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 2012 
ii 

TABLE OF CONTENTS

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 Factor 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 Considered 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 Conditions: 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 Consultation: 40 CFR 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 Strategy: 40 CFR 51.308(d)(3)(iii) – (iv) .............. 34

D.3.a Emissions Inventory ................................................................................................. 35

D.3.a.i New Mexico’s 2002 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 Impairment in New Mexico Class I Areas ............................. 39

D.3.c.i Sources of Visibility Impairment 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 Impairment 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 Impairment 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 .................................................................................................................................. 60
iii 

D.4 Consideration of Long Term Strategy Factors: 40 CFR 51.308(d)(3)(v) ....................... 61

D.4.a Emission reductions due to ongoing air pollution control programs, including 

measures to address reasonably attributable 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 agricultural 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 Mexico’s Long Term Strategy ................................................ 66

E. Monitoring Strategy/Other SIP Requirements: 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 Determination: 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 Practice 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) ................................................................... 80
iv 

TABLES

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% Worst 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 for 20% Worst and 20% Best Days .............................................. 28

Table 7 - 2064 Natural Conditions Goal for 20% Worst and Best Days ...................................... 29

Table 8- Baseline and Natural Visibility Conditions at New Mexico’s Class I Areas ................. 31

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

Table 10 - New Mexico’s 2018 Emissions Inventory (including Bernalillo County) .................. 36

Table 11 - Change (tpy) in New Mexico Emissions from 2002 to 2018 (including Bernalillo 

County) ......................................................................................................................................... 37

Table 12 - Net Change (%) in New Mexico Emissions 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 Nitrate Contribution to Visibility Impairment 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 and Nitrate on the 20% worst 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 Nitrate on the 20% worst days at Gila Wilderness

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

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

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

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

FIGURES

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 Planning Organization Boundaries .................................................... 9

Figure 4 – Sulfur Oxide Emissions by County for 2002 and 2018 ............................................... 21

Figure 5 – OMC and EC Emissions Affecting 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 sources 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 sources on 20% worst days at Bosque del Apache 48

Figure 10 - Regional Contributions to Sulfate on 20% worst days at Carlsbad Caverns ............. 50

Figure 11 - Contributions to sulfate from area sources on 20% worst days at Carlsbad Caverns 50

Figure 12 - Regional Contributions to Sulfate on 20% worst days at Gila Wilderness ................ 52

Figure 13 - Contributions to Sulfate from Area Sources 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 Sulfate 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 Contributions to Nitrate on 20% worst days at Salt Creek ......................... 57

Figure 19 - Source Region/Type Contributions to Nitrate on 20% worst days at Salt Creek ...... 57

Figure 20 - Regional Contributions 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 Contributions to Nitrate on 20% worst days at White Mountain ............... 60

Figure 23 - Source Region/Type Contributions to Nitrate on 20% worst days at White Mountain

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

APPENDICES

Appendix A. Technical Support Document for Technical Products Prepared by the Western 

Regional Air Partnership (WRAP) in Support of Western Regional Haze Plans, February 28, 

2011 

Appendix B. Review of Companion Rules to New Mexico’s Regional Haze State 

Implementation Plan 
5 

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 the 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 proposing 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—submitted on December 1, 2003; and July 5, 2011 

submitted revisions to 20.2.73.300.F NMAC, a subprovision 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 action when they are relevant to our analysis of New 

Mexico’s RH 309 SIP submittal. 

 

 This TSD contains two appendices that support the proposal. Appendix A to this TSD 

contains a report describing our review of the emission inventory development and 

photochemical visibility modeling, performed by the WRAP. Appendix B to this TSD contains 

the analyses of the companion rules. 

 

The 309(g) SIP submittal reviewed in this document 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 reasonable 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 must 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 regional 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 addition, pursuant to 40 CFR 

51.309(d)(4)(vii), a section 309 SIP must 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). Our Federal Register notice provides 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 Federal 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 determination has been made. However, all aspects of the TSD 

should be considered to be part of our proposal and are subject 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 Federal Class I areas which calls for the “prevention 

of any future, and the remedying of any existing, impairment of visibility in mandatory Federal 

Class I areas which impairment results from manmade air pollution.” Congress adopted the 

visibility provisions to protect visibility in 156 Federal Class I areas, which include certain 

national parks, memorial parks, and wilderness areas over a certain size, and all international 

parks. These areas are defined 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 Colorado 
7 

Plateau. The requirements to address regional haze visibility impairment at these 16 Class I 

areas are established in 51.309 and are discussed further in New Mexico’s Section 309 SIP 

submittal. 

Figure 1 - Map of Class I Areas 
8 

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

 On December 2, 1980, we promulgated regulations 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 addressing 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 pollutants and visibility impairment improved. 

In the 1990 Amendments to the CAA, Congress 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 second phase in addressing visibility impairment. 

States were required to submit state 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 (FLMs). States were required to submit a Regional Haze SIP to 

us within three years after the date of designation of areas under the National Ambient Air 

Quality Standard (NAAQS) for fine particulate matter (PM2.5). We promulgated PM2.5
9 

designations on December 17, 2004, and thus, regional haze SIPs were to be submitted to us by 

December 17, 2007, which is also specified at 40 CFR 51.308(b). 

 The RH rule addressed the combined visibility effects of various pollution sources over a 

wide geographic region. Consequently, all 50 states, including those without Class I areas, 

Washington, D.C., and the Virgin Islands, were required to submit Regional 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 Planning Organization Boundaries 

 New Mexico, through the NMED joined state air agencies from Alaska, Arizona, 

California, Colorado, Hawaii, Idaho, Montana, New Mexico, North Dakota, Oregon, South 

Dakota, Utah, Washington, and Wyoming in forming the WRAP, in 1997 to implement the 

Grand Canyon Visibility Transport Commission’s recommendations to EPA 2

. WRAP also 

includes federally recognized Indian tribes located within the geographic 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/reports/GCVTCFinal.PDF 
10 

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 drew 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 Attainment of Air Quality Goals for PM2.5 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 Emission Inventory SIP 

 Planning: 8-Hour Ozone, PM2.5 and Regional Haze Programs, dated 11/18/2002, from Lydia 

 Wegman to the Regional Air Directors.” 

8. Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program, dated 

 June 1, 2007. 

9. Visibility Monitoring Guidance, EPA-454/R-99-003, June 1999. 

10. Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National 

 Ambient Air Quality Standards (NAAQS) 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 Class 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 Improvement Board for approval. The State of 

New Mexico has nine federal Class I areas within its borders. These are Bandelier Wilderness 

Area, Bosque del Apache National Wildlife Refuge, Carlsbad Caverns National Park, Gila 

Wilderness, Pecos Wilderness, Salt Creek Wilderness, Wheeler Park Wilderness, White 

Mountain Wilderness and San Pedro Parks Wilderness 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 regional haze visibility impairment at these 16 

Class I areas are established in 51.309 and are discussed further in New Mexico’s Section 309 

SIP submittal. 

 NMED also determined that New Mexico emissions 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 New 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 sulfate at individual Class I areas in neighboring 

states on the 20% worst visibility days during the baseline period. The highest impact from New 

Mexico sources at other State’s Class I areas 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 percentages shown are the percent of the total WRAP 

contribution to visibility impairment due to nitrate or sulfate emissions in New Mexico. We note 

that some errors were discovered in section 12.2 and 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 Implementation Plans; New Mexico; Federal 

Implementation Plan for Interstate Transport of Pollution Affecting Visibility and Best Available 

Retrofit Technology Determination, 76 FR 52388), the SJGS has significant 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 adoption of a permit limit of 0.15 lb/MMBtu for 

SO2, will lead to significant improvement in visibility conditions and a significant decrease in 

New Mexico’s contributions to visibility impairment at the Class I areas in surrounding states by 

2018 

Table 1 - Percent of the WRAP contribution due to New Mexico emissions 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% 

Texas5

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 within the state as well as all Class I areas in 

neighboring states that may be affected 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 reasonable 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 least 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 percentage 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 modeling, (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 projected visibility conditions from 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 represent 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% Worst 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 17.317 7.84 7.43 

White Mountains 13.70 12.09 13.26 3.55 3.41 

Evaluation: 

The vehicle for ensuring continuing progress towards 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 “worst” 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 the exception of Carlsbad Caverns, 

all Class I areas also show no degradation on the 20% best days. 

For Carlsbad Caverns, NMED provided modeling data that demonstrates that significant 

projected growth in emissions by 2018 from Mexico are responsible for the degradation in 

visibility conditions on the 20% best days at this Class I area (Section 11.3.3 of the NM RH 

309(g) SIP submittal). WRAP visibility modeling results with Mexico emissions held constant8

from 2002 to 2018 show a slight improvement in visibility conditions at Carlsbad Caverns on the 

20% best days. Baseline visibility conditions for the 20% best days at Carlsbad is 5.9 dv. 

Projected visibility conditions for 2018 is 6.1 dv using the emission 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. NMED also provides results of the 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 Carlsbad Caverns Class I area, however, shows 

improvement in visibility conditions 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 Factor 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 Preliminary 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 Preliminary 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.shtml 
15 

the costs of compliance, the time necessary for compliance, the energy and non-air quality 

environmental impacts of compliance, and the remaining useful life of any potentially affected 

sources, and include a demonstration showing how these factors were taken into consideration in 

selecting the goal. 

State Submittal: Section 11.2, Appendix E, Appendix F 

For SO2, 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 

SO2 emissions milestone and backstop trading program will result in reductions in SO2

emissions. 

The WRAP hired EC/R Incorporated (EC/R), headquartered in Chapel Hill, North 

Carolina, to complete the four factor analysis 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 for analysis: Reciprocal Internal Combustion 

Engines and Turbines; Oil and Gas Exploration and Production Field Operations; Natural Gas 

Processing Operations; Industrial Boilers; Cement Kilns; Sulfuric Acid Manufacturing Plants; 

Pulp and Paper Lime Kilns; and Oil Refineries. NMED did not identify any additional 

reductions in their evaluation of the WRAP analysis. In the RH 309(g) SIP submittal, NMED 

commits to conduct further research to evaluate non-BART sources for possible emission 

controls and retrofits for the next Plan update in 2013.10 

 

In addition, NMED also requested an additional analysis be done on specific sources in 

New Mexico. EC/R completed a four factor analysis 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 were 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, Gallup 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 the controls currently installed at the FCCU at 

the Artesia Refinery and the low level of emissions, 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 Refinery has been in suspended operations since 

November 2009. The Bloomfield FCCU is subject to NOx and SO2 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 necessary at this source at this time due to the 

stringent emission limits already required by the 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 SO2 to 25 ppmvd (both at 0% O2) by December 31, 2010. The 

boiler will meet an emission rate of 0.04 lb/MMBtu after modifications including Low-NOx 

burners. The 309(g) SIP submittal includes a determination that additional controls at this source 

to address regional haze are unnecessary 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 that considered the four statutory factors 

under 40 CFR 51.308(d)(1)(i)(A) to evaluate the potential of controlling certain sources or 

source categories for addressing visibility impacts 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 Determination: 40 CFR 51.308(d)(1)(i)(B) 

In establishing a reasonable progress goal for any mandatory Class I Federal area within 

the State, New Mexico must analyze and determine the rate of progress needed to attain natural 

visibility conditions by the year 2064. To calculate this rate of progress, New Mexico must 

compare baseline visibility conditions to natural visibility conditions in the mandatory Federal 

Class I area and determine the uniform rate of visibility improvement (measured in deciviews) 

that would need to be maintained during each implementation period in order 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 calculate the rate of progress 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 natural visibility conditions for the 

eight additional Class I areas and determined the linear rate of visibility improvement (in 

deciviews) that would have to be maintained during each implementation period in order to 

                                                           

11 NMED Stipulation and Final Order No. AQCA 02-09 (CO) and No. AQCA 05-22(CO), August 2, 2005 
17 

attain natural visibility conditions by 2064. The URP for each Class I area is shown in Table 6-6 

of the NM RH 309(g) SIP and reproduced below 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 URP for each Class I area. NMED has calculated the 

number of years it would take to attain natural visibility conditions 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 determined the rate of progress needed to attain 

natural visibility conditions by the year 2064. NMED constructed the URP consistent with the 

requirements of the RH Rule and our 2003 Tracking Progress Guidance by plotting a straight 

graphical line from the baseline level of visibility impairment for 2000-2004 to the level of 

visibility conditions representing no anthropogenic impairment in 2064. NMED has calculated 

this rate of progress, and compared baseline visibility conditions to natural visibility conditions 

and determined the URP needed to be maintained during each implementation period in order to 

attain natural visibility conditions by 2064 for each Class I area in New Mexico. The submittal 

supports a finding that New Mexico has appropriately calculated the URP and satisfied the 

requirement in section 51.308(d)(1)(i)(B). 

B.4 Analysis of Reasonable Progress 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 visibility than the rate that 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 the 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 number of years it would take to 

attain natural conditions if visibility improvement continues at the rate of progress 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 number of years it would take to attain natural visibility 

conditions under the rate or progress selected by the State as reasonable, 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 modeling, (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 reasonable 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, New Mexico includes a discussion 

of the pollutant contributions and the sources of visibility impairment at each Class I area and 

compares the RPGs to the URP goal on a pollutant specific basis (see Section 11.3 of the NM 

RH 309(g) SIP). The factors that New Mexico considered 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 sources that cannot be controlled is significant. 

Section III.D.3 below discusses the sources of visibility 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 sulfate 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 progress achievable, particularly at those Class I areas located in 
19 

Southern New Mexico. Section III.D.3 below discusses the sources of visibility impairment at 

each Class I area and the percent contribution from Mexico and outside the modeling domain; 3) 

Controls on oil and gas emission sources are being evaluated and are anticipated 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 naturally 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-blown 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 associated with anthropogenic activities and are 

controllable have a minimal effect on visibility at New Mexico’s Class I areas 

compared to other sources of windblown dust. Because the State has limited 

ability to control these sources 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 during the planning period. Because of the 

difficulty and uncertainty in estimating emissions of windblown dust and the 

limited ability to control these emissions, windblown dust emissions are held 

constant from 2002 to 2018. Other sources of CM including fugitive dust and road 

dust emissions are projected to increase by 2018, however, these increases 

contribute to only a 4% increase 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 value of 1 when projecting course matter visibility impacts 

to the future year 2018, regardless of the future year modeling 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 WRAP. We note that New Mexico seeks 

approval for participation in the SO2 emissions milestone and backstop trading 

program that applies to all stationary sources that emit greater than 100 tpy of SO2

and will result in emission reductions of SO2 between 2002 and 2018. Our 

analysis of the WRAP emission inventories used in the photochemical modeling 

to project visibility conditions revealed an overestimation of area source SO2

emissions from New Mexico. In particular, emissions for Bernalillo County were 

much higher than current emissions and emission trends would suggest (Figure 4). 

WRAP emission projections include a 200% increase in New Mexico’s statewide 

area source SO2 emissions (Table 4), primarily in Bernalillo County, while no 

other WRAP state is projected to have an increase in area source SO2 emissions 

greater than 50%. Bernalillo County emission estimates reported to the National 

Emission Inventory are much lower than those in the 2002 WRAP emission 

inventory and show a trend of decreasing emissions from 2002 to 2008, as shown 

in Table 5. In development of the 2018 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 and state, in the analysis. 

This over prediction in area source SO2 emissions in New Mexico in the 2018 

WRAP modeling results in overall less modeled 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 SO2 emissions are also 

overestimated in the 2002 emission inventory and leads to an overestimate of the 

contribution of New Mexico emissions to visibility impairment at Class I areas in 

2002. Detailed information on the source apportionment modeling for SO2 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 Emissions13 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 Mexico point sources are also significant 

and are anticipated to increase by 2018. 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 visibility 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 

SO2 emissions under NMED jurisdiction. Due to reductions required by the 

consent decree and by the implementation of BART, significant reductions in SO2

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 that NMED’s submitted NOx BART 

determination though not under review for this proposal and not legally effective 

unless it is approved would require control 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 RHR requirements will result in greater 

visibility improvements than projected in the WRAP visibility modeling relied 

upon to establish the reasonable progress 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 inventory and the WRAP modeling used to 

determine the RPGs. Consequently, implementation 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 County Regional Haze SIP submittal 
23 

jurisdiction of NMED, are anticipated as the result of a BART determination that 

is part of a FIP. These two BART determinations represent significant reductions 

in NOx emissions at the largest emission 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 analysis and reasonable progress goals. There is sufficient support to 

determine that no further controls are warranted to meet the requirements of 40 CFR 308(d)(1). 

In setting its RPGs for its Class I areas for the 20% worst days, New Mexico relied on certain 

NOx emission reductions at the SJGS that may underestimate the reductions to be achieved. 

NOx BART is an element of the long term strategy necessary to achieve the reasonable progress 

goals. Whether the existing federal implementation plan or another future-approved NOx BART 

determination consistent with the RHR requirements 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 visibility improvement that results from all emission reduction 

measures in place by 2018. 

B.5 Reasonable Progress State Consultation: 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 visibility impairment in the 

mandatory Class I Federal area. In any situation in which New Mexico 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 disagreement. The Administrator 

will take this information, if available, into account in determining whether its goal for visibility 

improvement provides for reasonable progress 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 SIP. 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 neighboring states’ contributions to the visibility 

impairment at New Mexico’s Class I areas. The technical analyses and 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, and relied on the technical tools, policy 

documents, and other products that all Western states used to develop their regional haze plans. 

The WRAP Implementation Work Group was one of the primary collaboration mechanisms. All 

the states relied upon similar emission inventories, results from source apportionment studies and 

BART modeling, review of IMPROVE monitoring data, existing state smoke management 

programs, and other information in assessing the 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 share of emission reductions needed to meet reasonable progress 

goals. 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 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, and all states participating in the consultations agreed. 

 

Evaluation: 

The submitted SIP supports a finding that New Mexico has satisfied the requirement 

under sections 51.309(g) and 51.308(d)(1)(iv) to consult with other states that may reasonably be 

anticipated to cause or contribute to visibility impairment at New Mexico’s Class I areas. 

B.6 Reasonable Progress Goal To Be Considered by Administrator: 40 CFR 51.308(d)(1)(v) 

 The language under Section 51.308(d)(1)(v), “The reasonable progress goals established 

by the State are not directly enforceable but will be considered by the Administrator in 

evaluating the adequacy of the measures in the SIP to achieve the progress 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 Minimum: 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 progress goal that represents less visibility 

improvement than is expected to result from implementation of other requirements of the CAA 

during the applicable planning period. 

State Submittal: Chapter 9 

 The RPGs established by New Mexico are based on WRAP 2018 modeling projections. 

The modeling projections conducted by WRAP contain 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 programs that are either currently in effect or will 

take effect with mandated future-year emission 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 baseline year and 2018. Since WRAPS’s 2018 modeling 

projections are based on local, State, and federal control programs that are either currently in 

effect or with mandated future-year emission reduction schedules, NMED’s RPGs represent at 

least as much visibility improvement as is expected to result from implementation requirements 

of the CAA during the applicable planning period. 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 since 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 Conditions: 40 CFR 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 onsite monitoring data for 2000–2004, New Mexico 
26 

must establish baseline values using the most representative available monitoring data for 2000–

2004, in consultation with the Administrator or his or her designee. 

State Submittal: Section 4.1, 6.1 and 6.3 

Section 4.1 of the NM RH 309g SIP provides an overview of the IMPROVE network, 

describes the metrics used to describe visibility 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. Baseline conditions are calculated using multiyear 

averaging of the 20 percent of monitored days with 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 extinction 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 similar 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, because 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 expressed 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 measured. NMED calculated its baseline conditions in 

accordance with our 2003 Natural Visibility Guidance,16 as required by the RHR. The baseline 

condition calculation begins with the calculation of light extinction, using the IMPROVE 

equation. The IMPROVE equation sums the light extinction 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 Visibility Conditions Under the Regional Haze Program, EPA-454/B-03-005, 

September 2003. 
27 

purpose of this refinement is to provide more accurate 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 particulate matter: sulfurous, nitrate, 

organic carbonaceous, elemental “light-absorbing” carbonaceous, fine soil, chlorine or chloride, 

and coarse matter. The equation also accounts for Rayleigh scattering of light and for 

deliquescence on sulfurous, nitrate, and chlorine or chloride particulates with an estimate of 

particle-bound water as a function of relative humidity. It reflects the most recent review of the 

science17 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 light absorption by gaseous nitrogen dioxide. Sitespecific values are used for Rayleigh scattering (scattering of light due to atmospheric gases) to 

account for the site-specific effects of elevation and temperature. Separate relative humidity 

enhancement factors are used for small and large 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 mass terms, do not change between the original 

and new IMPROVE equations. 

 As with the natural visibility conditions calculation, NMED chose to use the new 

IMPROVE equation. The choice between use of the 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 for calculating both the baseline and natural 

visibility conditions because it takes into account the most recent review 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 from 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, September 2003). Monitors for Bandelier, 

Guadalupe Mountains (representative 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), Colorado State University, Cooperative Institute for Research in the 

Atmosphere, Fort Collins, Colorado. 

http://vista.cira.colostate.edu/improve/publications/GrayLit/016_IMPROVEeqReview/IMPROVEeqReview.htm; and 

Pitchford, Marc., 2006, Natural Haze Levels II: Application of the 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_NaturalCondII/naturalhazelevelsIIrenatu.ppt 
28 

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 IMPROVE site over the 2000-2004 period. 

 

 NMED calculated the baseline by first summing 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: 

βext = βext S + βext NO3 + βext organic+ βext elemental+ βext Soil+ βext coarse+ βext Cl+ βext Rayleigh 

 NMED then converted the total light extinction values to deciviews (dv), using the Haze 

Index (HI) equation: 

HI (dv) = 10 ln[βext/(10 Mm -1)] 

Table 6 (Taken from Table 6-1 of the NM RH 309g SIP) shows the baseline conditions 

for each IMPROVE monitor site in New Mexico. 

Table 6 - Baseline Conditions for 20% Worst and 20% Best Days 

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 adequately 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 Visibility Conditions: 40 CFR 51.308(d)(2)(iii) 

 For each additional mandatory Class I Federal 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 appropriate data analysis techniques. 

State Submittal: Section 6.4 

 Natural background visibility, as defined 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 components adjusted by site-specific estimates of 

humidity. The natural condition for each Class I area represents the visibility goal expressed in 

deciviews for the 20% worst visibility days and the 20% best visibility days 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 guidance, 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 areas. One alternative approach is to develop and justify the use of 

alternative estimates of natural concentrations of fine particle components. 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 the various factors that affect 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 because 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 conditions. 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 Goal for 20% Worst 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 2.16 
30 

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 deciviews by which baseline conditions exceed natural 

visibility conditions for the most impaired 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 the 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 and the least impaired (20% best) 

days for each Class I area 
31 

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 -0.5718 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 schedules, and other measures as necessary to 

achieve the reasonable progress goals established by States having 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 RPO, 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, WHPE1 is located at an elevation of 11,000 ft 
32 

components: (1) construction of a WRAP 2002 baseline emission inventory; (2) construction of 

a WRAP 2018 projected emission inventory, including reductions from WRAP member state 

controls required or expected under federal and state regulations (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 detailed long-term strategy 

is included in Chapter 12 of the NM RH 309(g) SIP. 

Evaluation: 

Our evaluation regarding whether the New Mexico 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 Consultation: 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 Federal area located in another State or States, it 

must consult with the other State(s) in order to develop coordinated emission management 

strategies. New Mexico must consult with any other State having emissions that are reasonably 

anticipated to contribute to visibility impairment in any mandatory Class I Federal area within it. 

State Submittal: Chapter 2, Chapter 12 

As in the development of New Mexico’s reasonable progress goals for its Class I areas, 

NMED used the WRAP as its main vehicle for facilitating collaboration with FLMs and other 

states in satisfying its LTS consultation requirement. This helped NMED and other state 

environmental agencies analyze emission apportionments at Class I areas and develop 

coordinated RH SIP strategies. 

NMED’s consultations with other states are described in section III.B.5 above. As 

already discussed elsewhere, NM neither requested additional emission reductions from other 

states, nor made a commitment to other states for additional emission reductions beyond the 

coordinated emission management strategies developed through the WRAP consultation process 

and factored in the WRAP’s 2018 visibility projections 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 consultation process agreed with this decision. 

 
33 

Evaluation: 

 The submittal supports a finding that New Mexico 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 its 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 obligations 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 Mexico 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 Western states used to develop their regional haze 

plans. The WRAP Implementation Work Group was one of the primary collaboration 

mechanisms. All the states relied upon similar emission inventories, results from source 

apportionment studies and BART modeling, review of IMPROVE monitoring data, existing state 

smoke management programs, and other information 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 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, 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 agreed to as a result of that process, unless it proposes a separate 

process and performs its consultations on the 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 regional 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 choosing 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 statutory factors. At the same time, we cannot 

require States to participate in regional planning efforts if the 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 justify their apportionment, which generally will require regional 

inventories and a regional modeling analysis. Additionally, 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 the 2011 submitted RH SIP proposes controls more 

stringent than those assumed in the modeling, New 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 Class I areas in other states. The submittal, in 

conjunction with the NOx BART determination under the FIP or any replacement that may be 

approved as being consistent with Regional Haze 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 must document the technical basis, including modeling, monitoring and 

emissions information, on which the State is relying to determine its apportionment of emission 

reduction obligations necessary for achieving reasonable 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 organization and approved by all State participants. New Mexico must 

identify the baseline emissions inventory on which its strategies are based. 

 New Mexico must also identify all anthropogenic sources of visibility impairment 

considered by the State in developing its long-term strategy. It should consider major and minor 

stationary sources, mobile sources, 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 following discussion of emission inventories for the 2002 

base and 2018 future year, 2002 and 2018 photochemical modeling results, and our review of the 
35 

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 TSD20. 

D.3.a Emissions Inventory 

State Submittal: Chapter 8, Appendix A

The emissions inventory used in the RH technical analyses was developed by WRAP 

with assistance from New Mexico using approved EPA methods. Emissions within New Mexico 

are both naturally occurring and man-made. Two primary sources of naturally occurring 

emissions in New Mexico include wildfires and windblown dust. An emissions inventory for 

each visibility impairing pollutant was developed by WRAP for New Mexico for the baseline 

year 2002 and for 2018, which is the first reasonable progress milestone. NMED and the WRAP 

developed an emission inventory for anthropogenic sources (point, stationary 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 emissions of the visibility-impairing pollutants NOx, 

SO2,, volatile organic compounds (VOCs), primary organic aerosol (POA), elemental Carbon 

(EC), fine particulate matter (Soil – PM2.5), CM, and ammonia (NH3). 

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

New Mexico 2002 emissions inventory is summarized in Table 9: 

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

Source Category SO2 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 Technical Products Prepared by the Western Regional Air Partnership (WRAP) 

in Support of Western Regional Haze Plans, February 28, 2011 
36 

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 Model (IPM) for electric generating units in 

constructing its 2018 emission inventory. More specifically, the WRAP developed emissions for 

a number inventory source classifications: point, area, non-road and on-road mobile sources, 

biogenic sources, anthropogenic and natural fire, road and fugitive dust, and area oil and gas 

emissions. The WRAP used its 2002 emission inventory, described above, to project emissions 

forward to 2018. Reductions expected from federal and state regulations were included in the 

inventory. See Chapter 8 of the NM RH 309(g) SIP and Appendix A of our TSD for more details 

on how the 2018 emissions inventory was constructed. The WRAP 2018 Base Case emission 

inventory (referred to as the Base18b emission inventory) reflects growth plus all controls “on 

the books” as of December 2004. The WRAP 2018 Preliminary Reasonable Progress Case 

(referred to as the PRP18b emission inventory) reflects refined growth estimates, all controls “on 

the books” as of 2007, and includes presumptive or known SO2 BART controls. Emission 

inventory data summarized below is based on the PRP18b emission 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 Inventory (including Bernalillo County) 

Source Category SO2 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 35,181 
37 

Table 11 - Change (tpy) in New Mexico Emissions from 2002 to 2018 (including Bernalillo 

County) 

Table 12 - Net Change (%) in New Mexico Emissions from 2002 to 2018 (including Bernalillo 

County) 

Source Category SO2 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 projection modeling for 2018. 

Evaluation: 

The submittal supports a determination that New Mexico’s 2002 and 2018 emission 

inventories are acceptable for the purpose of developing the LTS, while noting that some issues 

Source Category SO2 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 1,040 
38 

have been identified in the emission inventories as discussed above in Section B.4 that must be 

considered when analyzing the results of modeling analysis prepared using this inventory. 

Statewide, total NOx and SO2 emissions are projected to decrease from 2002 levels by 

2018. NOx emissions in the 2018 WRAP emission projections 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. 

SO2 mobile and point source emissions are also projected to decrease from 2002 to 2018. 

However, the large increase in area source SO2 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 production activities in the State. Much of the POA 

and EC emissions are due to natural fires that can fluctuate greatly in location and intensity from 

year to year. The 2018 emission inventory assumes 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 Mexico Regional Haze SIP discuss the modeling 

methods and protocol used by theWRAP and NMED 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 that began with selection of the 

modeling system. The WRAP used (1) the Mesoscale Meteorological Model (MM5) 

meteorological model, (2) the Sparse Matrix Operator Kernel Emissions (SMOKE) modeling 

system to generate hourly gridded speciated emission inputs, (3) the Community Multiscale Air 

Quality (CMAQ) photochemical grid model and (4) the Comprehensive Air Quality model with 

extensions (CAMx), as a secondary 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) cells that covers the continental United States, 

portions of Canada and Mexico, and portions of the Atlantic and Pacific Oceans along the east 

and west coasts. Selection of a representative period of meteorology is crucial for evaluating 
39 

baseline air quality conditions and projecting future changes in air quality due to changes in 

emissions of visibility-impairing pollutants. 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 model results were suitable for use in the RH 

assessment of the LTS and for use in the modeling assessment. The 2002 modeling efforts were 

used to evaluate air quality/visibility modeling for a historical episode—in this case, for calendar 

year 2002—to demonstrate the suitability of the modeling systems for subsequent planning, 

sensitivity, and emissions control strategy modeling. Model performance evaluation was 

performed by comparing the output from model simulations with ambient air 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 model to determine the 2018 RPGs using the current 

and future year air quality modeling 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 inventory 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 (monitored 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/guide/final-03-pm-rh-guidance.pdf 

See also “Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter National Ambient Air 

Quality Standards (NAAQS) and Regional Haze Regulations,” August 2005, updated November 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 Technical Products Prepared by the Western Regional Air Partnership (WRAP) 

in Support of Western Regional Haze Plans, February 28, 2011 
40 

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% Worst 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 across 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 apportionment analysis techniques developed by the 

WRAP. The first technique was regional modeling 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, PM2.5, 

and PM10. The WEP tool is based on emissions and residence 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 transformations, transport, and removal of 

NOX and SO2. These two pollutants are important because they can be significant contributors to 

visibility impairment and much of the total mass of NOx and SO2 originates from anthropogenic 

sources. Therefore, the results from this analysis can be useful in determining contributing 

sources that may be controllable, both in-state and in neighboring states. 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 percent contribution of nitrate 

and sulfate from the WRAP and other source regions to modeled visibility impairment on the 

20% worst days for 2002. Also shown is the percentage of the WRAP contributions from New 

Mexico sources. The Central Regional Air Planning Association (CENRAP) region includes the 

states and tribal areas of Nebraska, Kansas, Oklahoma, Texas, Minnesota, Iowa, Missouri, 

Arkansas, and Louisiana. Some errors were discovered 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 states, BART requirements and reductions through 

                                                           

23 WRAP technical products are available at http://vista.cira.colostate.edu/tss/ 
41 

the SO2 emission milestone trading program will result in additional NOx and SO2 reductions 

beyond than those assumed in the source apportionment modeling. 

Table 14 - Percentage of Nitrate Contribution to Visibility Impairment 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 Impairment 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 identify source regions that have the potential to 

contribute to haze formation at specific Class I areas. Unlike PSAT, this method does not 

account for chemistry or deposition. 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 TSS 
42 

and residence times of air masses over each area where 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 expected 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 this 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 contributions are provided for other 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 natural fires. More than 65% of 

CM emissions are from wind-blown dust. As discussed above, 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 associated 

with anthropogenic activities and are controllable have a minimal effect on visibility at New 

Mexico’s Class I areas, compared to other sources of windblown dust. A large portion of EC 

emissions are also due to natural fires, while mobile emission sources also contribute to the total 

EC emissions. EC emissions from mobile sources are expected to decrease significantly by 2018. 

These pollutants, primarily from natural sources, contribute significantly to visibility impairment 

in New Mexico. 
43 

Figure 5 – OMC and EC Emissions Affecting New Mexico’s Class I Areas 

D.3.c.i Sources of Visibility Impairment in Bandelier Wilderness 

Visibility impairment at Bandelier 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 Bandelier on the 20% worst days come from sources outside 

the modeling domain (26%), followed by point sources in CENRAP states (14%), the Eastern 

United States (11%), New Mexico (11%), and Mexico (8%). New Mexico area sources 

contribute 2% of the sulfate on these days. 

The 2018 projections assume that natural fire emissions of OMC 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 expected to increase. Visibility impairment due 

to sulfate is projected to decrease by 2018, due to large decreases in emissions in CENRAP 

states and the Eastern United States. Sulfate contributions 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, SO2 emissions 

from area source emissions in New Mexico, particularly in Bernalillo County, are overestimated 

in the WRAP modeling. Bandelier is located only 83 km outside of Bernalillo County and is 
44 

impacted by the WRAP’s large assumed increase in SO2 emissions. 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 additional 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 16 shows the percent contribution (PSAT modeling 

results) to sulfate and nitrate from the WRAP states, Canada (CAN), Mexico (MEX), Eastern 

United States (EUS) and outside of the domain (OD) on the 20% worst days for both 2002 and 

2018. Figure 6 shows the regional contributions to sulfate and Figure 7 shows the area source 

contributions to sulfate on the 20% worst days. 

Table 16 - Percent Contribution to Sulfate and Nitrate on the 20% worst 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 days at Bandelier Wilderness 

Figure 7 - Contributions to sulfate from area sources on 20% worst days at Bandelier Wilderness 

 

D.3.c.ii Sources of Visibility Impairment in Bosque 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 emissions are primarily from natural fires from NM and 

AZ. In 2002, the largest contributions of sulfate to Bosque del Apache on the 20% worst days 

come from point sources in CENRAP states (19%), sources outside 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. Contributions of nitrate are from mobile sources in New Mexico 

(19%) and CENRAP states (10%) along with contributions from New Mexico point sources 

(8%), CENRAP point sources (9%) and New Mexico area sources (7%). 

The 2018 projections assume that natural fire 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 emissions from windblown dust 

are held constant from 2002 levels and remain a significant contribution to visibility impairment 
46 

in 2018. Visibility impairment due to sulfate is projected to decrease by 2018, due to large 

decreases in emissions in CENRAP states and the Eastern United States. Sulfate contributions to 

visibility impairment at Bosque del Apache 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, SO2 emissions from area source emissions in New Mexico, 

particularly in Bernalillo County, are overestimated in the WRAP modeling. Contributions of 

nitrate from CENRAP states and New Mexico from mobile sources are projected to decrease 

significantly, while contributions from area source emissions, including 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 additional 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 the 20% worst days for both 2002 and 2018. Figure 8 shows the 

regional contributions to sulfate and Figure 9 shows the area source 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 Sulfate on 20% worst days at Bosque del Apache 
48 

Figure 9 - Contributions to sulfate from area sources on 20% worst days at Bosque del Apache 

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

Visibility impairment at Carlsbad Caverns in 2002 on the worst 20% days is largely due 

to sulfate and CM. The IMPROVE monitoring site for Carlsbad Caverns is located in 

Guadalupe Mountains National Park, 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 States (39%), CENRAP states (23%), and Mexico (9%). CM 

emissions impacting Carlsbad Caverns are primarily from windblown dust in New Mexico and 

neighboring CENRAP states. WEP results for organic carbon indicate that contributions are 

from area source emissions in CENRAP states and 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 Carlsbad Caverns from Mexico will 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 significantly, while 

contributions from area source emissions, including 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 Mexico impacting Carlsbad Caverns decrease 

significantly by 2018. 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 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 results) to sulfate and nitrate on the 20% worst days for both 2002 
49 

and 2018. Figure 10 shows the regional contributions to sulfate and Figure 11 shows the area 

source contributions to sulfate on the 20% worst days. 

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

Figure 11 - Contributions to sulfate from area sources on 20% worst days at Carlsbad 

Caverns 

D.3.c.iv Sources of Visibility Impairment in Gila Wilderness 

Visibility impairment 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 impairment at Gila during the base period. In 2002, the 

largest contributions of sulfate to Gila Wilderness on the 20% worst days come from sources 

outside the modeling domain (20%), followed by point sources in the Eastern United States 

(17%), Mexico (17%), CENRAP states (16%), and Arizona(5%). We note that an error in data 

retrieval affected initial results for modeled visibility conditions 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.edu/tss/help/plan02d_rev.pdf
51 

The 2018 projections assume that natural fire emissions of OMC remain constant 

between 2002 and 2018. In 2018, visibility impairment is still primarily due to OMC from 

natural fires. 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 Gila from Mexico, Arizona, and New Mexico increase 

from 2002 levels due to increases in emissions from point sources. Table 19 shows the percent 

contribution (PSAT modeling results) to sulfate and nitrate on the 20% worst days for both 2002 

and 2018. Figure 12 shows the regional contributions to sulfate and Figure 13 shows the area 

source contributions to sulfate on the 20% worst days. 

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

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 Contributions to Sulfate on 20% worst days at Gila Wilderness 

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

Wilderness 

D.3.c.v Sources of Visibility Impairment in Pecos Wilderness and Wheeler Peak 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 modeling domain (26%), followed by point sources in 

CENRAP states (15%), Mexico (9%), the Eastern United States (6%), and New Mexico (6%). 

Contributions from New Mexico natural fires are 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 expected to increase. 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 
53 

Pecos/Wheeler Park 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, 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 additional 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 20 shows the percent contribution (PSAT modeling results) 

to sulfate and nitrate on the 20% worst days for both 2002 and 2018. Figure 14 shows the 

regional contributions to sulfate and Figure 15 shows the area source contributions to sulfate on 

the 20% worst days. 

 

Table 20 - Percent Contribution to Sulfate and Nitrate on the 20% worst days 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 days 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 Impairment in Salt Creek Wilderness 

Visibility impairment at Salt Creek in 2002 on the worst 20% days is largely due to 

sulfate, nitrate, OMC and CM. In 2002, the largest contributions of sulfate to Salt Creek on the 

20% worst days come from point sources in the Eastern United States (28%), CENRAP states 

(24%), Mexico (9%), and New Mexico (6%). Contributions 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 neighboring CENRAP states. 

WEP results for organic carbon indicate that contributions are from area source emissions in 

CENRAP states and 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 emissions in CENRAP states and the Eastern United States. Sulfate contributions to 
55 

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 significantly, while contributions from area source 

emissions, including 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 Mexico impacting Salt Creek decrease significantly by 2018. 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 

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 Salt Creek 

due to lower NOx emissions and lower SO2 area emissions than included in the WRAP 2018 

modeling episode used in this analysis. Table 21 shows the percent contribution (PSAT modeling 

results) to sulfate and nitrate 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 contributions to sulfate 

on the 20% worst days. Figure 18 shows the regional contributions to nitrate and Figure 19 

shows the source region and source type contributions to sulfate on the 20% worst days. 

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

Figure 17 - Contributions to Sulfate from Area Sources on 20% worst days at Salt Creek 
57 

Figure 18 - Regional Contributions to Nitrate on 20% worst days at Salt Creek 

Figure 19 - Source Region/Type Contributions to Nitrate on 20% worst days at Salt Creek 

D.3.c.vii Sources of Visibility Impairment in White Mountain 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% days is largely due to sulfate, 

nitrate, OMC and CM. Compared to Salt Creek, visibility 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 the 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 point sources in New Mexico and CENRAP states. 

CM emissions impacting White Mountain are primarily from windblown dust in New Mexico 

and neighboring CENRAP states. WEP results for organic carbon indicate that 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 the Eastern United States. Sulfate contributions to 

visibility impairment at White Mountain from Mexico increase from 2002 levels due to increases 

in emissions from point sources. Contributions of nitrate from CENRAP states and New Mexico 
58 

from mobile sources are projected to decrease significantly, while contributions from area source 

emissions, including emissions from oil and gas production in New Mexico and the CENRAP 

states are projected to increase. 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 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 White Mountain due to lower NOx and SO2 emissions than 

included in the WRAP 2018 modeling episode used in this analysis. Table 22 shows the percent 

contribution (PSAT modeling results) to sulfate and nitrate on the 20% worst days for both 2002 

and 2018. Figure 20 shows the regional contributions 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 Nitrate on the 20% worst days at White 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 Sulfate on 20% worst days at White Mountain 

Figure 21 - Contributions to Sulfate from Area Sources on 20% worst days at White Mountain 
60 

Figure 22 - Regional Contributions to Nitrate on 20% worst days at White Mountain 

Figure 23 - Source Region/Type Contributions to Nitrate on 20% worst days at White Mountain 

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

CAMx PSAT results were also utilized to evaluate the impact of New Mexico emission 

sources in 2002 on visibility impairment at Class I areas outside of the state. Section 12.2 of the 

NM RH 309(g) SIP 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. 

See section III.A of this TSD for additional information of New Mexico’s contributions to ClassI 

areas in nearby states. New Mexico emissions are responsible for up to 60% of the nitrate and 

43% of the sulfate at individual Class I areas in neighboring states on the 20% worst visibility 

days during the baseline period. The highest impact from New Mexico 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 areas 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 RHR 
61 

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 modeling, monitoring, and emissions information, on 

which it relied upon to determine its apportionment of emission reduction obligations necessary 

for achieving reasonable progress in each mandatory Class I federal area it affects.27 The record 

also supports a finding that New Mexico has adequately identified all anthropogenic sources of 

visibility impairment it considered in developing its LTS. We therefore recommend finding that 

New Mexico has satisfied the requirements under section 308(d)(3)(iii) – (iv). 

D.4 Consideration of Long Term Strategy Factors: 40 CFR 51.308(d)(3)(v) 

Section 51.308(d)(3)(v) requires that New Mexico minimally consider 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 retirement and replacement 

schedules; (e) smoke management techniques for agricultural and forestry management purposes 

including plans as currently exist within the state 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 SO2 emission milestone 

and trading program, New Mexico’s LTS incorporates emission reductions due to a number of 

ongoing air pollution control programs. This includes enforceable emissions limitations, 

compliance schedules, administrative orders, the 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 ongoing 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 review of each factor follows: 

D.4.a Emission reductions due to ongoing air pollution control programs, including 

measures to address reasonably attributable visibility impairment 

The two primary regulatory tools for addressing visibility impairment from industrial 

sources are BART and the Prevention of Signification Deterioration (PSD) /New Source Review 

(NSR) rules. The New Mexico PSD rules protect visibility in Class I areas from new major 

industrial sources and major changes to existing sources . New Mexico’s PSD SIP rules (20.2.74 

NMAC) contain requirements for review of visibility impact assessment from new and modified 

major stationary sources within 100 km of a Class I area. New Mexico’s Construction Permits 

SIP rule (20.2.72 NMAC) addresses construction or modifications of sources, including minor 

sources, and assures compliance with ambient air quality standards. New Mexico’s Operating 

Permit Program (20.2.70 NMAC) consolidates all air quality regulatory requirements and 

provides for appropriate compliance assurance monitoring 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 sources 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 areas 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 (MACT) under 20.2.82 NMAC which may result in 

reductions of emissions of visibility impairing pollutants. 

We approved New Mexico’s Visibility 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 reasonably attributable visibility impairment in 

New Mexico’s Class I areas through visibility monitoring and control strategies. It includes PSD 

requirements for visibility protection and applying BART to existing sources if certified as 

causing RAVI. 

Mobile source annual emissions show a major decrease in NOx in New Mexico from 

2002 to 2018. This reduction will result from numerous ‘‘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 diesel fuel from 500 parts per million (ppm) to 15 

ppm. Ultra-low sulfur diesel fuel enables the use of cleaner technology diesel engines and 

vehicles with advanced emissions control devices, resulting in significantly lower emissions. 

Diesel fuel intended for locomotive, marine, and non-road (farming and construction) engines 

and equipment was required to meet a low sulfur diesel fuel maximum specification of 500 ppm 
63 

sulfur in 2007 (down from 5000 ppm). By 2010, the ultra-low sulfur diesel fuel standard of 15 

ppm sulfur applied to all non-road diesel fuel. Locomotive and marine diesel fuels are required to 

meet the ultra-low sulfur diesel standard beginning in 2012, resulting in further reductions of 

diesel emissions. New Mexico also considered ongoing federal mobile source regulations 

including the Tier 2 Vehicle Emission Standards, 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 established 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 impacts of construction activities 

Section 51.308(d)(3)(v)(B) requires that New Mexico consider measures to mitigate the 

impacts of construction activities in developing its LTS. New Mexico considered developing a 

rule to address fugitive dust. New Mexico conducted 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 Events Action Plans developed 

for Dona Ana and Luna Counties contain procedures for the use of control measures for 

anthropogenic sources of wind-blown dust. These control measures include the use of dust 

suppressants, phased construction, and stopping or slowing construction activities during high 

winds to mitigate the impacts of construction activities on visibility impairment. We also note 

that Bernalillo County, which falls under the jurisdiction 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) SIP 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 the reasonable 

progress goal 

40 CFR 51.308(d)(3)(v)(C) requires that in developing its LTS, New Mexico consider 

emissions limitations and schedules of compliance to achieve the RPGs.. The SIP contains 

emission reduction milestones and a backstop trading program that addresses SO2 emissions 

from point sources in the State. The backstop trading program provides emission limits and 

schedules of compliance for SO2 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 NOx BART determination consistent with the 

RHR. We are not reviewing the submitted NOx BART determination for purposes of this 

proposal, but this does not interfere with our recommendation that the record supports a finding 

that this requirement is satisfied. 

D.4.d Source retirement and replacement schedules 

The State does not anticipate any specific major source retirements or replacements. 

Replacement of existing facilities will be managed 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 agricultural and forestry management purposes 

including plans as currently exist within the State for these purposes 

40 CFR 51.308(d)(3)(v)(E) requires that New Mexico consider smoke management 

techniques for agricultural and forestry management purposes in developing its LTS. New 
65 

Mexico’s smoke management plan and Smoke Management Rule (20.2.65 NMAC) are 

described in Section V.H of the Federal Register notice. 

Evaluation: 

The submittal supports a finding that the smoke management plan appropriately contains 

smoke management techniques for agricultural and 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 limitations and control measures 

 

Section 51.308(d)(3)(v)(F) requires that New Mexico ensure the enforceability of emission 

limitations and control measures used to meet reasonable progress goals. With the exception of 

the NOx BART limit included in the FIP, all existing 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 enforceable 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 submitted determination that, on EPA approval, 

replaces those requirements. See 70 FR at 39172. 

 

Evaluation: The submittal supports a finding that NMED 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 emissions 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 visibility 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 the 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 SIP Requirements: 40 CFR 51.308(d)(4) 

New Mexico must submit with the SIP a monitoring strategy for measuring, 

characterizing, and reporting of regional haze visibility 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 attributable visibility impairment. 

Compliance with this requirement may be met 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 additional monitoring sites or equipment needed to assess 

whether reasonable progress goals to address regional haze for all mandatory Class I 

Federal areas within New Mexico are being achieved. 

(ii) Procedures by which monitoring data and other information are used in determining the 

contribution of emissions from within New Mexico to regional haze visibility impairment 

at mandatory Class I Federal areas both 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 determining 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 mandatory 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 pollutants 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 update the inventory periodically. 
67 

(vi)Other elements, including reporting, recordkeeping, and other measures, necessary to 

assess and report on visibility. 

State Submittal: Chapter 4 

As Section 51.308(d)(4) notes, compliance with this requirement may be met through 

participation in the IMPROVE network, which applies to the monitors at all Class I areas in New 

Mexico. The State of New Mexico is relying on the IMPROVE program to meet these 

monitoring operation and data collection 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 that, resources for operation and sample analysis of a complete 

and representative monitoring network of these long-term reasonable progress tracking sites by 

the IMPROVE program are a collaborative responsibility of EPA, states, tribes, and FLMs and 

the IMPROVE program steering committee. The State of New Mexico will collaborate with the 

EPA, FLMs, other states, tribes, and the IMPROVE committee to assure adequate and 

representative data collection and reporting by the IMPROVE program. 

The IMPROVE Steering Committee consists of representatives from the FLMs, us, and 

regional-state agencies. At the direction of the National Park Service, the Cooperative Institute 

for Research in the Atmosphere, at Colorado State University’s Foothills Campus in Fort 

Collins, Colorado, maintains the network plan on the IMPROVE Internet Web site.28 The 

primary objectives of the IMPROVE Web site are to provide federal, state, and air quality 

regulatory agencies as well as the general public 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 progress 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 monitored visibility data corresponds. 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 were 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 Wilderness 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 determining the contribution of emissions from within a 

state to RH visibility impairment at mandatory Class I Federal areas both within and outside the 

state. The IMPROVE monitoring program is national in scope, and other states have similar 

monitoring and data reporting procedures, ensuring a consistent and robust monitoring data 

collection system. As section 51.308(d)(4) indicates, participation in the IMPROVE program 

constitutes compliance with this requirement. The submittal supports a finding that this 

requirement is satisfied. 

Section 51.308(d)(4)(iv) requires that RH SIPs provide for the reporting of all visibility 

monitoring data to the Administrator at least annually for each mandatory Class I Federal area in 

the state. To the extent possible, New Mexico should report visibility monitoring data 

electronically. Section 51.308(d)(4)(vi) also requires that NMED provide for other elements, 

including reporting, recordkeeping, and other measures, necessary 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 least annually, is easily accessible, and therefore the 

309(g) SIP submittal complies with this requirement. 

Section 51.308(d)(4)(iv) requires that NMED maintain a statewide inventory of 

emissions of pollutants 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 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 review periodic emissions information 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 Mexico has satisfied the requirements of 

section 51.308(d)(4). 

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

Pursuant to 40 CFR 51.309(d)(4)(vii), a section 309 SIP must 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 Mexico must submit a SIP containing emission 

limitations representing Best Available Retrofit Technology (BART) and schedules 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 Federal area, unless 

it demonstrates that an emissions trading program or other alternative will achieve greater 

reasonable progress toward natural visibility conditions. 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 schedules 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 Federal area” is conducted 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 method of satisfying the Section 

308 SO2 BART requirements with emission milestones 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 application of BART pursuant to 40 CFR 51.308(e)(2). This SO2 emission 

milestones and a backstop trading program is discussed 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 Identification: 40 CFR 51.308(e)(1)(i) 

New Mexico must submit a SIP containing a list of all BART-eligible sources within the State. 

Note: This section is intended to cover the general question of whether the state identified which 

sources were subject to BART. Subsequent sections treat 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 year 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, and 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, and 
71 

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 existence 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); Public Service Company of New 

Mexico, San Juan Generating Station Boilers 1 through 4; Giant Refining San Juan Refinery 

(now Western Refining Southwest, Bloomfield Refinery) Unit #1 fluid catalytic cracking unit 

electrostatic precipitator; DEFS Artesia Gas Plant (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 Gas Plant (now Oxy USA WTP Indian Basin Gas 

Plant) sulfur recovery unit; DEFS Linam Ranch 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 Public Service Cunningham Station; Southwestern 

Public Service Maddox Station; El Paso Rio Grande Generating Station. 

Evaulation: 

 The submittal supports a finding that NMED has adequately identified 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 have the option of exempting a BART-eligible 

source from the BART requirements based on dispersion modeling demonstrating that the source 

cannot reasonably be anticipated to cause or contribute 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 subject to BART. Appendix C of the submitted 

NM RH SIP for 309(g) summarizes the initial 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 anticipated to cause or 
72 

contribute to impairment of visibility in Class I areas, i.e., “is subject to BART”. The Guidelines 

state that we believe CALPUFF is the best regulatory modeling application currently available 

for predicting a single source’s contribution to visibility impairment (70 FR 39162). NMED 

relied on WRAP screening modeling using the 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 modeling protocol for 

making individual source attributions, and suggest that states may want to consult with us, FLM 

representatives, and their RPO to address any issues prior to modeling. NMED relied on the 

WRAP to develop a modeling protocol for the BART screening. The procedures used are 

outlined in the WRAP Regional Modeling Center (RMC) BART Modeling Protocol.29 

Stakeholders, including EPA, FLM representatives, 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 applicability of BART to single sources, the 

BART Guidelines note that the first 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 for determining whether a 

source contributes to visibility impairment’ may reasonably differ across states,” but, “[a]s a 

general matter, any threshold that you use for determining whether a source ‘contributes’ to 

visibility impairment should not be higher than 0.5 deciviews.” 70 FR 39104, 39161. Further, in 

setting a contribution threshold, states should “consider the number of emissions sources 

affecting the Class I areas at issue and the magnitude of the individual sources’ impacts. The 

Guidelines affirm that states are free to use a lower threshold if they conclude that the location of 

a large number of BART-eligible sources in proximity of a Class I area justifies this approach. 

NMED and the WRAP used a contribution threshold 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’ SO2, 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 modeled visibility impacts well above 0.5 dv, the highest visibility 

impact of the remaining BART-eligible sources 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/WRAP_RMC_BART_Protocol_Aug15_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, 2010 
73 

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 basis, causes visibility impairment 

at all 16 Class I areas that lie within 300 km of the facility 

 

Evaluation: 

NMED provided the WRAP’s screening modeling results in Appendix C of the RH 

309(g) SIP for all sources identified as BART-eligible 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 impacts 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 and CALPUFF v6.112) utilized by the WRAP 

since the original WRAP CALPUFF 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 errors, therefore a version of 

CALPUFF that was indicated as having corrections 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 conducted 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 the required regulatory review in 

updating the regulatory version of the model. EPA’s review indicated that some of the ‘bug’ 

fixes were addressed but that there were other significant changes, including changes in default 

options, that had been incorporated in the VISTAS and v6.112 versions. EPA’s determined that 

some of these changes were not approvable and worked with the model developer to include the 

‘bug’ fixes and changes EPA agreed were acceptable 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 regulatory action on June 29, 2007. The CALPUFF 

modeling system approved at that time included CALPUFF version 5.8, level 070623, CALMET 

version 5.8 level 070623, and CALPOST version 5.6394, level 070622. 

 In support of the FIP, modeling was performed by EPA that allows for the comparison of 

model results between the WRAP’s CALMET 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/regionalstatelocalmodelingworkshop/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_final.pdf); “CALPUFF Regulatory 

Update”, Roger W. Brode, Presentation at Regional/State/Local Modelers Workshop, June 10-12, 2008, available at 

(http://www.cleanairinfo.com/regionalstatelocalmodelingworkshop/archive/2008/presentations/BRODE_CA.pdf). 32 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. 
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 differences 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 subject 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 these sources that screened out, 

EPA chose to examine those sources with the highest 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 the values are consistent with the original conclusions. In the 

WRAP’s modeling the highest impact in a year was 0.34 dv from any 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 sources other than the SJGS screen out of a full 5-

factor BART analysis. 

 

For the SJGS, the WRAP’s results of the screening 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 based on the installed control technology at the time 

and does not reflect emission reductions due to the installation of consent decree33 controls. 

Revised modeling performed by NMED and by us, including controls required by the consent 

decree and currently installed, further confirmed that 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 impairment at the remaining areas on a facility-wide basis. Furthermore, 

on an individual unit basis, all units ‘‘cause’’ visibility impairment at Mesa Verde National Park, 

and cause or contribute to visibility impairment 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 has 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 average 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 impact 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 only New Mexico sources subject to BART. 

F.3. BART Five Factor Determination: 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 BART 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 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 that is subject to BART within the State. In 

this analysis, New Mexico must take into consideration the technology available, the costs of 

compliance, the energy and non-air quality environmental impacts of compliance, any pollution 

control equipment in use at the source, the remaining 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 perform the BART analysis. The BART Guidelines35 

describe the BART analysis as consisting of the following five basic steps: 

• Step 1: Identify All Available Retrofit Control Technologies, 

• Step 2: Eliminate Technically 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 generating units and associated support facilities. 

Each coal-fired unit burns pulverized coal and No. 2 diesel oil (for startup) 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 BART Determinations under the 

Regional Haze Rule) 

                                                           

35 70 FR 39164. 
76 

In June, 2007, the operator of the SJGS, Public Service Company of New Mexico (PNM) 

submitted its PM evaluation to NMED. That evaluation 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 SO2

are met through New Mexico’s participation in a SO2 milestone emissions and backstop trading 

program. 

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

State Submittal: Section 10.4 and Appendix D 

 

The SJGS currently has pulse jet fabric filters installed and an emission 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 Available 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 also identified wet ESP (WESP). 

Step 2- Eliminate Technically Infeasible Options: Hot-side ESP and compact hybrid particulate 

collector were eliminated because these technologies were determined to not provide control 

performance lower than the currently permitted limit for PM. The max-9 electrostatic fabric 

filter was also eliminated due to limited application in large utility boilers. WESP and PJFF 

were determined to be technically feasible and were evaluated in PNM’s BART analysis for 

PM.37 

Step 3- Evaluate Control Effectiveness of Remaining Control Technologies: PNM determined 

that PJFF and WESP are capable of achieving emission limits of 0.015 lb/MMBtu PM and 0.010 

lb/MMBtu PM, respectively. 

                                                           

36 Public Service Company of New Mexico, San Juan Generating 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 Generating 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 impacts, 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 consumption, and waste water disposal 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-effectiveness 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 control technology and an existing 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 jet 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-effectiveness and incremental cost-effectiveness 

of additional control technology (WESP) and found these costs to be excessive. 

3. There are no non-air impacts associated 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 improvement 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 (Mesa Verde). The installation 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 Manual38, where possible, as directed by the BART Guidelines.39 For 

                                                           

38 U.S. EPA, EPA Air Pollution Control Cost Manual, Report 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 visibility improvement of 0.62 dv from WESP being 

installed on all four units at Mesa Verde and 0.14 dv improvement at San Pedro Parks. Visibility 

benefits at other Class I areas are below 0.1 dv. As discussed in detail in the FIP and 

accompanying TSD41, 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 anticipated 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 determination 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 any mandatory Class I Federal area. All such sources are subject to 

BART. New Mexico is not required to make a determination of BART for SO2 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 potential to emit less than 15 tons per year of such 

pollutant. 

State Submittal: 

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

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

 

If New Mexico determines in establishing BART that technological or economic 

limitations on the applicability of measurement methodology to a particular source would make 

                                                           

40There 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 making and are also available 

in the docket to our FIP (Docket No. EPA-R06-OAR-2010-0846). 
79 

the imposition of an emission standard infeasible, it may instead prescribe a design, equipment, 

work practice, or other operational 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, equipment, work practice or operation, and must 

provide for compliance by means which achieve equivalent results. 

State Submittal: 

 NMED did not determine that technological or economic limitations on the applicability 

of measurement methodology to a particular source would make the imposition of an emission 

standard infeasible. NMED did not prescribe a design, equipment, work practice, or other 

operational standard, or combination thereof, 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) install and operate BART as expeditiously as 

practicable, but in no event 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 require 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 emissions trading program or other 

alternative measure rather than require sources subject to BART to install, operate, and maintain 

BART for PM and NOx. New Mexico’s participation 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 action
80 

F.8 CAIR for BART: 40 CFR 51.308(e)(4) 

 If a State chooses to meet the emission reduction requirements of the Clean Air Interstate 

Rule (CAIR) by participating in one or more of the EPA-administered CAIR trading programs 

for SO2 and NOx, it need not require BART-eligible EGUs subject to such trading programs in 

the State to install, operate, and maintain BART for the pollutants covered by such trading 

programs in it. The State may choose to participate 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 SO2 program) or by remaining subject to the Federal implementation plan in part 97 of 

this chapter (which may be modified by a SIP approved in accordance with sections 51.123(p) 

and (ee) and 51.124(r)). If the State chooses to participate in such trading programs, it may also 

adopt provisions, consistent with such trading programs, for a geographic enhancement to the 

program to address the requirement under section 51.302(c) related to BART for reasonably 

attributable impairment from the pollutants covered by the CAIR cap-and-trade programs. 

Note: This provision of the regional haze rule does 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 for BART or implemented emissions trading 

program or other alternative measure that achieves 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 same 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 requirement under paragraph (e) of this section 

to install, operate, and maintain BART may apply to the Administrator for an exemption from 

that requirement. An application for an exemption 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.