 0% 0% 6% 0% 0% 0% 0% 0% 0% Point 2% 0% 1% 9% 1% 1% 1% 1% 8% 0% 0% 0% 2% 0% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 8% 2018 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM NV PO SD UT WY OD Nat. Fires & Bio. 1% 0% 1% 5% 1% 0% 0% 0% 7% 0% 0% 1% 0% 0% 0% Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 2% 2% 2% 5% 1% 1% 0% 0% 6% 0% 0% 0% 0% 0% 0% Area 0% 1% 1% 6% 1% 0% 0% 0% 15% 0% 1% 0% 0% 0% 0% Point 4% 1% 1% 11% 1% 1% 1% 1% 9% 1% 0% 0% 1% 0% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 10%54 Figure 14 - Regional Contributions to Sulfate on 20% worst d ays at Pecos/Wheeler Park

Figure 15 - Contributions to Sulfate from Area Sources on 20% worst days at Pecos/Wheeler Park

D.3.c.vi Sources of Visibility Impair ment in Sa lt Creek Wilderness

Visibility impairment at Sa lt Creek in 2002 on the worst 20% days is largely due to sulfate, nitrate, OMC and CM. In 2002, the larges t contributions of sulfate to Salt Creek on the 20% worst days come from point sources in th e Eastern United States (28%), CENRAP states (24%), Mexico (9%), and New Mexico (6%). Cont ributions of nitrate are primarily from area, mobile and point sources in New Mexico and CENRAP states. CM emissions impacting Salt Creek are primarily from windblown dust in New Mexico and neighbor ing CENRAP states. WEP results for organic carbon indicate that co ntributions are from area source emissions in CENRAP states and New Mexico as well as natu ral fires in New Mexico and Arizona and local New Mexico point sources.

Visibility impairment due to sulfate is projected to decrease by 2018, due to large decreases in emissions in CENRAP states and th e Eastern United States. Sulfate contributions to55 visibility impairment at Salt Creek from Mexico increase from 2002 levels due to increases in emissions from point sources. Contributions of nitrate from CENRAP states and New Mexico from mobile sources are projected to decrease si gnificantly, while contributions from area source emissions, including emissions from oil and ga s production in New Mexico and the CENRAP states are projected to increase. WEP results in dicate that point sour ce emissions of organic carbon in New Mexico impacting Salt Creek decr ease significantly by 2018. CM emissions from windblown dust are held constant from 2002 leve ls and remain a significant contribution to visibility impairment in 2018. We note that the PSAT results do not include NOx and SO2 reductions due to BART and the SO2 milestone and emissions trading program. We anticipate additional visibility improvement in 2018 beyond th e modeled visibility c onditions at Salt Creek due to lower NOx emissions and lower SO2 ar ea emissions than incl uded in the WRAP 2018 modeling episode used in this analysis. Table 21 shows the per cent contribution (PSAT modeling results) to sulfate and nitr ate on the 20% worst days for both 2002 and 2018. Figure 16 shows the regional contributions to sulfate and Figure 17 shows the area source c ontributions to sulfate on the 20% worst days. Figure 18 shows the regi onal contributions to nitrate and Figure 19 shows the source region and source type contri butions to sulfate on the 20% worst days.

Table 21 - Percent Contribution to Sulfate and N itrate on the 20% wors t days at Salt Creek 2002 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX MT ND NM PO UT WY OD Nat. Fires & Bio. 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 1% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0%

Area 0% 0% 0% 4% 0% 2% 1% 0% 0% 1% 1% 0% 0% 0% Point 2% 0% 1% 24% 1% 28% 9% 0% 1% 6% 0% 0% 0% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 15% 2018 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX MT ND NM PO UT WY OD Nat. Fires & Bio. 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

Area 0% 0% 0% 5% 0% 2% 1% 0% 0% 1% 1% 0% 0% 0% Point 3% 0% 2% 23% 0% 16% 13% 0% 1% 7% 1% 1% 1% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 20% 2002 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX MT ND NM PO UT WY OD Nat. Fires & Bio. 0% 0% 0% 2% 0% 0% 0% 0% 0% 3% 0% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 3% 1% 0% 8% 2% 0% 0% 0% 0% 13% 0% 1% 0% 0%

Area 0% 0% 0% 5% 1% 0% 0% 0% 0% 13% 0% 0% 0% 0% Point 2% 0% 0% 11% 1% 0% 1% 0% 0% 16% 0% 2% 0% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 11% 2018 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX MT ND NM PO UT WY OD Nat. Fires & Bio. 0% 0% 0% 3% 0% 0% 0% 0% 0% 3% 0% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 1% 1% 0% 3% 1% 0% 0% 0% 0% 7% 0% 0% 0% 0%

Area 0% 0% 0% 6% 2% 0% 0% 0% 0% 23% 0% 0% 0% 0%56 Point 3% 0% 0% 13% 1% 0% 1% 0% 0% 14% 0% 1% 0% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 13%

Figure 16 - Regional Contribu tions to Sulfate on 20% wo rst d ays at Salt Creek

Figure 17 - Contributions to Sulfate from Ar ea Sources on 20% worst days at Salt Creek57 Figure 18 - Regional Contribu tions to Nitrate on 20% wo rst days at Salt Creek

Figure 19 - Source Region/Type C ontributions to Nitrate on 20% worst days at Salt C reek

D.3.c.vii Sources of Visibility Impair ment in White Mou ntain Wilderness

Visibility impairment at White Mountain in 2002 and 2018 is similar to Salt Creek. Visibility impairment at White Mountain in 2002 on the worst 20% da ys is largely due to sulfate, nitrate, OMC and CM. Compared to Salt Creek, vi sibility impairment due to CM is higher at White Mountain, while impairment due to nitrate is less significant. In 2002, the largest contributions of sulfate to White Mountain on th e 20% worst days come from point sources in the Eastern United States (30%), CENRAP states (25%), and Mexico (9%). Contributions of nitrate are primarily from area, mobile and poi nt sources in New Mexi co and CENRAP states. CM emissions impacting White Mountain are pr imarily from windblown dust in New Mexico and neighboring CENRAP states. WEP results for organic carbon indicate th at contributions are from natural fires in New Mexico and Arizona and area source emissions in CENRAP states and New Mexico.

Visibility impairment due to sulfate is projected to decrease by 2018, due to large decreases in emissions in CENRAP states and th e Eastern United States. Sulfate contributions to visibility impairment at White Mountain from Me xico increase from 2002 levels due to increases in emissions from point sources. Contributions of nitrate from CENRAP states and New Mexico58 from mobile sources are projected to decrease significantly, while contributions from area source emissions, including emissions from oil and ga s production in New Mexico and the CENRAP states are projected to increas e. CM emissions from windblown dust are held constant from 2002 levels and remain a significant contribution to visibility impairment in 2018. We note that the PSAT results do not include NOx and SO2 reducti ons due to BART and the SO2 milestone and emissions trading program. We anticipate addi tional visibility improvement in 2018 beyond the modeled visibility conditions at White Mount ain due to lower NOx and SO2 emissions than included in the WRAP 2018 modelin g episode used in this analysis. Table 22 shows the percent contribution (PSAT modeling result s) to sulfate and nitrate on the 20% worst days for both 2002 and 2018. Figure 20 shows the regional contributi ons to sulfate and Figure 21 shows the area source contributions to sulfate on the 20% worst days. Figure 22 shows the regional contributions to nitrate and Figure 23 shows the source region and source type contributions to sulfate on the 20% worst days.

Table 22 - Percent Contribution to Sulfate and N itrate on the 20% worst days at W hite Mountain 2002 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM PO SD WA WY OD Nat. Fires & Bio. 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 1% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0%

Area 0% 0% 0% 4% 0% 2% 1% 0% 0% 1% 0% 0% 0% 0% Point 2% 0% 2% 25% 1% 30% 9% 1% 3% 0% 0% 0% 1% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 12% 2018 Sulfate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM PO SD WA WY OD Nat. Fires & Bio. 1% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0%

Area 0% 0% 0% 5% 0% 3% 1% 0% 1% 1% 0% 0% 0% 0% Point 3% 0% 3% 24% 1% 17% 13% 1% 4% 1% 0% 0% 1% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 17% 2002 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM PO SD WA WY OD Nat. Fires & Bio. 1% 0% 1% 5% 1% 0% 0% 0% 2% 0% 0% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 4% 5% 1% 14% 3% 0% 1% 0% 7% 1% 1% 0% 1% 0%

Area 0% 1% 1% 5% 0% 0% 0% 0% 3% 1% 0% 0% 0% 0% Point 1% 1% 1% 13% 2% 0% 1% 1% 3% 0% 0% 0% 1% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 16% 2018 Nitrate Source Apportionment AZ CA CAN CEN CO EUS MEX ND NM PO SD WA WY OD Nat. Fires & Bio. 1% 0% 1% 6% 1% 0% 1% 0% 3% 0% 1% 0% 0% 0%

Anthro. Fires 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% Mobile 2% 2% 2% 5% 1% 0% 1% 0% 4% 0% 0% 0% 1% 0%

Area 0% 1% 1% 7% 1% 0% 0% 0% 6% 1% 0% 0% 1% 0% Point 2% 1% 1% 16% 2% 0% 1% 1% 4% 0% 0% 0% 1% 0% Outside Domain 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 0% 19%59 Figure 20 - Regional Contributions to Sulf ate on 20% worst days at White Mountain

Figure 21 - Contributions to Sulfate from Area Sources on 20% worst days at White Mountain60 Figure 22 - Regional Contributi ons to Nitrate on 20% wors t days at White Mountain

Figure 23 - Source Region/Type C ontributions to Nitrate on 20% worst days at W hite Mountain

D.3.d New Mexico’s Contributions to Visibility Impairment at Class I areas in Other States

CAMx PSAT results were also u tilized to ev aluate the impact of New Mexico emission sources in 2002 on visibility impa irment at Class I areas outside of the state. Section 12.2 of the NM RH 309(g) SIP presents the contribution of Ne w Mexico sources to nitrate and sulfate on the 20% worst days at the Class I areas in Colora do, Arizona, Nevada, Utah, Wyoming and Texas. See section III.A of this TSD for additional information of New Mexico’s contributions to ClassI areas in nearby states. New Mexi co emissions are responsible fo r up to 60% of the nitrate and 43% of the sulfate at individual Class I areas in neighboring stat es on the 20% worst visibility days during the baseline period. Th e highest impact from New Mexi co sources at other State’s Class I areas occurs at Mesa Verde National Park and Weminuche Wilderness for both sulfate and nitrate. These two Class I ar eas are less than 100km from the SJGS. As discussed in the FIP, the SJGS has significant impacts on visibility conditions at a large number of surrounding Class I areas. Emissions reductions as a result of implementation of the existing federal implementation plan or another future-approved NOx BART determination consistent with the RHR61 requirements will lead to improvement in visibility conditions and a decrease in New Mexico’s contributions to visibility impairment at the Class I areas in surrounding states by 2018. The SO2 milestone emissions and trading program will result in a reduction of statewide SO2 emissions by 2018. NOx emissions from mobile sources are also anticipated to decrease significantly by 2018, reducing the impact of New Mexico sources on other Class I areas.

Evaluation:

The record supports a finding that NMED ’s 2002 and 2018 emission inventories and the visibility projection modeling are acceptable. It appears that New Mexico has adequately documented the technical basis, including m odeling, monitoring, and emissions information, on which it relied upon to determine its apportionment of emission reduction obligations necessary for achieving reasonable progress in each ma ndatory Class I federal area it affects. 27 The record also supports a finding that New Mexico has ade quately identified all an thropogenic sources of visibility impairment it consider ed in developing its LTS. We th erefore recommend finding that New Mexico has satisfied the requireme nts under section 308(d)(3)(iii) – (iv).

D.4 Consideration of Long Term St rategy Factors: 40 CF R 51.308(d)(3)(v)

Section 51.308(d)(3)(v) requires th at New Mexico minimally c onsider certain factors in developing its long-term strategy (the LTS factors). These include : (a) emission reductions due to ongoing air pollution control programs, including measures to address RAVI; (b) measures to mitigate the impacts of construction activities; (c) emissions limitations and schedules for compliance to achieve the reasonable progress goal; (d) source retire ment and replacement schedules; (e) smoke management techniques for agricultural and forestry management purposes including plans as currently exist within the st ate for these purposes; (f) enforceability of emissions limitations and control measures; and (g) the anticipated net effect on visibility due to projected changes in point, area, and mobile source emissions over the period addressed by the long-term strategy.

State Submittal: Section 12.7

In addition to its PM BART determination for the SJGS and the SO 2 emission milestone and trading program, New Mexico’s LTS incorporates emission re ductions due to a number of ongoing air pollution control programs. This includes enforceable emissions limitations, compliance schedules, administrative orders, th e issuance and enforcement of permits limiting emissions from all known major sources in New Mexico, state rules which specifically limit

27 A detailed evaluation of the 2002 and 2018 Emissions Inventories and the WRAP visibility projection modeling, can be found in Appendix A to this TSD.62 targeted emissions sources and categories, and several other ongoi ng air pollution control

programs.

A summary of how NMED addresses the long term strategy factors in 40 CFR 51.308(d)(3)(v)(A)-(G) and our revi ew of each factor follows:

D.4.a Emission reductions due to ongoing ai r pollution control programs, includ ing measures to address reasonably at tributable visibility impairment

The two primary regulatory tools for addressi ng visibility impairment from industrial sources are BART and the Preven tion of Signification Deteriorat ion (PSD) /New Source Review (NSR) rules. The New Mexico PSD rules protect visibility in Class I areas from new major industrial sources and major ch anges to existing sources . Ne w Mexico’s PSD SIP rules (20.2.74 NMAC) contain requirements for re view of visibility impact a ssessment from new and modified major stationary sources within 100 km of a Cl ass I area. New Mexico’s Construction Permits SIP rule (20.2.72 NMAC) addresse s construction or modifications of sources, including minor sources, and assures compliance with ambient ai r quality standards. New Mexico’s Operating Permit Program (20.2.70 NMAC) consolidates a ll air quality regulatory requirements and provides for appropriate compliance assurance m onitoring and an opportunity for participation by the public, EPA, and other States in the permitting process. NMED issues permits to all major and the majority of minor point sour ces in New Mexico, and each permit contains enforceable limitations on emissions of various pollutants, including those which cause or contribute to RH at the Class I ar eas in New Mexico. New Mexico also periodically incorporates by reference Federal New Source Performance Standards (20.2.77 NMAC) and Federal National Emission Standards for Hazardous Air Pollutant (20.2.78 NMAC), and determines case-by-case Maximum Achievable Control Technology (MAC T) under 20.2.82 NMAC which may result in reductions of emissions of visi bility impairing pollutants.

We approved New Mexico’s Visibi lity Protection Plan for Phase I, Parts I and II, as a SIP revision on January 27, 2006. See 71 FR 4490. This plan contains short and long-term strategies for reasonable progress related to addressing reas onably attributable visibility impairment in New Mexico’s Class I areas through visibility monitoring and cont rol strategies. It includes PSD requirements for visibility prot ection and applying BART to ex isting sources if certified as causing RAVI.

Mobile source annual emissions show a majo r decrease in NOx in New Mexico from 2002 to 2018. This reduction will result from nume rous ‘‘on the books’’ Federal mobile source regulations. This trend is expected to provide significant visibility benefits. Beginning in 2006, we mandated new standards for on-road (highway) diesel fuel, known as ultra-low sulfur diesel. This regulation dropped the sulfur content of di esel fuel from 500 parts per million (ppm) to 15 ppm. Ultra-low sulfur diesel fuel enables th e use of cleaner technol ogy diesel engines and vehicles with advanced emissions control devi ces, resulting in signi ficantly lower emissions. Diesel fuel intended for locomotive, marine, a nd non-road (farming and construction) engines and equipment was required to meet a low sulf ur diesel fuel maximu m specification of 500 ppm63 sulfur in 2007 (down from 5000 ppm). By 2010, the ul tra-low sulfur diesel fuel standard of 15 ppm sulfur applied to all non-road diesel fuel. Locomotive and mari ne diesel fuels are required to meet the ultra-low sulfur diesel standard be ginning in 2012, resulting in further reductions of diesel emissions. New Mexico also consid ered ongoing federal mobile source regulations including the Tier 2 Vehicle Emission Standard s, federal low-sulfur gasoline, national low emissions vehicle standards, heavy-duty vehicle standards and other federal Non-Road measures in developing its LTS.

In December of 2007, NMED adopted 20.2.88 NMAC – Emission Standards for New Motor Vehicles, which incorporates California emission standards for new passenger cars, lightduty trucks and medium duty vehicles sold in New Mexico beginning with model year 2011.

New Mexico also considered programs es tablished to address the PM10 NAAQS. This includes Natural Events Action Plans developed for Dona Ana and Luna Counties. The plans outline procedures to utilize control measures to reduce anthropogenic sources of wind-blown dust.

Evaluation:

The submittal supports a finding that NMED properly addressed the requirements of section 51.308(d)(3)(v)(A) in the development of its LTS.

D.4.b Measures to mitigate the impact s of con struction activities

Section 51.308(d)(3)(v)(B) requires that New Me xico consider measures to mitigate the impacts of construction activitie s in developing its LTS. New Me xico considered developing a rule to address fugitive dust. New Mexico condu cted a survey to gather public comments on regulation of dust sources in New Mexico. We note that the earlier discussed programs developed to address the PM10 NAAQS, including the Natural Ev ents Action Plans developed for Dona Ana and Luna Counties contain proced ures for the use of control measures for anthropogenic sources of wind-blown dust. Thes e control measures in clude the use of dust suppressants, phased constructi on, and stopping or slowing cons truction activities during high winds to mitigate the impacts of construction acti vities on visibility impairment. We also note that Bernalillo County, which falls under the juri sdiction of the AQCB, has a fugitive dust rule (20.11.20 NMAC) that addresses fugitive emissions from construction activities within the City of Albuquerque and Bernalillo County. New Mexico did not go forward to adopt the rule that was under consideration at the time the 309(g) SI P was developed. The State has the opportunity to provide an updated analysis of the issue in the progress report and in any needed, future SIP revisions, as contemplated by the requirements of Section 309.

Evaluation:64 that the submittal supports a finding that New Mexico satisfies this component of LTS to consider measures to mitigate the impacts of construction activities.

D.4.c Emissions limitations and schedules for compliance to achieve th e reasonable progress goal

40 CFR 51.308(d)(3)(v)(C) require s that in developing its LT S, New Mexico consider emissions limitations and schedules of complia nce to achieve the RPGs.. The SIP contains emission reduction milestones and a back stop trading program that addresses SO 2 emissions from point sources in the State. The backst op trading program provides emission limits and schedules of compliance for SO 2 emissions from point sources.

Evaluation:

The FIP establishes emission limits and a schedule of compliance for the San Juan Generating Station and may be replaced by a NO x BART determination consistent with the RHR. We are not reviewing the submitted NOx BART determination for purposes of this proposal, but this does not inte rfere with our recommendation th at the record supports a finding that this requirement is satisfied.

D.4.d Source retirement and replacement schedules

The State do es not anticipate any specific major source retirements or replacements. Replacement of existing facilities will be ma naged accordingly through the existing Prevention of Signification Deterioration program. As NMED becomes aware of such actions, they will be factored into future reviews.

Evaluation:

The submittal supports a finding that NMED properly addressed the requirements of section 51.308(d)(3)(v)(D) in the development of its LTS.

D.4.e Smoke management techniques for agr icultural an d forestry management purposes including plans as currently exist within the State for these purposes

40 CFR 51.308(d)(3)(v)(E) requ ires that New Mexico c onsider smoke management techniques for agricultural and forestry ma nagement purposes in developing its LTS. New65 Mexico’s smoke management plan and Sm oke Management Rule (20.2.65 NMAC) are described in Section V.H of th e Federal Register notice.

Evaluation:

The submittal supports a finding that the smoke management plan appropriately contains smoke management techniques for agricultural a nd forestry management purposes, and we are proposing to approve 20.2.65 NMAC that was submitted as a SIP revision in 2003.

D.4.f Enforceability of emissions lim ita tions and control measures

Section 51.308(d)(3)(v)(F) requires that New Mexi co ensure the enforceability of emission limitations and control measures used to meet reasonable progre ss goals. With the exception of the NOx BART limit included in the FIP, all ex isting emission limitations and control measures used to meet the RPGs for which the State is responsible are enforceable by the State either through New Mexico Administrative Code or the SIP measures previously approved by EPA. Future emission limitations will be enfor ceable through NSR permit conditions (that automatically become part of the SIP) or EPA approved SIP measures. The NOx BART requirements for SJGS must be included by NMED in a Part 70 air quality permit whether they draw from 40 CFR §52.1628 or from any subm itted determination that, on EPA approval, replaces those requirements. See 70 FR at 39172.

Evaluation: The submittal supports a finding that NM ED properly addressed the requirements of section 51.308(d)(3)(v)(F) in the development of its LTS.

D.4.g The anticipated net effect on visibility due to projected changes in point, area, and mobile source emission s over the period addressed by the long-term strategy.

40 CFR 51.308(d)(3)(v)(G) requires that in developing its LTS, New Mexico consider the anticipated net effect on visibi lity due to projected changes in point, area, and mobile source emissions over the period addressed by the long -term strategy. The anticipated net effect on visibility due to projected changes in point, area, and mobile source emissions during this planning period was analyzed using the WRAP visibility modeling for 2018 and is discussed in detail elsewhere in this TSD.

Evaluation:

The submittal supports a finding that NMED properly addressed the requirements of section 51.308(d)(3)(v)(G) in th e development of its LTS.66 D.5 Our Conclusion on New Mexico’s Long Term Strategy:

We recommend proposing to approve New Mexico’s long-term strategy. . The record supports a determination that the long-term strategy satisfies the requirements of 40 CFR 51.308(d)(3)and that additional controls and analysis are not presently warranted.

E. Monitoring Strategy/Other SI P Requirements: 40 CFR 51.308(d)(4)

New Mexico must submit with the SI P a monitoring strategy for measuring, characterizing, and reporting of regional haze visibil ity impairment that is representative of all mandatory Class I Federal areas within it. This monitoring strategy must be coordinated with the monitoring strategy required in section 51.305 for reasonably attribut able visibility impairment. Compliance with this requirement may be me t through participation in the Interagency Monitoring of Protected Visual Environments (IMPROVE) network. The SIP must also provide for the following:

(i) The establishment of any addi tional monitoring sites or equipment needed to assess whether reasonable progress goals to addre ss regional haze for all mandatory Class I Federal areas within New Me xico are being achieved.

(ii) Procedures by which monitoring data and othe r information are used in determining the contribution of emissions from within New Mexico to regional haze visibility impairment at mandatory Class I Federal areas bo th within and outside the State.

(iii)For a State with no mandatory Class I Federal areas, procedures by which monitoring data and other information are used in dete rmining the contribution of emissions from within the State to regional haze visibility impairment at mandatory Class I Federal areas in other States.

(iv) The SIP must provide for the reporting of all visibility monitoring data to the Administrator at least annually for each manda tory Class I Federal area in the State. To the extent possible, New Mexico should report visibility monitoring data electronically.

(v) A statewide inventory of emissions of pollutant s that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class I Federal area. The inventory must include emissions for a baseline year, emissions for the most recent year for which data are available, and estimates of future projected emissions. The State must also include a commitment to upda te the inventory periodically.67 (vi) Other elements, including reporting, recordk eeping, and other measures, necessary to assess and report on visibility.

State Submittal: Chapter 4

As Section 51.308(d)(4) notes, compliance wi th this requirement may be met through participation in the IMPROVE network, which applie s to the monitors at all Class I areas in New Mexico. The State of New Mexico is rely ing on the IMPROVE program to meet these monitoring operation and data co llection goals, with the fundamental assumption that network data collection operations will not change, or if changed, will remain directly comparable to those operated by the IMPROVE program during the 2000-2004 RHR baseline period. Further, the State of New Mexico notes th at, resources for operation and sa mple analysis of a complete and representative monitoring network of these long-term reasonable progress tracking sites by the IMPROVE program are a collabo rative responsibility of EPA, states, tribes, and FLMs and the IMPROVE program steering committee. The Stat e of New Mexico will collaborate with the EPA, FLMs, other states, tribes, and the IMPROVE committee to assure adequate and representative data collection a nd reporting by the IMPROVE program.

The IMPROVE Steering Committee consists of representatives from the FLMs, us, and regional-state agencies. At the di rection of the National Park Se rvice, the Cooperative Institute for Research in the Atmosphere, at Colorado St ate University’s Foothills Campus in Fort Collins, Colorado, maintains the network plan on the IMPROVE Internet Web site. 28 The primary objectives of the IMPROV E Web site are to provide fede ral, state, and air quality regulatory agencies as well as the general pub lic access to IMPROVE data, data products, and metadata fully describing the IMPROVE database , including characteristics and history of all network sites. The Web site allows users to query data, review reports, and communicate with different members of the IMPROVE Program.

Section 51.308(d)(4)(i) requires the establishment of any additional monitoring sites or equipment needed to assess whether reasonable pr ogress goals to address RH for all mandatory Class I Federal areas within the state are being achieved. Table 4-1 of the NM RH 309(g) SIP submittal (shown as Table 23 below) shows the IMPROVE monitor site locations, elevations, start date, and the Class I area to which the mon itored visibility data co rresponds. Chapter 4 of the NM RH 309(g) SIP submittal describes the location of each monitor. Monitors for Bandelier, Guadalupe Mountains (representative of Carlsbad), and Gila Wilderness were installed between 1988 and 1994. New monitors we re established at Bosque del Apache, Salt Creek and Wheeler Peak (representative of both Wheeler Peak and Pecos Wilderness) in mid-

28 Please see http://vista.cira.colostate.edu/improve/

.68 2000. The monitor at White Mountain Wilderne ss began operation in early 2002. New Mexico has not identified the need for any additional monitors and we agree with this conclusion. We propose to find the 309(g) SIP submittal has satisfied this requirement.

Table 23 - IMPROVE Monitors in New Mexico

Section 51.308(d)(4)(ii) requires that RH SIPs establish procedures by which monitoring data and other information are used in determin ing the contribution of em issions from within a state to RH visibility impairment at mandatory Class I Federal areas both within and outside the state. The IMPROVE monitori ng program is national in scope, and other states have similar monitoring and data reporting pr ocedures, ensuring a consistent and robust monitoring data collection system. As secti on 51.308(d)(4) indicates, particip ation in the IMPROVE program constitutes compliance with th is requirement. The submittal supports a finding that this requirement is satisfied.

Section 51.308(d)(4)(iv) requires th at RH SIPs provide for th e reporting of all visibility monitoring data to the Administrator at least an nually for each mandatory Class I Federal area in the state. To the extent possible, New Me xico should report visibility monitoring data electronically. Section 51.308(d)(4 )(vi) also requires that NMED provide for other elements, including reporting, recordkeepi ng, and other measures, necessa ry to assess and report on visibility. We propose to determine that New Mexico’s participation in the IMPROVE network ensures the monitoring data is reported at leas t annually, is easily accessi ble, and therefore the 309(g) SIP submittal complies with this requirement.

Section 51.308(d)(4)(iv) requi res that NMED maintain a statewide inventory of emissions of pollutants that are reasonably anti cipated to cause or contribute to visibility impairment in any mandatory Cla ss I Federal area. The inventor y must include emissions for a baseline year, emissions for the most recent year for which data are available, and estimates of future projected emissions. The state must al so include a commitment to update the inventory periodically. Please refer to section D.3.a above , where we discuss NMED’s emission inventory.69 The 309(g) SIP provides a stated commitment to update the New Mexico statewide emissions inventories periodically and revi ew periodic emissions informati on from other states and future emissions projections. We propose to determine the RH SIP submittal satisfies this requirement.

Evaluation: The submittal supports a finding that New Me xico has satisfied the requirements of section 51.308(d)(4).

F. Best Available Retrofit Techno logy (BART) Requirements: 40 CFR 51.308(e)

Pursuant to 40 CFR 51.309(d)(4)(vii), a section 309 SIP m ust contain any necessary long term strategies and BART requirements for PM and NOx. Any such BART provisions may be submitted pursuant to 40 CFR 51.308(e). New Mexi co must submit a SIP containing emission limitations representing Best Available Retr ofit Technology (BART) and schedules for compliance with BART for each BART eligible source that may reasonably be anticipated to cause or contribute to any impair ment of visibility in any mandatory Class I Federal area, unless it demonstrates that an emissions trading progr am or other alternativ e will achieve greater reasonable progress toward natural visibility c onditions. As previously discussed, the submitted NOx BART determination for SJGS is not under evaluation and not part of EPA’s proposal.

Note: The evaluation of whether the RH SIP contains “adequate emission limitations representing BART and sche dules for compliance with BART for each BART eligible source that may reasonably be anticipated to cause or contribute to any impairment of visibility in any mandatory Class I Fe deral area” is conducte d within the BART evaluation in Section III.F.2.

Section 40 CFR 51.308(e)(2) – (3) concerning the use of a trading program or other alternative to BART to satisfy the requirements of BART for PM and NOx are not applicable to the NM RH 309(g) SIP evaluated here. Section 309 provides an alternative met hod of satisfying the Section 308 SO 2 BART requirements with emission milestone s and a backstop trading program (40 CFR 51.309(d)(4)). The milestones must be shown to provide for greater reasonable progress than would be achieved by applic ation of BART pursuant to 40 CFR 51.308(e)(2). This SO 2 emission milestones and a backstop trading program is disc ussed in detail in the Federal Register notice and is addressed by New Mexico in the NM RH 309 SIP submittal.

F.1. BART Eligible Source Identi fication: 40 CFR 51.308(e)(1 )(i)

New Mexico must submit a SIP cont aining a list of all BART-eligibl e sources within the State.

Note: This section is intended to cover the genera l question of whether the state identified which sources were subject to BART. S ubsequent sections tr eat this determination in more detail.70 State Submittal: Section 10.3.1

NMED identified sources as BART eligible if they:

1. Belonged to one of the twenty-six BART categories listed below; 2. Did not operate before August 7, 1962, but were in existence on August 7, 1977; and 3. Had the potential to emit 250 tons per ye ar or more of any visibility-impairing pollutant.

NMED initially determined which sources were BART eligible by screening its emissions inventory and permitting database to identify major facilities with emission units in one or more of the 26 BART categories:

1. Fossil-fuel fired steam electric plants of more than 250 million British thermal units (BTU) per hour heat input, 2. Coal cleaning plants (thermal dryers), 3. Kraft pulp mills, 4. Portland cement plants, 5. Primary zinc smelters,
6. Iron and steel mill plants,
7. Primary aluminum ore reduction plants, 8. Primary copper smelters, 9. Municipal incinerators capable of charging more than 250 tons of refuse per day, 10. Hydrofluoric, sulfuric, a nd nitric acid plants, 11. Petroleum refineries, 12. Lime plants, 13. Phosphate rock processing plants, 14. Coke oven batteries, 15. Sulfur recovery plants, 16. Carbon black plants (furnace process), 17. Primary lead smelters, 18. Fuel conversion plants, 19. Sintering plants, 20. Secondary metal production facilities, 21. Chemical process plants, 22. Fossil-fuel boilers of more than 250 million BTUs per hour heat input, 23. Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels, 24. Taconite ore processing facilities, 25. Glass fiber processing plants, and71 26. Charcoal production facilities.

NMED then used its databases and records to identify facilities within these source categories with potential emissions of 250 tons per year or more for any visibility-impairing pollutant from any unit that was in exis tence on August 7, 1977 and began operation after August 7, 1962. New Mexico identified 11 sources as BART-eligible: Giant Refining, Ciniza Refinery (now Western Refining Southwest, Gallup Refinery); P ublic Service Company of New Mexico, San Juan Generating Station Boilers 1 through 4; Giant Refini ng San Juan Refinery (now Western Refining Southwes t, Bloomfield Refinery) Unit #1 fluid catalytic cracking unit electrostatic precipitator; DEFS Artesia Gas Pl ant (now DCP Midstream Artesia Gas Plant) sulfur recovery unit; Amoco Empire Abo (now Frontier Field Services Empire Abo Gas Plant) sulfur recovery unit; Marathon Indian Basin Ga s Plant (now Oxy USA WTP Indian Basin Gas Plant) sulfur recovery unit; DEFS Linam Ranc h Gas Plant (now DCP Midstream Linam Ranch Gas Plant) sulfur recovery unit, Dynegy Saunders (now Versado Gas Processors Saunders Gas Plant) sulfur recovery unit; Southwestern Publ ic Service Cunningham Station; Southwestern Public Service Maddox Station; El Pa so Rio Grande Generating Station.

Evaulation:

The submittal supports a finding that NMED ha s adequately identifie d all BART-eligible sources in New Mexico.

F.2 BART Sources Exempted Due to Modeling Waivers

State Submittal: Section 10.3 , Appendix C

Pursuant to federal regulations, states ha ve the option of exem pting a BART-eligible source from the BART requirements based on disp ersion modeling demonstrating that the source cannot reasonably be anticipated to cause or contri bute to visibility impairment in a Class I area. Following the identification of those sources which were determined to be BART eligible and consistent with the BART Guidelines, NMED relied on the WRAP’s initial BART screening modeling to assess the extent of each facility’s contribution to visibility impairment at surrounding Class I areas and identify sources su bject to BART. Appendix C of the submitted NM RH SIP for 309(g) summarizes the initia l BART screening performed by the WRAP for New Mexico.

The BART Guidelines provide that states may choose to use the CALPUFF modeling system or another appropriate model to predict the visibility impacts from a single source on a Class I area, and to therefore determine whether an individual source is an ticipated to cause or72 contribute to impairment of visibi lity in Class I areas, i.e., “is s ubject to BART”. The Guidelines state that we believe CALPUFF is the best re gulatory modeling application currently available for predicting a single source’s contribution to visibility im pairment (70 FR 39162). NMED relied on WRAP screening modeling using th e CALPUFF modeling system to determine whether individual sources in New Mexico were subject to or exempt from BART.

The BART Guidelines also recommend that states develop a m odeling protocol for making individual source attributions, and suggest that states may want to consult with us, FLM representatives, and their RPO to address a ny issues prior to mode ling. NMED relied on the WRAP to develop a modeling protocol for th e BART screening. The procedures used are outlined in the WRAP Regional Modeling Center (RMC) BART Modeling Protocol. 29 Stakeholders, including EPA, FLM representati ves, industrial sources, trade groups, and other interested parties, actively participated in the development and review of the WRAP protocol at the time it was developed in 2005/6.

For states using modeling to determine the ap plicability of BART to single sources, the BART Guidelines note that the firs t step is to set a contribution threshold to assess whether the impact of a single source is sufficient to cause or contribute to visibility impairment at a Class I area. The BART Guidelines state that “the appropriate threshold fo r determining whether a source contributes to visibility impairment’ ma y reasonably differ across states,” but, “[a]s a general matter, any threshold th at you use for determining whet her a source ‘contributes’ to visibility impairment should not be higher th an 0.5 deciviews.” 70 FR 39104, 39161. Further, in setting a contribution threshol d, states should “consider the number of emissions sources affecting the Class I areas at issue and the magn itude of the individual sources’ impacts. The Guidelines affirm that states are free to use a lowe r threshold if they concl ude that the location of a large number of BART-eligible sources in proxim ity of a Class I area jus tifies this approach. NMED and the WRAP used a contribution thresh old of 0.5 dv for determining which sources are subject to BART.

Initial modeling was performed for the 11 source complexes in New Mexico with visibility estimated from the sources’ SO 2 , NOx, and PM emissions by the WRAP. The results of the visibility impacts modeling demonstrated that the majority of the individual BART-eligible sources had visibility impacts well below 0.5 dv. 30 With the exception of the San Juan Generating Station that had mode led visibility impacts well above 0.5 dv, the highest visibility impact of the remaining BART-eligible source s was 0.34 dv. NMED and the WRAP determined

29 The procedures used are outlined in the WRAP Regional Modeling Center (RMC) BART Modeling Protocol that is available at: http://pah.cert.ucr.edu/aqm/308/bart/W RAP_RMC_BART_Proto col_Aug1 5_2006.pdf

30 See Appendix C of the NM RH 309(g) SIP for a Summary of WRAP RMC BART Modeling for New Mexico Draft#6, December 17, 201073 that the only sources that did not screen out in New Mexico were the four units of the SJGS. The results of this analysis indicated that SJGS, on a facility-wide basi s, causes visibility impairment at all 16 Class I areas that lie within 300 km of the facility

Evaluation:

NMED provided the WRAP’s screening mode ling results in Appendix C of the RH 309(g) SIP for all sources identified as BART-e ligible sources. We agree that the WRAP screening modeling for exemption concludes that all of the facilities identified by NMED as exempt from BART each have visibility impact s well below the 0.5 dv threshold for significant contribution to visibility impairment. However, some concerns have been identified with the CALPUFF modeling system (CALMET v6.211 a nd CALPUFF v6.112) utilized by the WRAP since the original WRAP CALPUF F screening modeling was conducted. 31 At the time the WRAP modeling protocol was developed there were some known concerns with ‘bugs’ in the regulatory version of CALPUFF (v5.711) that could lead to e rrors, therefore a version of CALPUFF that was indicated as having correct ions for the ‘bugs’ but had not been fully evaluated by EPA was recommended for use in the WRAP screening modeling. As the WRAP screening modeling was being condu cted pursuant to the protocol , EPA continued analyzing the changes to the CALPUFF modeling system that were included in the CALPUFF v6.112 and v5.756 model systems (v5.756 was also referred to as the “VISTAS version”). EPA was conducting the evaluation of these newer versions as part of th e required regulatory review in updating the regulatory version of the model. EPA’s review indi cated that some of the ‘bug’ fixes were addressed but that th ere were other significant changes, including changes in default options, that had been incorporated in the VI STAS and v6.112 versions. EPA’s determined that some of these changes were not approvable and wo rked with the model developer to include the ‘bug’ fixes and changes EPA agreed were accepta ble in the current version at the time (v5.711) and update the regulatory version. Eventually, EPA approved an updated version that is the current version of CALPUFF approved for re gulatory action on June 29, 2007. The CALPUFF modeling system approved at that time incl uded CALPUFF version 5.8, level 070623, CALMET version 5.8 level 070623, and CA LPOST version 5.6394, level 070622.

In support of the FIP, modeling was performe d by EPA that allows for the comparison of model results between the WRAP’s CALM ET v6.211 and EPA’s CALMET v5.8 for the San Juan Generating Station. 32 While impacts at individual Class I areas varied, the overall

31 “CALPUFF: Status and Update” , Dennis Atkinson, Presentation at Regional/State/Local Modelers Workshop, May 16, 2007. ( http://www.cleanairinfo.com/regionalstatelocalmodelin gworkshop/archive/2007/presentations/Wednesday%20- %20May%2016%202007/CALPUFF_status_update.pdf ); EPA report, “Assessment of the “VISTAS” Version of the CALPUFF Modeling System”, EPA-454/R-08-007, August 2008 available at (http://www.epa.gov/ttn/scram/reports/ calpuff_vistas_assessment_report_f inal.pdf); “CALPUFF Regulatory Update”, Roger W. Brode, Presentation at Regional/State/L ocal Modelers Workshop, June 10-12, 2008, available at (http://www.cleanairinfo.com/regionalstatelocalmodelin gworkshop/archive/2008/presentations/BRODE_CA.pdf).
32 See the TSD for our FIP, “Visibility Modeling for BA RT Determination: San Juan Generating Station, New Mexico” available in the docket to our FIP (Docket No. EPA-R06-OAR-2010-0846) and included in the docket for this action.74 magnitude of impacts from the units at the San Juan Generating Station were slightly less, but similar. EPA’s modeling indicated that the San Juan Generating Station units impacts were still large and did not screen out of a full BART analysis. This comparison of the two versions of modeling results helps to support the conclusion that the differe nces due to the operation of CALMET in accordance with the WRAP protocol several years ago and the current regulatory approach would not likely change the original determination by the WRAP and NMED of which sources screen out of BART and which are subj ect to a full BART analysis. In addition, EPA has performed preliminary modeling of other BART -eligible sources that were screened out by the WRAP modeling (less than 0.5 dv ) in the NM RH SIP. Of th ese sources that screened out, EPA chose to examine those sources with the hi ghest impacts to confirm that revised modeling using current regulatory model/settings would still indicate the highest impacts are below 0.5 dv and would still be screened out from doing a BART 5-factor analysis. The results of EPA’s additional modeling indicate that th e values are consistent with th e original conclusions. In the WRAP’s modeling the highest imp act in a year was 0.34 dv from a ny of the screened outsource complexes and EPA’s results of a selection of source complexes indicate the highest impact is well below 0.5 dv. Based on the conglomeration of modeling results, we propose to concur with New Mexico that all other BART eligible source s other than the SJGS screen out of a full 5- factor BART analysis.

For the SJGS, the WRAP’s results of the sc reening analysis indicated that SJGS, on a facility-wide basis, causes visibility impairment at all 16 Class I areas that lie within 300 km of the facility. However, this modeling was base d on the installed cont rol technology at the time and does not reflect emission reductions due to the installation of consent decree 33 controls. Revised modeling performed by NMED and by us, including controls required by the consent decree and currently installed, further confirmed th at SJGS still ‘‘causes’’ visibility impairment at more than half of the Class I areas in the vicinity of the facility and contributes (above 0.5 deciviews) to visibility impairmen t at the remaining areas on a fac ility-wide basis. Furthermore, on an individual unit basis, all units ‘‘cause’’ visi bility impairment at Mesa Verde National Park, and cause or contribute to visibility impai rment at a number of other Class I areas. 34 Our modeling indicates that the visibility impairment is primarily dominated by nitrate particulates. Therefore, as the WRAP screening modeling ha s previously concluded, and further modeling by NMED and EPA confirms, even with post-consent decree controls on SJGS units, the SJGS units

33 Consent Decree in The Grand Canyon Trust and Sierra Club, Plaintiffs, The State of New Mexico, PlaintiffIntervenor, v. Public Service Company of New Mexico, Defendant, (CV 02–552 BB/ACT (ACE)), lodged in the United States District Court, District of New Mexico, on March 10, 2005, at 15–16. The consent decree resulted in the installation of low-NOx burners with overfire air ports and a neural network system to reduce NOx emissions, and a full-sized pulse jet fabric filter to reduce PM emissions. The wet limestone scrubber was modified to eliminate flue gas bypass, and dibasic acid was added to the scrubber process to improve SO2 removal. Installation of these controls on all four units was completed in the spring of 2009. The consent decree requires compliance with emission limits of 0.3 lb/MMBtu NOx, 0.015 lb/MMBtu PM, and 90% annual av erage control, not to exceed 0.25 lb/MMBtu SO2 for a seven day block average for each unit.
34 See the TSD for our FIP, “Visibility Modeling for BART Determination: San Juan Generating Station, New Mexico” available in the docket to our FIP (Docket No. EPA-R06-OAR-2010-0846) and included in the docket for this action.75 1, 2, 3, and 4 still have a significant imp act at surrounding Class I areas. Based upon WRAP/NMED and our modeling, we concur with NMED’s subject-to-BART determination that units 1, 2, 3, and 4 of the SJGS are the onl y New Mexico sources subject to BART.

F.3. BART Five Factor Determinat ion: 40 CFR 51.308(e)(1)(ii)(A)-(B)

For the sources that were not exempt from the BART requirements via dispersion modeling analyses, NMED must make a determination of BA RT for each BART-eligible source in New Mexico that emits any air pollutant whic h may reasonably be anticipated to cause or contribute to any impairment of visibility in any mandatory Class I Federal area. All such sources are subject to BART. The determination of BART must be based on an analysis of the best system of continuous emission control technology available and associated emission reductions achievable for each BART-eligible source th at is subject to BART within the State. In this analysis, New Mexico must take into cons ideration the technology av ailable, the costs of compliance, the energy and non-air quality enviro nmental impacts of compliance, any pollution control equipment in use at the source, the remaini ng useful life of the source, and the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.

The third step of a BART evaluation is to pe rform the BART analysis. The BART Guidelines 35 describe the BART analysis as consis ting of the following five basic steps: • Step 1: Identify All Availabl e Retrofit Control Technologies, • Step 2: Eliminate Techni cally Infeasible Options, • Step 3: Evaluate Control Effectiveness of Remaining Control Technologies, • Step 4: Evaluate Impacts and Document the Results, and • Step 5: Evaluate Visibility Impacts.

The SJGS consists of four (4) coal-fired ge nerating units and associated support facilities. Each coal-fired unit burns pulverized coal and N o. 2 diesel oil (for star tup) in a boiler, and produces high-pressure steam which powers a steam turbine coupled with an electric generator. Electric power produced by the units is supplied to the electric power grid for sale. Coal for the units is supplied by the adjacent San Juan Mine and is delivered to the facility by conveyor. Units 1 and 2 have a unit capacity of 350 and 360 MW, respectively. Units 3 and 4 each have a unit capacity of 544 MW. The BART determination for SJGS, as a fossil-fuel fired power plant having a total generating capacity greater than 750 megawatts, must be made pursuant to the guidelines in appendix Y of 40 CFR Part 51 (Guidelines for BA RT Determinations under the Regional Haze Rule)

35 70 FR 39164.76 In June, 2007, the operator of the SJGS, Pub lic Service Company of New Mexico (PNM) submitted its PM evaluation to NMED. That ev aluation was revised incorporate additional visibility modeling analyses , control technology considerations, and cost analyses. 36 NMED’s final evaluation of this BART analysis for PM is available in Chapter 10 and Appendix D of the NM RH 309(g) SIP submittal. We discuss the PM BART determinations in the following section. As discussed in the Federal Register notice for this action, BART requirements for SO 2 are met through New Mexico’s participation in a SO 2 milestone emissions and backstop trading

program.

F.3.a New Mexico’s PM BART De termination for the SJGS

State Submittal: Section 10.4 and Appendix D

The SJGS currently has pulse jet fabric filters installed and an em ission limit of 0.015 lb/MMBtu PM. PNM performed a BART five –factor analysis for PM. A summary of this analysis is presented below:

Step 1- Identify All Availabl e Retrofit Control Technologies: PNM identified flue gas conditioning with hot side electrostatic precipitator (ESP), pulse jet fabric filter (PJFF), compact hybrid particulate collector, and max-9 electrostatic fabric filter as available controls for PM at SJGS. At NMED’s request, PNM al so identified wet ESP (WESP).

Step 2- Eliminate Technically Infeasible Options : Hot-side ESP and co mpact hybrid particulate collector were eliminated becau se these technologies were determined to not provide control performance lower than the currently permitted li mit for PM. The max-9 electrostatic fabric filter was also eliminated due to limited appli cation in large utility boilers. WESP and PJFF were determined to be technically feasible a nd were evaluated in PNM’s BART analysis for
PM. 37

Step 3- Evaluate Control Effectivenes s of Remaining Control Technologies: PNM determined that PJFF and WESP are capable of achievi ng emission limits of 0.015 lb/MMBtu PM and 0.010 lb/MMBtu PM, respectively.

36 Public Service Company of New Mexico, San Juan Gene rating Station, Best Available Retrofit Technology Analysis, June 6, 2007; Public Service Company of New Mexico, San Juan Generating Station Final particulate matter BART analysis, August 28, 2008
37 Public Service Company of New Mexico, San Juan Gene rating Station Final particulate matter BART analysis, PNM (August 28, 2008).77 Step 4- Evaluate Impacts and Document the Results : PNM then evaluated the impacts, including costs of compliance, energy impact s, non-air quality impacts, and the remaining useful life, of operating WESP in addition to the existing PJFF. PNM’s evaluation considered auxiliary power consumption, additional water cons umption, and waste water dispos al requirements, as well as cost. The installation of WESP was estimated to reduce emissions of PM by 69 tons per year (tpy) each for Units 1 and 2, 107 tpy for Unit 3 and 105 tpy at Unit 4. The addition of WESP was determined by PNM and evaluated by NMED to have a cost-effect iveness ranging from about $145,000 to $173,000 per ton of PM removed for each unit.

Step 5- Evaluate Visibility Impacts : PNM then performed modeling to investigate the visibility impacts.

Based on the five factor analysis , NMED determined that BART for Units 1-4 for PM is existing pulse jet fabric filter contro l technology and an ex isting emission rate of 0.015 lb/MMbtu.

The Department’s determination of BART was based on the following results of the full five factor analysis: 1. Each of Units 1-4 is equipped with a pulse je t fabric filter (PJFF) and is subject to a federally enforceable emission limit of 0.015 lb PM/MMbtu. 2. The Department reviewed both the cost-effect iveness and incremental cost-effectiveness of additional control technology (WESP) and found these costs to be excessive. 3. There are no non-air impacts asso ciated with the WESP technology. 4. There are additional energy impacts associated with the WESP technology and the Department considers these costs to be reasonable. 5. The Department reviewed the visibility improve ment that resulted from the installation of the consent decree technology (PJFF and LNB/ OFA) and that would result from the addition of WESP technology. The Department determined that on a facility-wide basis the visibility improved by 1.06 deciviews (dv) from the installation of the consent decree technology at Mesa Verde National Park (Mes a Verde). The installa tion of WESP would result in a facility-wide improvement of 0.62 dv at Mesa Verde.

Evaluation Regarding PM BART Determination for SJGS:

PNM overestimated the cost of WESP because PNM did not follow the EPA Air Pollution Control Cost Manual 38 , where possible, as directed by the BART Guidelines. 39 For

38 U.S. EPA, EPA Air Pollution Control Cost Manual, Repo rt EPA/452/B–02–001, 6th Ed., January 2002 (‘‘Cost Manual’’), The EPA Air Pollution Control Cost Manual is the current name for what was previously known as the OAQPS Control Cost Manual, the name for the Cost Manual in previous (pre-2002) editions of the Cost Manual.
39 In order to maintain and improve consistency, cost estimates should be based on the OAQPS Control Cost Manual, where possible. 70 FR 39104, 39166 (2005).78 example, PNM’s cost analysis includes costs not allowed under EPA’s Cost Manual methodology, such as Allowance for Funds Used During Construction (AFUDC). 40 PNM’s visibility analysis shows a maximum visibi lity improvement of 0.62 dv from WESP being installed on all four units at Me sa Verde and 0.14 dv improvement at San Pedro Parks. Visibility benefits at other Class I ar eas are below 0.1 dv. As discusse d in detail in the FIP and accompanying TSD 41 , we identified inconsistencies between PNM’s modeling and EPA guidance. In our evaluation of NMED’s PM BART determination we considered these deviations from EPA guidance for cost estimates and visibility impact analysis. We note that some visibility benefit is antic ipated at Mesa Verde through the installation of WESP at SJGS. However, given the high anticipated cost on a $/ ton removed basis for WESP at SJGS, even if we corrected the cost estimate to be consistent with EPA guidance, we believe the cost of installation and operation of WESP would not be cost-effective. Therefore, the record supports approval of NMED’s PM BART determination for the SJGS that PM BART is satisfied by the existing PJFF and the existing emission limit of 0.015 lb/MMBtu.

F.4. De Minimis BART: 40 CFR 51.308(e)(1)(ii)(C)

A determ ination of BART is required for each BART-eligible source in New Mexico that emits any air pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility in a ny mandatory Class I Federal area. All such sources are subject to BART. New Mexico is not required to make a determination of BART for SO 2 or for NOx if a BART-eligible source has the potential to emit less than 40 tons per year of such pollutant(s), or for PM10 if a BART-eligible source has the potentia l to emit less than 15 tons per year of such pollutant.

State Submittal:

NMED did not specifically exclude any BA RT eligible sources under this provision.

F.5. Design, Equipment, or Work Pr actice BART: 40 CFR 51.308(e)(1)(iii)

If New Mexico determ ines in establishing BART that technological or economic limitations on the applicability of measuremen t methodology to a particular source would make

40 There may be other deficiencies in New Mexico’s cost evaluation of PM BART for the SJGS, but we take no position on them, as they are moot in light of the potential visibility benefits versus the order of any possible magnitude adjustment in New Mexico’s cost analysis.

41 The proposed FIP, the TSD, and the Final Rule are added to the docket for this rule ma king and are also available in the docket to our FIP (Docket No. EPA-R06-OAR-2010-0846).79 the imposition of an emission sta ndard infeasible, it ma y instead prescribe a design, equipment, work practice, or other operationa l standard, or combination thereof, to require the application of BART. Such standard, to the degree possible, is to set forth the emission reduction to be achieved by implementation of such design, equi pment, work practice or operation, and must provide for compliance by means whic h achieve equivalent results.

State Submittal:

NMED did not determine that technologica l or economic limitations on the applicability of measurement methodology to a particular so urce would make the imposition of an emission standard infeasible. NMED di d not prescribe a design, equipmen t, work practice, or other operational standard, or combination thereo f, to require the application of BART.

F.6. Installation of BART: 40 CFR 51.308(e)(1)(iv) – (v)

Each source subject to BART must (1) inst all and operate BART as expeditiously as practicable, but in no even t later than 5 years after approval of the SIP revision, and (2) maintain the control equipment required by this subpart and establish procedures to ensure such equipment is properly operated and maintained. As concerns the PM BART determination under review in this proposal, this requirement is inapplicable.

F.7 CAIR for BART: 40 CFR 51.308(e)(2)-(3)

New Mexico may opt to implement or requi re participation in an emissions trading program or other alternative measure rather than require sources subject to BART to install, operate, and maintain BART. Such an emissions trading program or other alternative measure must achieve greater reasonable progress than would be achieved through the installation and operation of BART.

Note: This provision of the regional haze rule does not apply to New Mexico for NOx or PM since it did not opt to implement or require participation in an em issions trading program or other alternative measure rather than re quire sources subject to BART to install, operate, and maintain BART for PM and NOx. New Mexico’s particip ation in the 309 SO2 emissions milestone and backstop trading program is discussed in detail in the review of the NM RH 309 SIP submittal contained in the notice for this proposed action80 F.8 CAIR for BART: 40 CFR 51.308(e)(4)

If a State chooses to meet the emission reduc tion requirements of the Clean Air Interstate Rule (CAIR) by participating in one or more of the EPA-admi nistered CAIR trading programs for SO 2 and NOx, it need not require BART-eligible E GUs subject to such trading programs in the State to install, operate, and maintain BA RT for the pollutants covered by such trading programs in it. The State may choose to partic ipate in the EPA-administered CAIR trading programs either by submitting a SIP that incorporates the CAIR model trading rules in part 96 of this chapter, and is approved, in accordance with section51.123(o )(1) or (2) (for the NOx annual program) and (aa)(1) or (2) (for the NOx ozone season program) and section 51.124(o)(1) or (2) (for the SO 2 program) or by remaining subject to the Fe deral implementation plan in part 97 of this chapter (which may be m odified by a SIP approved in acco rdance with sections 51.123(p) and (ee) and 51.124(r)). If the State chooses to pa rticipate in such trading programs, it may also adopt provisions, consistent w ith such trading programs, for a geographic enhancement to the program to address the requirement under sec tion 51.302(c) related to BART for reasonably attributable impairment from the pollutants c overed by the CAIR cap-and-trade programs.

Note: This provision of the regional haze rule do es not apply to New Mexico because New Mexico evaluated BART controls for its subject to BART sources and the State is not in CAIR for NOx or SO2

F.9. Reasonable Progress and BART: 40 CFR 51.308(e)(5)

After a State has met the requirements fo r BART or implemented emissions trading program or other alternative measure that achiev es more reasonable progress than the installation and operation of BART, BART-eligible sources will be subject to the requirements of paragraph (d) of this section in the sa me manner as other sources.

Note: There are no BART sources that NMED revisited for the purposes of obtaining additional reductions under Section 51.308(d).

F.10. BART Exemptions: 40 CFR 51.308(e)(6)

Any BART-eligible facility subject to the re quirement under paragraph (e) of this section to install, operate, and maintain BART may a pply to the Administrator for an exemption from that requirement. An application for an exempti on will be subject to the requirements of section 51.303(a)(2)–(h).81 Note: This provision of the regional haze rule was not used by NMED in the preparation of its RH SIP.