# Clark County Department of Air Quality Ozone Advance Program Path Forward

June 2014Clark County: Ozone Advance Program Path Forward

iiClark County: Ozone Advance Program Path Forward

iii Table of Contents 1. Introduction .................................................................................................................. ........ 1-1 Current Attainment Status...................................................................................................... .. 1-1 Impacts of Meteorological Condition s on Ozone Concentrations ........................................... 1-3 2. Emission Sources .............................................................................................................. ... 2-1 Emissions and Source Categories ............................................................................................ 2- 2 Source Apportionment Modeling ............................................................................................ 2-4 3. Stakeholders .................................................................................................................. ....... 3-1 4. Outreach, Education and Volunt ary Control Measures ....................................................... 4-1 Private Companies ............................................................................................................. ...... 4-4 5. Local Mandatory Measures .................................................................................................. 5-1 Air Quality Regulations ....................................................................................................... .... 5-1 Inspection and Maintenance Program ...................................................................................... 5-2 Renewable Portfolio Standard ................................................................................................. 5-3 Progress ...................................................................................................................... .......... 5-4 Future Planned Projects ....................................................................................................... 5-5 2013 Emission Reductions ................................................................................................... 5- 6 6. Potential Voluntary Control Measures ................................................................................. 6-1 DAQ-Specific .................................................................................................................. ........ 6-1 Electric Vehicle Purchase .................................................................................................... 6-1 Vacuum-Assist Stage II Disab ling Assistance Program ...................................................... 6-1 Vapor Processor Rebate Program ........................................................................................ 6-1 Other Entities ................................................................................................................ ........... 6-1 7. Future Mandatory Control Measures ................................................................................... 7-1 Federal Rules ................................................................................................................. .......... 7-1 Reid Gardner Power Plant ...................................................................................................... . 7-1 Project Neon................................................................................................................... .......... 7-1 Boulder City Bypass ........................................................................................................... ..... 7-2 8. Path Forward Implementation .............................................................................................. 8-1 On-road and Non-road Mobile Emission Reductions .............................................................. 8-1 Stage II Vapor Recovery and Control Systems ....................................................................... 8-1 Congestion Mitigation and Ai r Quality Projects ..................................................................... 8-1 DAQ Public Education and Outreach Program ....................................................................... 8-2 Renewable Portfolio Standard ................................................................................................. 8-2Clark County: Ozone Advance Program Path Forward

iv Conclusion .................................................................................................................... ........... 8-2Clark County: Ozone Advance Program Path Forward

v 

### List of Figures Figure 1-1: Clark County Ozone Maintenance and Attainment/Unclassifiable Areas. ............... 1-1 Figure 1-2: Design Value History. ............................................................................................. .. 1-2 Figure 1-3. Average wind speed s at McCarran (1989-2012). .................................................... 1-4 Figure 1-4. Wind Directions in Clark County. ........................................................................... 1-4 Figure 1-5. Airflow in Clark County. ......................................................................................... 1-5 Figure 2-1. NO x Source Apportionment. .................................................................................... 2-1 Figure 2-2. VOC Source Apportionment. ................................................................................... 2-2 Figure 5-1. Clark County Emi ssions Testing Area. .................................................................... 5-3 Figure 5-2. Monthly NO x Reductions. ........................................................................................ 5-7



### List of Tables Table 1-1. Fourth Highest Concentrations .................................................................................. 1- 3 Table 1-2. 2013 Design Values for Clark County ...................................................................... 1-3 Table 2-1. NO x Emissions for 2008 and 2011 ............................................................................. 2-1 Table 2-2. VOC Emissions for 2008 and 2011 ............................................................................ 2-2 Table 2-3. NO x Emissions in 2011 .............................................................................................. 2-2 Table 2-4. VOC Emissions for 2011 ............................................................................................ 2-3 Table 2-5. Emissions for Reid Gardner ....................................................................................... 2 -3 Table 4-1. Southwest Gas Incentive Programs ............................................................................ 4-6 Table 5-1. Future RE Projects ................................................................................................. ..... 5-5 Table 5-2. New & Proposed Capacities ....................................................................................... 5- 5 Table 5-3. Inputs for AVERT Model ........................................................................................... 5 -6 Table 5-4. Model Outputs ...................................................................................................... ...... 5-6Clark County: Ozone Advance Program Path Forward

vi 

### List of Acronyms and Abbreviations Acronyms AQR Clark County Air Quality Regulation BCC Clark County Board of County Commissioners CFR Code of Federal Regulations DAQ Clark County Depart ment of Air Quality EPA U.S. Environmental Protection Agency I/M Nevada Vehicle Inspecti on and Maintenance Program HA Hydrographic Area MEGAN Model of Emissions of Gases and Aerosols from Nature NAAQS National Ambient Air Quality Standards NAC Nevada Administrative Code NDEP Nevada Division of Environmental Protection NEI National Emissions Inventory NRS Nevada Revised Statues RTC Regional Transportation Comm ission of Southern Nevada SIP state implementation plan SLAMS State and Local Air Monitoring System SBAP Small Business Assistance Program SNFA Southern Nevada Fleet Association SNRCP Southern Nevada Re gional Planning Coalition TAC Technical Advisory Committee WESTAR Western States Air Resources Council Abbreviations CO carbon monoxide KWh kilowatt hour MW megawatt NO x nitrogen oxides ppb parts per billion tpy tons per year VOC volatile organic compoundsClark County: Ozone Advance Program Path Forward

1-1 

### 1. Introduction The Clark County Department of Air Quality ( DAQ) enrolled in EPA’s Ozone Advance program on June 12, 2013. The program’s goal is to help maintenance and attainment areas reduce emissions to ensure continued health protectio n, to better position those areas to remain in attainment, and to efficiently direct available re sources toward actions to address ozone and its precursors quickly. To this end, DAQ has implemen ted a set of stringent Air Quality Regulations (AQRs) in Clark County.


### Current Attainment Status Clark County is a maintenance area for the 1997 8-hour ozone Nationa l Ambient Air Quality Standard (NAAQS) and is in at tainment/unclassifiable for the 2008 8-hour ozone standard. The state of Nevada uses hydrogra phic areas (HAs) to define airs heds. In Clark County, HAs 164A, 164B, 165, 166, 167, 212, 213, 214, 216, 217, and 218 are in the ozone “attainment/unclassifiable” and “m aintenance” areas (Figure 1-1).

Figure 1-1: Clark County Ozone Maintenance and Attainment/Unclassifiable Areas.Clark County: Ozone Advance Program Path Forward

1-2 The redesignation of the Clark County nonattai nment area for the 1997 8-hour ozone standard became effective on February 7, 2012 (Vol. 78, pg. 1149 of the Federal Register [78 FR 1149]). Clark County is an “attainment/unclassifiab le” area under the 2008 8-hour ozone standard. The design value history in Figure 1-2 shows a downward trend from 2007 through 2011; however, the design values increased in 2012 and 2013.

Figure 1-2: Design Value History. Clark County was impacted by several fires during the 2012 and 2013 wildfire seasons, and the impacts from these fires raised the design valu es by a few parts per billion (ppb). Table 1-1 shows the fourth highest concentrations for 2013; the highest concentrations occurred during the fires on May 4 and July 3, 2013.Clark County: Ozone Advance Program Path Forward

1-3 Table 1-1. Fourth Highest Concentrations Monitoring Site Highest Second Highest Third Highest Fourth Highest Date Value Date Value Date Value Date Value Apex 6/21/2013 78 4/30/2013 74 5/5/2013 73 5/4/2013 73 Mesquite 5/22/2013 68 5/16/2013 68 6/21/2013 67 6/18/2013 67 Paul Meyer 7/3/2013 87 5/4/2013 80 5/25/2013 76 6/21/2013 75 Walter Johnson 7/3/2013 87 5/4/2013 80 5/25/2013 75 7/19/2013 74 Palo Verde 7/3/2013 83 5/4/2013 82 5/25/2013 76 7/19/2013 74 Joe Neal 7/3/2013 81 6/21/2013 77 5/4/2013 77 7/20/2013 76 Winterwood 5/4/2013 76 6/21/2013 75 5/25/2013 73 5/21/2013 71 Jerome Mack 5/4/2013 74 5/25/2013 73 6/21/2013 72 5/21/2013 69 Boulder City 6/21/2013 74 5/22/2013 72 5/21/2013 72 6/22/2013 71 Jean 5/4/2013 84 5/21/2013 78 5/25/2013 76 6/21/2013 75 JD Smith 6/21/2013 76 5/25/2013 74 5/4/2013 74 6/5/2013 72 DAQ has submitted an exceptional event package for wildfires on May 23, 2012, and is in the process of completing exceptional event packag es for the 2013 fires. Hopefully, the Region 9 office of the U.S. Environmental Protection Agen cy (EPA) will concur with our findings, which will lower the design values near or under th e NAAQS. Our design value for calendar year 2013 is currently 77 ppb (Table 1-1). Table 1-2. 2013 Design Values for Clark County Monitoring Site Fourth Highest Average DV 2011 2012 2013 Jerome Mack 73 76 69 72 Paul Meyer 78 77 75 76 Winterwood 73 74 71 72 Joe Neal 77 80 76 77 Boulder City 70 77 71 72 Jean 74 77 75 75 Walter Johnson 77 78 74 76 Palo Verde 77 78 74 76 J.D. Smith 72 76 72 73 

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2-3 TIER 1 NAME NOx % of Total SOLVENT UTILIZATION 0.36 0.00 METALS PROCESSING 0.20 0.00 TOTAL 53,562.48 100.00 Biogenics make up the highest category of VOC emissions, accounting for 76% of the 2011 total. On-road vehicles are the second-highest category, fo llowed by solvent utilization.
Table 2-4. VOC Emissions for 2011 TIER 1 NAME V OC % of Total BIOGENICS - VEGETATION & SOIL 126,574.00 76.52 HIGHWAY VEHICLES 12,744.08 7.70 SOLVENT UTILIZATION 12,675.41 7.66 OFF-HIGHWAY 8,838.12 5.34 STORAGE & TRANSPORT 2,057.69 1.24 FUEL COMB. OTHER 1,114.26 0.67 OTHER INDUSTRIAL PROCESSES 497.77 0.30 MISCELLANEOUS 340.28 0.21 WASTE DISPOSAL & RECYCLING 318.84 0.19 FUEL COMB. ELEC. UTIL. 227.02 0.14 FUEL COMB. INDUSTRIAL 13.29 0.01 PETROLEUM & RELATED INDUSTRIES 11.26 0.01 METALS PROCESSING 4.76 0.00 TOTAL 165,416.80 100.00 The Reid Gardner power plant, owned by NV Energy, contributed 80% of the utility NO x total in 2011, or 3,034 tons per year (tpy) (Table 2-5).
Table 2-5. Emissions for Reid Gardner TPY Percent NEI 2011 Utilities 3,788.70 100.00% Reid Gardner utility boilers 2011 3,034.02 80.08% Reid Gardner utility boilers 2013 1,847.85 60.90%Clark County: Ozone Advance Program Path Forward

2-4 In June 2013, Nevada’s governor signed a law accelerating the retireme nt of Reid Gardner Generating Station. Three of the plant's four un its will close in 2014, and the remaining unit will close in 2017. Currently, the boilers are coal fired; the fuel conversion from coal to natural gas at the plant will significantly reduce NO x emissions in Clark County. According to EPA’s Air Markets Program Data, 3 total 2011 NO x emissions in Clark County were 3,789 tpy, with a Reid Gardner contribution of 3,034 tpy, or 80 percent. In 2013, however, Reid Gardner NO x emissions were 1,848 tpy, a reduction of 61 percent from 2011 levels (Table 2-5). To offset the closure of the plant, NV Energy will constr uct or obtain 150 megawatts (MW) of renewable energy in upcoming years. 

### Source Apportionment Modeling DAQ has conducted several studies to characterize ozone transport, and the results show that interstate transport si gnificantly impacts Clark County. Tran sport from Asia and stratospheric ozone intrusions also contribute to ozone concentrations. Howeve r, it is almost impossible to quantify transport contributions from any of thes e sources. Nevertheless, DAQ plans to perform source apportionment modeling in the near future, with the goal of identifying sources that affect ozone concentrations in the count y. The new computer modeling pl atform that EPA is proposing may be able to analyze interstate transport and better characterize source contributions. Past modeling results show that the background ozone concentrati on in Clark County is between 40 and 45 ppb. The same results also show that transport into Clark County from inside and outside the United States is between 20 and 40 percent, depending on the episode.

3 http://ampd.epa.gov/ampd/.Clark County: Ozone Advance Program Path Forward

3-1 

### 3. Stakeholders DAQ has engaged with stakeholder groups for ma ny years to provide a forum to review and provide feedback on state implementation pl ans, Exceptional Event Rule demonstration packages, county rulemakings, etc. Stakeholde r groups include members of the regulated community, environmental groups, other Clark County communities, state agencies, and the EPA. In August 2001, the department’s Ma nagement Board established the Technical Advisory Committee (TAC) . The TAC consists of representatives from local and state governments, as well as private sector stak eholders. Its mission is to:

 Provide input on technical and policy i ssues to the Clark County Air Quality Management Board and the Ex ecutive Advisory Committee;

 Discuss and recommend solutions to conflicts, challenges, or policy i ssues relating to air quality programs in Clark County;

 Ensure that the respective governing bodies of local governments and state agencies are kept abreast of all issues of concern, challenges, and pr ogress in the development and implementation of air quality programs in Clark County; and

 Provide assistance to th e DAQ management staff. The TAC provides essential oversight and assi stance in building cons ensus on policy and technical issues and in resolving problems as we move forward with a variety of programs to improve air quality in southern Nevada. The committee is scheduled to meet quarterly; occasionally, more frequent meetings are needed to address specific issues and work programs. All meetings of the TAC are publicly noti ced, and the public is invited to attend. Members of the Technical Advisory Co mmittee (TAC) represent the following:

 Clark County

 City of Boulder City

 Regional Transportation Commission

 Nevada Division of Environmental Protection

 City of North Las Vegas

 City of Henderson

 Nevada Division of Weights and Measures

 City of Mesquite

 Associated General Contractors

 Various citizen and environmental groups

 Southern Nevada Homebuilders AssociationClark County: Ozone Advance Program Path Forward

3-2  Bureau of Land Management

 Clark County Department of Aviation

 Nevada Department of Transportation (NDOT)

 Nevada Department of Agriculture

 University of Nevada, Las Vegas (UNLV)

 Western States Petroleum Association

 American Trucking Association

 Public Utilities Commission

 Silver State Materials Corporation

 Nevada Motor Transport Association

 Manufacturing industry

 Las Vegas Paiute Tribe.
Clean Cities ( Las Vegas Clean Cities Coalition ) is an organization that works with vehicle fleet managers, fuel suppliers, community leaders, a nd others throughout the c ounty to decrease fuel use in transportation. The Southern Nevada Fleet Association ( SNFA ) is a subcommittee of Clean Cities, a nonprofit whose goal is to improve efficiency and reduce operating costs by advancing clean technologies, networking be tween agencies, education, and training. SNFA provides the following tools to its members:

 Technical training, both for fl eet managers and technicians

 Educational programming

 Networking

 Newsletters

 Problem-solving forums

 Strategies for reducing operating costs

 Grant access and information

 High-level speakers, manufactur ers, and expert panels

 Best practices for fleets

 Fleet scorecards and benchmarking

 Web site blogs and forums

 Equipment and vehicle purchasing methods

 Specification writing and a library of sample specifications. The Metropolitan Planning Subcommittee ( MPS ) assists the Southern Nevada Regional Transportation Commission (RTC) Executiv e Advisory Committee in preparing recommendations to the RTC Board. The subcom mittee considers trans portation planning that needs further analysis. Members include the planning agency manager of each RTC memberClark County: Ozone Advance Program Path Forward

3-3 entity, the NDOT chief of program development, the director of the Department of Aviation, and the planning agency director of any incorpor ated city in Clark C ounty. Additional members include DAQ staff and representatives from th e Nevada Taxicab Authority, the Clark County School District, the Bureau of Land Management , the Southern Nevada Water Authority, public mass transit operators in Clark County, and the urban goods/freight tran sportation industry. The Southern Nevada Regional Planning Coalition ( SNRPC) recognizes that fast growth brings about many challenges that transcend gov ernmental jurisdictional boundaries. In January 2000, Clark County, the cities of Boulder City, Henderson, Las Vega s and North Las Vegas, and the Clark County School District en tered into an agreement to esta blish the SNRPC. Its purpose, guided by a 10-member board, is to “focus and capit alize on strategies that create a sustainable and balanced environment where economic and fi scal vibrancy, social equity, environmental preservation, and physical improvements are expe rienced by all in the community.” Projects include the Sustainability Initiatives, Southern Nevada Strong, the Committee on Homelessness, and the Regional Open Space & Trails project. The legal authority for the Advisory Committee on Contro l of Emissions from Motor Vehicles was established by the 2013 Nevada Legislature in Nevada Revised Statute (NRS) 445B.830, as amended by Senate Bill 148 . The committee was charged to:

a. Establish goals and objectives for the program for contro l of emissions from motor vehicles; b. Identify areas where funding s hould be made available; and
c. Reviewing and make recomme ndations concerning regulatio ns adopted pursuant to NRS 445B.770

. Committee members are appointed by the deputy dire ctor of the Department of Motor Vehicles and meet at least quarterly. See Nevada Administrati ve Code AQT445B.853–857 for details. The Western States Air Resources Council ( WESTAR ) was founded in 1988 by eight western state air agencies, and has since grown to fifteen states and several local and tribal air quality agencies. It was formed to promote the exchange of information between states, share resources for the common benefit of members, and serve as a forum for discussing regional air quality issues of common concern. WESTAR changed it s bylaws in 2013, allowing DAQ to join as an ex-officio member, and the department has been a very active participant now that ozone transport has become a regional issue. During meetings and conferences, WESTAR discusses possible control measures an d other ways to reduce NO x and VOC emissions. This is an excellent platform to exchange information with agencies outside of Clark County and evaluate their control programs. The council’s purposes are to:

 Promote the exchange of information related to the control of air pollu tion for use in state and federal activities, as authorized by air quality statutes and regulations.Clark County: Ozone Advance Program Path Forward

3-4  Develop processes and procedures for cons ideration by western states, federal land managers, and EPA to meet air quality objectives and protect environmental resources.

 Discuss air quality issues of common concern.

 Report on the status of efforts undertak en to achieve air quality objectives.

 Establish work groups, task forces, etc., to investigate specific t opics and recommend a course of action for council members.

 Adopt resolutions and policy statements for council member implementation or use during the development of local, state, a nd federal programs, re gulations, and laws.Several a control o entities, a County t o Howeve r involve successf u measure s program s program s 

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4-2 In addition, SBAP conducts outreach activitie s, giving presentations to business groups and holding workshops for specific industries th at may require a more narrow focus. The Clark County Office of Sustainability promotes sustainability practices within Clark County. One of its goals is to help reside nts and businesses understand the options available regarding energy conservation, clean transportation, and recycling, to name a few. Some of the regi onal efforts the office supports are greenhouse gas emission reductions, the Southern Nevada Green Building Program, the Southern Nevada Regiona l Plant Program, and the Regional Planning Work Program. Most of thes e are targeted towards energy and resource conservation. In 2008, the Clark County Board of County Commissioners (BCC) adopted the “Cla rk County Eco-County Initiative,” which focuses on seven topics: air quality, water, land use/ habitat conservation, water reduction, green building, and energy use. 

### Welcome to Fabulous Las Vegas Three different organizations, Clark County's Office of Sustainability, Green Chips and Clean Energy Project partnered to promote energy conserva tion in Clark County. One project they developed was to power the “Welcome to Fabul ous Las Vegas” sign using solar photovoltaic energy and “...serve as a measurable stride toward a more sustainable future in Southern Nevada.” 

### Solar photovoltaic (PV) projects and electric car charging stations Two 30 kilowatt (kW) solar PV arrays were installed on top of parking canopies at the Clark County Government Center and Development Serv ices Campus. The array at the Government Center covers 20 visitor parking spaces, with six of those spaces equipped with electric vehicle charging stations. The Devel opment Services Campus solar PV array is a covered parking installation with an interactive kiosk locate d inside the building. Toge ther, these systems will reduce the County’s electric purchases by an esti mated 52,000 kilowatt hours (kWh) per year. In addition, the County has an existin g 30kW solar PV array located at the Spring Mountain Youth Camp. 

### Streetlight Retrofits Clark County Public Works (CCPW) has converted approximately 5,000 residential neighborhood street lights from me rcury vapor to energy efficient induction lighting that provide approximately 30% in energy savings, or, 850,0 00 kWh per year. CCPW has also replaced 400 watt High Pressure Sodium (HPS) luminaire fi xtures with 130 watt LED fixtures at 190 signalized intersections for an energy saving s of approximately 66%. Ultimately, all the remaining 310 signalized intersectio ns will have the 400 watt HPS luminaire fixtures replaced to LED luminaire fixtures, and all new traffic signals will be equipped with LED luminaire fixtures.Clark County: Ozone Advance Program Path Forward

4-3 

### Automotive Fleet The County’s fleet size is 2,700 vehicles with 100% alternative fuels and 537 hybrids with an estimated cost savings over regular gas vehi cles of approximately $1.5 million annually. By replacing the 537 regular gas vehi cles with the same number of hybrid vehicles the County has reduced CO2 emissions by 1,276 tons per year. The City of Las Vegas has implemented the “Sus taining Las Vegas” program, which focuses on air quality and transportation, energy efficiency , renewable energy, green buildings, and climate protection. The Air Quality componentpromotes the purchase of fuelefficient vehicles, encourages alte rnative transportation methods, and focuses on greenhouse gas emission reduc tion. The city’s vehicle fleet includes several hybrid and electric cars, and employees have the opportunity to use electric bikes fo r short trips around the downtown area. Energy Efficiency and Renewables focuses on energy conservation programs and home energy assessments, targeting the use of alternative energy in the home. Additionally, the city monitors and manages energy consumption and costs for all city facili ties, streetlights, and fleets. To that end, Las Vegas adopted a “Sustainability Energy Strategy” in 2008 that will help build a more sustainable community by conserving energy and in creasing the use of renewable resources. The City of Henderson’s sustainability prog ram, “OurHenderson,” focuses on being green, which, “in the desert...really isn’t about green at all....Being green, or sustainable, is really about maintaining the quality of our lives within the means of nature.” 4 The city thus implemented a range of energy conservation measures at city facilities, which add up to an average savings of $250,000 annually. These measures include remote power management to reduce com puter energy demands in city facilities during off-peak hours, installation of ne w boilers at government buildi ngs, lighting controls, an energy management control system for heating/air conditioning systems in city buildings, and traffic signal conversion from incandes cent lamps to energy-saving LEDs. The city has expanded the number of hybrid and alternative-fuel vehicles in its fleet for a number of years, until now only 13 percent of non-emergency vehicles use st andard fuels. The weatherization program emphasizes energy-efficient homes; the city performs a home assessment upon request and suggests measures that might increase energy e fficiency. Homeowners who meet certain income requirements may have the opportunity for home weatherization at no cost to them. The City of North Las Vegas introdu ced the ongoing “greeNLV” strategy in 2009. The Enhanced Recycling Program cut the number of garbage pickups to one day a week, reducing the number of tr ips by garbage/recycling trucks. The majority of the city’s fleet has been replaced by hybrids or vehicles converted to alternative fuels to reduce NO x emissions.

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. The i lableClark County: Ozone Advance Program Path Forward4-6Table 4-1. Southwest Gas Incentive ProgramsName of Rebate/ProgramExpirationDateDescriptionAppliance Connections - Special Offer - NVHomeowner/Renter9/30/2014 Have your gas range, dryer, or barbeque connected at a special price.Nevada Air Curtain - Business12/31/2014Air curtains can help you reduce your energy usage and now we have rebates available! Requiresnatural gas space heating.Nevada Boiler Equipment - Business12/31/2014 Take advantage of rebates for new boilers or high-efficiency equipment for existing boilers.Nevada Commercial Energy Audit Program12/31/2014An energy audit can lead you in the right direction tohigher efficiency. Incentive awards 50% (up to$5,000/facility; $50,000/customer).Nevada Convection Oven - Business12/31/2014Using hot air, commercial convection ovens are the workhorses in commercial kitchens and one of themost widely used appliances in the foodservice industry.Nevada Conveyor Oven - Business12/31/2014 Save money, energy and time with a natural gas conveyor oven!Nevada Custom Commercial Rebates Program -Business12/31/2014Southwest Gas commercial customers in Nevada may beeligible to receive rebates on the installation ofeligible measures resulting in verifiable natural gas savings.Nevada Dishwasher - Business12/31/2014Want to save up to $2,000 on a new ENERGY STAR® qualified commercial dishwashers (requiresnatural gas water heating)?Nevada Lavatory Faucet - Business12/31/2014 Receive a $50 rebate for Lavatory Faucet.Nevada Lavatory Faucet - Homeowner/Renter12/31/2014 Receive a $50 rebate for Lavatory Faucet.Nevada Multi-Family Master-Metered Rebates12/31/2014Southwest Gas is pleased to offer rebates to multi-family master-metered builders within Southwest Gas’Nevada service territories.Nevada Natural Gas Clothes Dryer - Business12/31/2014Get faster heat-up and shorter drying times with a natural gas dryer. Receive up to $30 rebate on thepurchase of a gas dryer with a moisture sensor.Nevada Natural Gas Storage Water Heater - Business12/31/2014Get higher efficiency, better insulation and heat traps, and more efficient burners. Rebate up to $500.Unit with thermal efficiency of at least 95% and input rating > 199,000 btu/hr.Nevada Natural Gas Tankless Water Heater - Business12/31/2014Heat water only when you need it. Save energy, money, and space. Rebate of$350 on the purchase ofan ENERGY STAR® qualified unit.Nevada Natural Gas Tankless Water Heater -Homeowner/Renter12/31/2014Heat water only when you need it. Save energy, money, and space. Rebate of$350 on the purchase ofan ENERGY STAR® qualified unit.Nevada Smart Low-Flow Showerhead - Business12/31/2014Lower your monthly water and natural gas bill byusing SmartTechnology thatprevents hot water waste.$20 rebate on the purchase of a showerhead withShowerStart TechnologyTM and have a natural gaswater heater installed in household.Clark County: Ozone Advance Program Path Forward4-7Name of Rebate/ProgramExpirationDateDescriptionNevada Smart Low-Flow Showerhead -Homeowner/Renter12/31/2014Lower your monthly water and natural gas bill byusing SmartTechnology thatprevents hot water waste.$20 rebate on the purchase of a showerhead withShowerStart TechnologyTM and have a natural gaswater heater installed in household.Nevada Smarter Greener Better® Homes Program forHomebuilders12/15/2014Enhance customer satisfaction and increase yourbusiness potential with ENERGY STAR® homes thatprovide all the features and amenitiesthat homebuyers are looking for.Nevada Smarter Greener Better® Solar Water HeatingProgram for BuilderRebate incentives to qualifying Nevada customers who install solar water heating systems with a naturalgas back up.Nevada Smarter Greener Better® Solar Water HeatingProgram for Business12/15/2014Rebate incentives to qualifying Nevada customers who install solar water heating systems with a naturalgas back up.Nevada Steamer - Business12/31/2014Enjoy shorter cooking times and higher production rates with these ENERGY STAR® qualified steamers.Rebate up to $200.Nevada Tankless Water Heater – Single-Family andMulti-Family Individually-Metered12/31/2014Now is the perfect time to makeSmarter Greener Better®choices for you and the environment. Savemoney with rebates on qualified energy-efficient products.Nevada Windows Rebate - Homeowner/Renter12/31/2014Whether you own or rent your residence, the Southwest Gas Nevada Windows Rebate is a great way toincrease the energy efficiency of your home.NV Cooktops & Ranges - Special Offer -Homeowner/Renter6/30/2014Receive a FREE GE appliance with the purchase ofa GE Monogram Pro Range or any Wall Oven &Cooktop Combo. See link or participating stores for details.NV Cooktops & Ranges - Special Offer -Homeowner/Renter6/30/2014Receive a free dishwasher, ventilation system, or instant savings on the purchase of a qualifying Dacorappliances. See link or an authorized Dacor retailer for details.NV Cooktops & Ranges - Special Offer -Homeowner/Renter9/30/2014 Receive a free dishwasher on the purchase of any 36" or 48" DCS U-Series range. See link for details.NV Cooktops & Ranges - Special Offer -Homeowner/Renter12/15/2014 Receive a FREE dishwasher and ventilation hoodwith the purchase of select Thermador appliances.NV Cooktops - Special Offer - Homeowner/Renter9/30/2014 Receive a free dishwasher on the purchaseof any DCS cooktop, wall oven & refrigerator.NV Natural Gas Clothes Dryer - Homeowner/Renter12/31/2014Get faster heat-up and shorter drying times witha natural gas dryer. Receive a $30 rebate on thepurchase of a gas dryer with a moisture sensor.NV Ranges - Special Offer - Homeowner/Renter9/30/2014Receive a free dishdrawer dishwasher on the purchase of a DCS french door refrigerator & any 30" DCSU-Series range. See link for details.Smarter Greener Better® Solar Water Heating Programfor Nevada - Homeowner/RenterSouthwest Gas is proud to offer a program providing rebate incentives to qualifying Nevada customerswho install solar water heating systems with a natural gas back-up.MGM R its 15 pr o

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4-9 year early. These efforts, and others, have earned Caesars three Travelife Gold Certifications for commendable environmental su stainability practices.Clark County: Ozone Advance Program Path Forward

5-1 

### 5. Local Mandatory Measures
Air Quality Regulations In accordance with NRS Chapter 445B, the BCC has adopted the AQRs and delegated enforcement authority to DAQ. Emission sources within Clark County ar e required to comply with all existing rules and regul ations through federally enforceable state implementation plan regulations. 7 Clark County has an approved Prevention of Signi ficant Deterioration (PSD) program, and most of the AQRs are EPA-approved. The BCC has a dopted several regulatory updates and submitted them to EPA for incorporation in Nevada’s State Implementation Plan (SIP). Below is the complete list of AQRs, with section numbers on the left side. 0 Definitions 2 Procedures for Adoption and Revision of Regulations and for Inclusion of those Regulations in the State Implementation Plan 4 Control Officer 5 Interference with Control Officer 6 Injunctive Relief 7 Hearing Board and Hearing Officer 8 Persons Liable for Penalties – Punishment: Defense 9 Civil Penalties 10 Compliance Schedules 12.0 Applicability, General Requirements and Transition Procedures 12.1 Permit Requirements For Minor Sources 12.2 Permit Requirements For Major Sources In At tainment Areas (Preve ntion Of Significant Deterioration) 12.3 Permit Requirements For Major Sources In Nonattainment Areas 12.4 Authority To Construct Application And Permit Requirements For Part 70 Sources 12.5 Part 70 Operating Permit Requirements 12.6 Confidentiality 12.7 Emission Reduction Credits 12.9 Annual Emissions Inventory Requirement 12.10 Continuous Monitoring Requireme nts for Stationary Sources 12.11 General Permits for Minor Stationary Sources 12.12 Transfer of Permit 12.13 Posting of Permit 13 National Emission Standards for Hazardous Air Pollutants 14 New Source Performance Standards 18 Permit and Technical Service Fees 21 Acid Rain Permits 22 Acid Rain Continuous Emission Monitoring

7 Although not a SIP rule, DAQ administers the Part 70 (Title V) permit requirements through the implementation of Section 12.5 – Part 70 Operating Permit Requirements.Clark County: Ozone Advance Program Path Forward

5-2 25 Affirmative Defense for Excess Emissions Due to Malfunctions, Startup, and Shutdown 26 Emission of Visible Air Contaminants 27 Particulate Matter from Process Weight Rate 28 Fuel Burning Equipment 32 Reduction of Animal Matter 33 Chlorine in Chemical Processes 40 Prohibitions of Nuisance Conditions 41 Fugitive Dust 42 Open Burning 43 Odors in the Ambient Air 44 Prohibitions on Planting, Selli ng, or Offering to Sell Fruitl ess Mulberry and European Olive Trees 45 Idling of Diesel Powered Motor Vehicles 50 Storage of Petroleum Products 51 Petroleum Product Loading into Tanks, Trucks And Trailers 53 Oxygenated Gasoline Program 70 Emergency Procedures 80 Circumvention 81 Provisions of Regulations Severable 90 Fugitive Dust From Open Areas and Vacant Lots 91 Fugitive Dust From Unpaved Roads, Unpaved Alleys, and Unpaved Easement Roads 92 Fugitive Dust From Unpaved Parking Lots and Storage Areas 93 Fugitive Dust From Paved Roads and Street Sweeping Equipment 94 Permitting and Dust Control for Construction Activities 

### Inspection and Maintenance Program Clark County implemented a basic inspection/main tenance (I/M) program in 1978, updated to an enhanced program in 1995. The current program is a decentralized hybrid program that includes both test-only and test and repair stati ons operated by independ ent contractors. NRS Chapter 445B (“Air Pollution” ) establishes the authorities and requirements for regulating motor vehicle emissions in th e state. In particular, NRS 445B.760 establishes the state’s authority to develop emission standards and NR S 445B.770 establishes the authority for counties to adopt regulations controlli ng vehicle emissions and to develop a program for vehicle inspection and testing. Emission testing is required of all passenger and light duty vehicles in the Las Vegas Valley (HA 212) and within a five-mile buffer zone around it. The only exceptions are vehicles based in Goodsprings, a small town near the border of the buffer zone. The town of Jean is outside the buffer zone.Clark County: Ozone Advance Program Path Forward

5-3 Figure 5-1. Clark County Emissions Testing Area.


### Renewable Portfolio Standard The Nevada Legislature adopted the state RPS in 1997, and has modified it in every legislative session since. The RPS establishes the percentage of electricity sold by an electric utility to retail customers that must come from renewable sour ces. More specifically, el ectric utilities are required to generate, acquire, or save a certain percentage of el ectricity annually using portfolio energy systems or energy efficiency measures. The percentage of renewable energy required by the RPS will increase ev ery two years until it reaches 25 percent in 2025. Included within that is a requirement that solar facilities generate at least five percent of th e total renewable energy in the port folio through 2015 and at least six percent beginning in 2016. In 2005, th e Legislature determined that energy efficiency measures can be used to comply with up to 25 percent of the annual RPS require ment; however, half of that 25 percent must come from measures installed at residen tial customer service locations.Clark County: Ozone Advance Program Path Forward

5-4 Progress
NV Energy installed 3,543 kW of solar electric e quipment in southern Nevada in 2013, out of a state total of 5,365 kW. Equipment was installed in residences, small businesses, schools, and public-sector buildings. The state’s Office of Energy closely tracks renewable energy generation. In 2010, Nevada generated 3,034,160 MWh from renewables. The fo llowing year saw a 6 percent increase to 3,217,758 MWh. In 2012, the last year for which da ta are available, Nevada generated 3,822,968 MWh of renewable energy, an increa se of 19 percent from the prev ious year. Projects scheduled for completion in 2014 will increase the to tal generated by renewables even more. The following projects are opera tional and online, some since 2007; others came online in 2013. As the list below demonstrates, Nevada has made substantial progress in generating renewable energy since the inception of the RPS. Apex Nevada Solar – 20.0 MW This solar PV project located 30 miles north of Las Vegas came on line in 2012. Las Vegas Valley Water Distri ct (6 projects) – 3.0 MW The Water District owns six Las Vegas-area solar PV projects totaling 3.0 MW. These installations began produ cing electricity in 2006. Mountain View Solar – 20.0 MW Currently in the construction stage, this solar PV project near Apex being developed by the City of North Las Vegas is expect ed to be operational in 2014. Nellis Air Force Base Solar Star – 13.2 MW + 19 MW This solar PV project is one of the largest in the West. Opera tional in 2007, it can produce more than 13 MW of energy for Nellis Air Force Ba se. An additional 19 MW solar photovoltaic power system will be built at the base in 2015. Nevada Solar One – 69.0 MW This solar thermal plant is located in Eldorad o Valley, near Boulder City. It came on line in 2007. Searchlight Solar – 17.5 MW Still in the development stage, this solar PV project will be locat ed near Searchlight. Silver State Solar – 52.0 MW Operational in 2012, this solar PV array near Pr imm was the first project built on public lands in Nevada. Spectrum Nevada Solar – 30.0 MW Operational in 2013, this solar PV project is located northeast of Las Vegas.Clark County: Ozone Advance Program Path Forward

5-5 CC Landfill Energy, LLC – 12.0 MWLocated at Republic Services' Apex regional landfill, this project is Nevada’s largest landfill gasto-energy facility. It be gan producing energy in 2012. Goodsprings Energy Recovery Station – 7.5 MW This is the first Nevada power plant to capture waste heat from a natural-gas compression plant. Searchlight Wind Energy – 200 MW Located in Searchlight, NV, 60 miles southeast of Las Vegas, this wind energy project will have 83 2.3 MW Siemens wind turbines. Moapa Solar Energy Center – 200MW The Moapa Solar Energy Center Project will invo lve the development of up to 1,000 acres of the Moapa reservation to produce appr oximately 200 MWs of solar energy. Midland Solar Project – 350MW A 350 MW solar plant will be built outside of Boulder City. This will be one of the largest renewable energy ventures in the country. Future Planned Projects
The following projects are curren tly planned in Clark County. Table 5-1. Future RE Projects

PLANT NAME COUNTY SUMMER CAPACITY PRIME MOVER ACTUAL OR PROPOSED ONLINE DATE Copper Mountain 2 Clark 58 MW Photovoltaic Dec. 2014 Spectrum Solar Clark 30 MW Photovoltaic Sept. 2013 Mountain View Solar Clark 8 MW Photovoltaic Feb. 2014 Copper Mountain 3 Clark 250 MW Photovoltaic Dec. 2016 K-Road Clark 250 MW Photovoltaic Dec. 2015 Silver State Solar Power South Clark 250 MW Photovoltaic May 2017 Table 5-2. New & Proposed Capacities

ENERGY SOURCE 2012 2013 2014 2015 2016 2017 TOTAL Solar PV 173 MW 30 MW 66 MW 250 MW 250 MW 250 MW 1,019 MW Solar Thermal 110 MW 110 MW TOTAL 1,129 MWClark County: Ozone Advance Program Path Forward

5-6 2013 Emission Reductions DAQ used EPA’s AVoided Emissions and geneRati on Tool (AVERT) to calculate the emission reductions in 2013 due to renewable energy and ener gy efficiency programs. It started with the nine projects online at the beginning of 2013, which generated a total of 203 MW. Another project, Spectrum Solar (30 MW), came online in 2013, and an additional 5 MW were recovered through NV Energy’s Solar Electric Program. 8 All in all, renewable energy projects produced a total of 238 MW in 2013. Table 5-3 shows the co rresponding input file fo r the AVERT model. Table 5-3. Inputs for AVERT Model Enter EE impacts based on the % reduction of regional fossil load. Reduce generation by a percent in some or all hours. Apply reduction to top X% hours: 0% % of top hours Reduction % in top X% of hours: 0.0% % reduction And/or enter EE impacts distributed evenly throughout the year. Reduce generation by annual GWh: 0 GWh OR Reduce each hour by constant MW. 0 MW And/or enter annual capacity of RE resources. Wind capacity: 0 MW Utility solar PV capacity: 238 MW Rooftop solar PV capacity: MW
According to the model, renewable energy ge neration displaced 87,700 MWh . This equals a reduction of 31,400 lbs. (15.7 tpy) of NO x . During the 2013 ozone seas on, renewables displaced a total of 22,500 lbs. (11.25 tons) of NO x in Clark County (Table 5-4). Table 5-4. Model Outputs Peak Gross Generation, Post-EERE (MW) Annual Gross Generation, Post-EERE (MWh) A nnual Displaced Generation

(MWh) A nnual Displaced NO x (lbs.) Ozone Season Displaced NO x (lbs.) 4,416 19,862,400 -87, 700 -31,400 -22,500

8 RenewableGenerations – December 2013.Clark County: Ozone Advance Program Path Forward

5-7 Figure 5-2. Monthly NO x Reductions. -6,000 -5,000 -4,000 -3,000 -2,000 -1,000 0 Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov DecNOx (lbs)Clark County: Ozone Advance Program Path Forward

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### 6. Potential Voluntary Control Measures
DAQ-Specific Earlier this year, the RTC asked if DAQ had a ny projects to include in the Transportation Improvement Program (TIP) for federal fiscal years 2015–2019. DAQ will participate in the TIP through projects funded by the Congestion Mitiga tion and Improvement Program (CMAQ). The three projects targeted for CMAQ funds are:
Electric Vehicle Purchase DAQ will invest up to $300,000 in plug-in hybrid vehi cles for the Clark County fleet, with the option to purchase electric charging stations. Th ey will be available to county employees at the Government Center for business purposes and to Building Department employees for conducting inspections. Electric vehicles emit up to 80 percent fewer VOCs and 79 percent less NO x than conventional gas-fueled vehicles. Vacuum-Assist Stage II Di sabling Assistance Program In May 2012, EPA determined that Stage II contro ls on gasoline stations are no longer necessary. DAQ will offer financial assistance to any gasoline station owner who wants to disable the assist system. A total of $500,000 is set aside for the program, and DAQ will reimburse owners up to 80 percent of the cost. This program could re duce VOC emissions by 1.26 tpy per station. Vapor Processor Rebate Program This program supplements the Stage II Disablin g Assistance Program. DAQ will offer financial assistance to any gasoline stati on owner to retrofit a pressure/vac uum relief valve with a device that reduces evaporative emissions while leaving the system intact. The potential cost of this retrofit is $40,000, so DAQ will use the $500,000 allocat ed to this program to reimburse owners 50–80 percent of their costs. This program coul d reduce VOC emissions by 4.46 tpy per station.


### Other Entities Other agencies and private companies will conti nue to provide the incentive programs described in Section 4 to their customers. Everybody invo lved is continuously evaluating programs and seeking funding for more pollution-prevention a nd emission-reduction programs. Stakeholders will continue with their educational programs, and DAQ will continue to hold stakeholders meetings as appropriate.Clark County: Ozone Advance Program Path Forward

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### 7. Future Mandatory Control Measures

Federal Rules DAQ relies on new federal rules for on-road a nd non-road mobile sources to control NO x emissions in Clark County. In early 2014, EPA fina lized the Tier 3 Motor Vehicle Emission and Fuel Standards, which set new emissions standard s and lower the sulfur co ntent of gasoline. The standards will reduce tailpipe a nd evaporative emissions from pa ssenger cars, light-duty trucks, medium-duty passenger vehicles, and some hea vy-duty vehicles. According to EPA estimates, Tier 3 will reduce non-methane organic gases and NO x by approximately 80 percent compared to today’s fleet. The new standard will become effective in 2017.


### Reid Gardner Power Plant Nevada Senate Bill 123 (SB123) spec ifies the details for retiring the coal-fired boilers at the Reid Gardner power plant. The bill requires NV Ener gy to submit to the Nevada Public Utility Commission a comprehensive plan for reducing em issions from coal-fired plants and their replacements with increased capacity from renewable energy facilities and other electric plants. An amendment 9 sets out the following actions:

 Retire Reid Gardner 1, 2 & 3 (300 MW) by December 31, 2014.
 Retire Reid Gardner 4 (257 MW) by December 31, 2017.
 Replace Reid Gardner 1, 2, 3 and 4 with 500–550 MW of natural gas.
 Build 150 MW of renewables, with construction to begin by December 2017 and finish by the end of 2021. Although SB123 allows retrofitting th e coal-fired boilers to gas-fi red boilers, that would still result in a significant reduction of NO x emissions. 

### Project Neon NDOT has future plans to reengineer and rebui ld the U.S. 95/I-15 interchange near downtown Las Vegas. Growing congestion (s pecifically on I-15) and freeway overcapacity co ntribute to high accident rates, noi se pollution, and air pollution, especi ally along the Las Vegas resort corridor. Project NEON is designed to alleviat e this congestion by providing alternatives to motorists who travel I-15 daily, which will also reduce emissions from NO x , one of the biggest ozone precursors. The project has six phases; the firs t has already started and is sche duled to be finished in 2016. It includes High-Occupancy Vehicle la nes between U.S. 95 and I-15, along with better connections to surface streets into the downt own area. Completion of all si x phases is scheduled for 2019.

9 NVision (proposed amendment to SB123), version 2, 4/11/13.Clark County: Ozone Advance Program Path Forward

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### Boulder City Bypass This project involves road improvements to U.S. Highway 93, a major regional commercial corridor and the single route thr ough Boulder City. As a major ur ban arterial, Highway 93 carries 32,000 vehicles per day of east-west traffic. Although Clark County is currently designated in attainment for oz one, there is concern that ozone levels are higher in Boulder City than in the Las Vegas Valley. If traffic congestion remains a problem on U.S. 93, ozone levels could ri se even higher. Past sampling of ozone at the Boulder City monitoring station has indicated that ozone levels recorded there are often as high as the values recorded at monitoring stations in Las Vegas. One explanation could be a high production of NO x from vehicles traveling on U.S. 93, since vehicle emissions contribute significantly to NO x . High traffic volumes, especially in combination with idling vehicles, produce higher levels of NO x , which could led to higher ozone levels.Clark County: Ozone Advance Program Path Forward

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### 8. Path Forward Implementation DAQ is proposing the following measures to pro actively control ozone precursors. We are dedicated to investigating any ne w measures that might become available, and will implement them if they are economically and financially feasible.


### On-road and Non-road Mob ile Emission Reductions According to data from the Nevada Department of Motor Vehicles, older cars and trucks are replaced with new, cleaner vehicl es at a rate of about 4 percent a year. Over the next few years, this turnover will significantly reduce NO x emissions. DAQ also anticipates significant reductions when the Tier 3 program for onroa d and nonroad engines and equipment becomes effective in 2017. DAQ does not have any jurisdiction to regulate e ngine emissions, so it has proactively promoted voluntary emission reduction programs and will continue to do so as long as federal funds are available to help. Availability of funding from several grant programs have already enabled our Clark County partners to effectiv ely replace their fleets with mo re efficient vehicles, hybrids, and/or electric cars. 

### Stage II Vapor Recovery and Control Systems In May 2012, EPA determined that onboard vapor recovery technology is used throughout motor vehicle fleets nationwide and waived the requireme nt to implement Stage II gasoline vapor and control systems at gasoline dispensing facilit ies in nonattainment areas. DAQ is currently reviewing this regulation, and is planning to phase out the installa tion of Stage II systems at gasdispensing facilities in Clark County. 

### Congestion Mitigation and Air Quality Projects DAQ’s Electric Vehicle project has two phases. In the first phase, DAQ will obtain a Buy American Waiver. This phase is scheduled to start in October 2014, and DAQ plans to have the waiver by January 2015. In the second phase, DAQ will issue bids and purchase the vehicles. This phase is set to start in Febr uary 2015 and finish in September 2015. The first phase of the Vacuum-Assist Program , which involves development, marketing, and roll-out, is scheduled to begin in October 2015 and finish in September 2016. The second phase, implementation, will begin in October 2016 and finish in September 2017. The Vapor Processor Rebate program will star t in October 2015 and last through September 2018. This includes the program development and marketing phases, as well as the program implementation phases.Clark County: Ozone Advance Program Path Forward

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### DAQ Public Education and Outreach Program DAQ actively conducts local public outreach a nd education activities through targeted community interaction to promote clean air in itiatives. Promoting in dividual and corporate behavior that reduces air pollution is an im portant role that is well suited to DAQ. DAQ promotes clean air initiatives by partnering with local schools and public/private organizations in the planning of public activities and events that provide public information (simple tips) and incentives to reduce ozone precursor emissions, e.g., Earth Day events. DAQ also maintains an EPA sponsored air qualit y messaging service (EnviroFlash) that the public can subscribe to via the DAQ webpage. Envi roFlash is designed to send emails about the daily air quality forecast in the Las Vegas Valley; information that the local radio or television stations provide, plus suggested safety meas ures when levels are unhealthy. Subscribing to EnviroFlash is important because exposure to hi gh levels of air pollution can aggravate heart disease, asthma and other respiratory diseases, and by being aware of th e “real time” air quality levels, individuals can take precautions to protect themselves and their families. Further, DAQ is in the process of developing materials to be used in outreach campaigns to promote air quality initiatives, as well as de veloping an annual calenda r of recurring outreach venues and opportunities to be tter educate the public. 

### Renewable Portfolio Standard Electric energy producers in Cl ark County and Nevada will continue to displace NO x and VOC emissions from traditional ener gy generating sources, such as co al-fired boilers, with clean renewable energy from sola r, wind, and hydropower units. 

### Conclusion Several factors out of DAQ’s control have a signif icant impact on ozone c oncentrations in Clark County. Taking into account that studies have sh own significant ozone transport from different regions, and that background concentrations are close to 45 ppb, Clark County will have a hard time meeting the NAAQS. The ozone design value is close to the NAAQS, and NO x emissions increased by 12 percent between 2008 and 2011 because of an increase in on-road mobile sources. In 2012 and 2013, smoke from wildfires in nearby st ates affected Clark County’s ambient air significantly; in fact, most of the higher daily ozon e concentrations were record ed during wildfire days. DAQ anticipates EPA concurrence with the exceptiona l event demonstrations it has submitted, which would exclude these higher wildfire-caused ozon e concentrations for a ny regulatory purposes. Private companies and agencies at all levels of government provide Clark County residents with a variety of programs to reduce emissions. Future federal regulations for mobile sources, in conjunction with scheduled highway impr ovement projects, will further reduce NO x emissions in the county, as will the replacement of the Reid Gardner coal-fired boilers and further RPS requirements.Clark County: Ozone Advance Program Path Forward

8-3 DAQ has implemented many voluntary and mandatory control measures for NO x and VOC. Many organizations in Clark C ounty, both government and private, are making great strides to reduce precursor emissions through various prog rams. Although few options remain that have not already been explored, DAQ will continue to re search and evaluate any control measures that become available.