Air Quality Bureau
Regional Haze
The blue skies and scenic vistas of New Mexico are considered some of the most beautiful in the United States. While New Mexico's residents and visitors frequently enjoy good visibility, air pollutants interfering with light transmission can impose limitations on aesthetic appreciation of scenery. Visibility is the term used to characterize physical limitations in the atmosphere that affect our ability to see clearly. Human caused pollution of varied concentrations and sizes in the atmosphere can impair or reduce visibility. Widespread visibility impairment caused by pollutants from a variety of sources and activities over a broad geographic area is known as regional haze.
Revisions to New Mexico's State Implementation Plan for Interstate Transport under the Clean Air Act Section 110(a)(2)(D)(ii). Information on this SIP proposed revision can be found on our Proposed Air Quality Plans and Regulations page.
2010 Sulfur Dioxide Milestone Report, 2011 Audit and 2018 Projected Inventory
The 2010 Sulfur Dioxide Milestone Report, 2011 Audit and 2018 Projected Inventory are now available for public review and comment. Comments will be accepted through March 2, 2012.
- Public Notice of Availability
- 2010 Sulfur Dioxide Milestone Report
- 2011 Audit Report
- 2007 Audit Report
- 2018 Projected Inventory
Decision
On June 2, 2011 the Environmental Improvement Board unanimously voted to approve New Mexico's State Implementation Plan for Regional Haze.
Comments Received (note: comments from EPA and Federal Land Managers are included below under Notices of Intent to Present Technical Testimony)
On May 27, 2011 the EIB and NMED received comments from the Western Environmental Law Center on behalf of Dine CARE, Natural Resources Defense Council, New Energy Economy, New Mexico Sportsman, the Rio Grande Chapter of the Sierra Club, the Sierra Club, San Juan Citizens Alliance, and WildEarth Guardians.
- Western Environmental Law Center Letter dated May 27, 2011
- Exhibit A - Letter from San Juan Citizens Alliance to NMED dated May 3, 2011
- Exhibit B - Letter from State of Colorado to U.S. EPA dated April 4, 2011
- Exhibit C - EPA notes from meetings and conference calls regarding San Juan Generating Station BART
- Exhibit D - NMED's San Juan Generating Station NOx BART Determination dated June 21, 2010
Notices of Intent to Present Technical Testimony
On May 20, 2011 NMED submitted a supplemental Notice of Intent to Present Technical Testimony to the Environmental Improvement Board including responses to comments received from the U.S. Environmental Protection Agency, Region 6 and the U.S.D.A. Forest Service.
- NMED 2nd Notice of Receipt of Comments - Includes comments from the National Park Service and Fish and Wildlife Service
- NMED Notice of Intent - Supplemental (May 20, 2011)
- NMED Exhibit 13 - Revisions to 309(g) SIP in response to EPA comments
- NMED Exhibit 14 - Revisions to 20.2.81 NMAC in response to EPA comments
- NMED Exhibit 15 - Comments from EPA Region 6
- NMED Exhibit 16 - NMED responses to EPA comments
- NMED Exhibit 17 - U.S.D.A. Forest Service comments
- NMED Exhibit 18 - NMED responses to Forest Service comments
- NMED Exhibit 19 - Proposed Statement of Reasons for adoption and order
On May 17, 2011 the Natural Resources Defense Council, San Juan Citizens Alliance, and WildEarth Guardians submitted an entry of appearance.
On May 17, 2011 Public Service Company of New Mexico (PNM) and San Juan Coal Company submitted Notices of Intent to Present Technical Testimony.
- Notice of Intent to Present Technical Testimony - Public Service Company of NM, in four parts: PNM1, PNM2, PNM3, PNM4
- San Juan Coal Company Notice of Intent
On May 16, 2011 NMED submitted a notice of receipt of EPA comments to the Environmental Improvement Board.
On May 2, 2011 NMED submitted its Notice of Intent to Present Technical Testimony to the Environmental Improvement Board.
- Notice of Intent
- Exhibit 1: Clean Air Act Section 169A
- Exhibit 2: Clean Air Act Section 169B
- Exhibit 3: 40 CFR 51.308
- Exhibit 4: 40 CFR 51.309
- Exhibit 5: U.S. EPA BART Guidelines from the Federal Register
- Exhibit 6a: Email regarding BART modeling results (November 9, 2006)
- Exhibit 6b: Email regarding BART modeling (June 26, 2007)
- Exhibit 6c: Email regarding comments on the BART modeling (July 30, 2007)
- Exhibit 6d: Email regarding additional information request on BART analysis (July 30, 2007)
- Exhibit 6e: Letter from NMED to PNM requesting additional information (December 21, 2007)
- Exhibit 6f: Letter from NMED to PNM requesting additional information (March 25, 2008)
- Exhibit 6g: Email regarding coal type burned at San Juan Generating Station (March 20, 2008)
- Exhibit 6h: Email following meeting with PNM (June 18, 2008)
- Exhibit 6i: Letter from NMED to PNM requesting additional information (December 29, 2008)
- Exhibit 7a: San Juan Generating Station Modeling Protocol (March 13, 2007)
- Exhibit 7b: Appendix E
- Exhibit 7b: PNM BART Analysis (June 6, 2007)
- Exhibit 7c: Email thread regarding cost analysis
- Exhibit 7d: SCR Cost Analysis (July 11, 2007)
- Exhibit 7e: SNCR Hybrid Cost Analysis (July 11, 2007)
- Exhibit 7f: Updated visibility cost effectiveness data (August 23, 2007)
- Exhibit 7g: PNM response to NMED (September 14, 2007)
- Exhibit 7h: PNM SCR schematic
- Exhibit 7i: Refined visibility results (November 5, 2007)
- Exhibit 7j: PNM discussion of OAQPS Cost Manual (March 29, 2008)
- Exhibit 7j: Attachments
- Exhibit 7k: Final BART modeling response (March 31, 2008)
- Exhibit 7k: Attachments
- Exhibit 7l: Final BART SNCR analysis (May 30, 2008)
- Exhibit 7l: Attachments
- Exhibit 7m: Discussion of San Juan Generating Station coal and classification
- Exhibit 7n: Final Nalco-MOBOTEC nitrogen oxides BART analysis (August 28, 2008)
- Exhibit 7n: Attachments
- Exhibit 7o: Final particulate matter BART analysis (August 28, 2008)
- Exhibit 7o: Attachments
- Exhibit 7p: PNM sulfate removal report (March 16, 2009)
- Exhibit 7p: Attachments
- Exhibit 7q: SNCR cover letter (February 9, 2011)
- Exhibit 7r: PNM BART SNCR analysis update (February 9, 2011)
- Exhibit 7s: SNCR cover letter (February 11, 2011)
- Exhibit 7t: Revised SNCR analysis (February 11, 2011)
- Exhibit 7u: Rate impact analysis (February 11, 2011)
- Exhibit 8a: Testimony of Mary Uhl on Regional Haze Background
- Exhibit 8b: Regional haze powerpoint slides
- Exhibit 8c: Testimony of Mary Uhl on BART Determination
- Exhibit 9a: Testimony of Rita Bates on 309 SIP Revisions
- Exhibit 9b: Testimony of Rita Bates on Proposed 309(g) SIP
- Exhibit 10: Additional proposed revisions to 309 SIP
- Exhibit 11: Additional proposed revisions to 309(g) SIP
- Exhibit 12: Public Notices
Public Meetings
The Air Quality Bureau held two public meetings on these proposed revisions.
- May 3, 2011, in Farmington
- May 4, 2011, in Santa Fe
- Click here to download posters used at the public meetings
- Comments/Questions from the public meetings
Public Hearing on Regional Haze State Implementation Plan
On February 28, 2011, the Environment Department submitted a proposed Regional Haze State Implementation Plan (SIP) under 40 CFR 51.309 to the Environmental Improvement Board. The Board has scheduled a public hearing for June 1 in Santa Fe at the State Capitol building, and on June 2 (3 and 4 if needed) in Farmington at San Juan College.
- Public Notice of Hearing - English version
- Public Notice of Hearing - Spanish version
- Revised Regional Haze SIP under 40 CFR 51.309 (309 SIP)
- Appendix K to 309 SIP - Recommendations for Making Attribution Determinations in the Context of Reasonably Attributable BART, WESTAR Council, May 2003
- Regional Haze SIP under 40 CFR 51.309(g) (309(g) SIP)
(revised March 31, 2011)
- Appendix A to 309(g) SIP - Emissions Overview (WRAP, undated)
- Appendix B to 309(g) SIP - Air Quality Modeling (WRAP, undated)
- Appendix C to 309(g) SIP - Summary of WRAP RMC BART Modeling for New Mexico
- Appendix D to 309(g) SIP - New Mexico BART Determination for San Juan Generating Station
- Appendix E to 309(g) SIP - Supplementary Information for Four Factor Analyses by WRAP States, EC/R Incorporated, May 4, 2009 (corrected April 20, 2010)
- Appendix F to 309 (g) SIP - Supplementary Information for Four-Factor Analyses for Selected Individual Facilities in New Mexico, May 5, 2009
- Proposed Revisions to 20.2.73 NMAC - Notice of Intent and Emission Inventory Requirements
- Proposed Revisions to 20.2.81 NMAC - Western Backstop Sulfur Dioxide Trading Program
Public Service Company of New Mexico (PNM) has submitted to the Environment Department an updated Best Available Retrofit Technology analysis focused on selective non-catalytic reduction technology (SNCR) for nitrogen oxides (NOx) on its San Juan Generating Station.
- Cover Letter from PNM with Updates to February 9, 2011 Analysis (February 11, 2011)
- Revised SNCR Analysis (February 11, 2011)
- Rate Impact Analysis (February 11, 2011)
- Cover letter from PNM (February 9, 2011)
- Updated SNCR analysis (February 9, 2011)
On December 20, 2010, the Environment Department submitted a proposed Regional Haze State Implementation Plan (SIP) under 40 CFR 51.309 to the Environmental Improvement Board. The Department intends to request a hearing on the SIP at the Board's scheduled January meeting.
- Revised Regional Haze SIP under 40 CFR 51.309 (309 SIP)
- Appendix K to 309 SIP - Recommendations for Making Attribution Determinations in the Context of Reasonably Attributable BART, WESTAR Council, May 2003
- Regional Haze SIP under 40 CFR 51.309(g) (309(g) SIP)
- Appendix A to 309(g) SIP - Emissions Overview (WRAP, undated)
- Appendix B to 309(g) SIP - Air Quality Modeling (WRAP, undated)
- Appendix C to 309(g) SIP - Supplementary Information for Four Factor Analyses by WRAP States, EC/R Incorporated, May 4, 2009 (corrected April 20, 2010)
- Appendix D to 309 (g) SIP - Supplementary Information for Four-Factor Analyses for Selected Individual Facilities in New Mexico, May 5, 2009
- Proposed Revisions to 20.2.73 NMAC - Notice of Intent and Emission Inventory Requirements
- Proposed Revisions to 20.2.81 NMAC - Western Backstop Sulfur Dioxide Trading Program
Public Service Company of New Mexico (PNM) filed a motion for continuance of the hearing on Regional Haze and the San Juan Generating Station Best Available Retrofit Technology (BART) Determination. The Environmental Improvement Board granted the motion. The Department withdrew its petition for a hearing on December 17.
- PNM Motion for Continuance
- NMED Response to PNM Motion
- Environmental Improvement Board Order on Motion for Continuance
- NMED Withdrawal of Petition for Regulatory Change and Request for Hearing
The New Mexico Environment Department submitted a proposed Regional Haze State Implementation Plan (SIP) under 40 CFR 51.308 to the Environmental Improvement Board on June 21, 2010. At the Board meeting on July 6, the Board scheduled the hearing for October 4, 2010. The following documents were submitted to the Board:
- Petition and Statement of Reasons
- Regional Haze State Implementation Plan
- Appendix A - Best Available Retrofit Technology (BART) determination for San Juan Generating Station
- Attachment A to Appendix A - BART Modeling Results
- Attachment B to Appendix A - BART Modeling Receptors
- Appendix B - Four Factor Analysis for the WRAP Region
- Appendix C - Four Factor Analysis for Specific Sources in New Mexico
- Appendix D - 20.2.65 NMAC - Smoke Management
Comments and attachments from the National Park Service and Fish & Wildlife Service on the Proposed SIP
- NPS FWS Comment letter
- BART Comments
- Appendix A. EGUs less 0.06 lb.mmBtu in 2009.xls
- SCR on eastern wall-fired EGUs.doc
- 2006 Wall-fired Dry-bottom Eastern EGUs with SCR charts.xls
- 2006 wall-fired EGU Ozone Season summary data sheet.xls
- NPS estimate of SJGS #1 SCR.xls
- NPS estimate of SJGS #2 SCR.xls
- NPS estimate of SJGS #3 SCR.xls
- NPS estimate of SJGS #4 SCR.xls
- SJGS #1 Dry-Bottom PC w FGD+FF PM speciation profile.xls
- SJGS #2 Dry-Bottom PC w FGD+FF PM speciation profile.xls
- SJGS #3 Dry-Bottom PC w FGD+FF PM speciation profile.xls
- SJGS #4 Dry-Bottom PC w FGD+FF PM speciation profile.xls
The New Mexico Environment Department reviewed Public Service Company of New Mexico's (PNM) analysis for Best Available Retrofit Technology for nitrogen oxides (NOx) on its San Juan Generating Station. Following are documents NMED received from PNM on their analysis.
PNM San Juan Generating Station BART Analysis
- PNM BART Modeling Protocol
- PNM BART Report Appendix E (WRAP Modeling Protocol)
- PNM SCR Cost Analysis - received July 11, 2007
- PNM SNCR Hybrid Cost Analysis - received July 11, 2007
- Update Visibility Cost Effectiveness Data - August 23, 2007
- PNM Response to NMED - September 14, 2007
- PNM SCR Schematic
- BART Modeling Refinements - received November 5, 2007
- Department Request 12-21-2007
- Discussion of OAQPS Cost Manual Method - received March 29, 2008
- Final BART Modeling Response with Attachments - received March 31, 2008
- Final BART SNCR Analysis - received May 30, 2008
- Final Discussion of SJGS Coal and Classification
- Final Nalco-MOBOTEC NOx BART Analysis - received August 28, 2008
- Final PM BART Analysis - received August 28, 2008
- PNM SO3 Removal Report - received March 16, 2009
In November 2003, the New Mexico Environmental Improvement Board approved NMED's proposed regional haze state implementation plan (SIP) under Section 309 of the Regional Haze Rule, along with implementing regulations. The approved SIP and regulations can be accessed using these links.
Regional Haze SIP (download appendices separately below)
- Appendix A: Projection of Visibility Improvement
- Appendix B: Western Regional Air Partnership Policy on Clean Air Corridors
- Appendix C: Stationary Sources
- [Appendix D: Reserved]
- Appendix E: Fire Programs
- Appendix E-1: Comparison of Existing NM Smoke Management Program with RHR Requirements
- Appendix E-2: Description of Process to Identify and Remove Administrative Barriers to the Use of Non-burning Alternatives
- Appendix E-3: Process for Establishing Annual Emission Goals
- Appendix E-4: Western Regional Air Partnership Policy on Enhanced Smoke Management Programs for Visibility
- Appendix E-5: Western Regional Air Partnership Policy on Annual Emission Goals for Fire
- Appendix E-6: Western Regional Air Partnership Fire Tracking System Policy
- Appendix F: Paved and Unpaved Road Dust
- Appendix G: Pollution Prevention
- [Appendices H - I: Reserved]
- Appendix J: Interstate and Regional Coordination
- [Appendices K - L: Reserved]
- Appendix M: Monitoring Requirements
- Appendix N - WRAP Technical Support Document (link to WRAP web site)
Updated Visibility Data - received October 16, 2007
- 20.2.81 NMAC - Western Backstop Sulfur Dioxide Trading Program Regulation
- 20.2.73 NMAC - Notice of Intent and Emission Inventory Requirements Regulation
- 20.2.65 NMAC - Smoke Management Regulation
Regional Haze Issues
Regional Haze is haze that reduces long range visibility over a wide region, that is, over a portion of a state or several states. Haze is caused by fine particles in the air that are so small they settle out only very slowly. Because of the harm that haze does to visibility in National Parks and wilderness areas, many efforts to control and reduce man-made haze, and the air pollutants that cause it, are under way - through national laws and regional collaboration. Such a collaboration, involving states, Indian tribes, industry, and environmental advocates, is the Western Regional Air Partnership (WRAP), under the auspices of the Western Governors' Association.
The WRAP develops the technical and policy tools needed by the western states and tribes to comply with the EPA's regional haze regulations. WRAP activities are conducted by a network of forums and committees composed of members and stakeholders who represent a wide range of viewpoints; public involvement is an integral part of the Partnership. For more information on the WRAP, please visit their web site.
Here are more links to sites that work with visibility and regional haze issues:
- National Park Service Visibility Monitoring Program
- National Park Service Air Resources
- Visibility and Air Pollution from US EPA
- National Park Service Fort Collins Air Resources Division
- USDA Forest Service National Air Resource Management Web Site
- USDA Forest Service Air Web Site
- Introduction to Visibility by William C. Malm, CIRA, Colorado State University
Reasonable Progress 4 Factor Evaluation Project
§308(d)(1) of the Regional Haze Rule requires States to set reasonable progress goals toward meeting a national goal of natural visibility conditions in Class I areas by the year 2064. The first reasonable progress goals will be established for the planning period 2008 to 2018 and the Regional Haze Rule identifies four factors which should be considered in evaluating potential emission control measures to meet those visibility goals. As listed in §308(d)(1)(i) these four factors are as follows:
- Cost of compliance
- Time necessary for compliance
- Energy and non-air quality environmental impacts of compliance
- Remaining useful life of any existing source subject to such requirements
Several WRAP States requested help in evaluating these four factors for additional control measures (beyond BART). These States first requested evaluation of a series of General Source Categories. In addition, five states (including New Mexico), also identified specific Stationary Sources located within their respective states for which they wanted a detailed control evaluation conducted.
The Scope of Work for this project, the specific source spreadsheet and drafts of the control measure evaluation reports are now posted on the Implementation Workgroup “documents” page at:
http://www.wrapair.org/forums/iwg/docs.html
Final Sulfur Dioxide Milestone Report
New Mexico's state implementation plan for regional haze, adopted by the
Environmental Improvement Board on November 18, 2003, requires that New Mexico
cooperate with four other states in producing an annual report to determine if
emissions of sulfur dioxide from large industrial sources are less than the
emissions milestone set in the plan. The final report for calendar year 2003 is
now available at http://www.wrapair.org, or you may contact
the New Mexico Air Quality Bureau for a copy of the report at (505) 827-1494 or
by mail at the address below.
The report shows that total emissions of sulfur dioxide from large sources in
the five states – New Mexico,
Utah, Arizona, Wyoming and Oregon – were 329,455 tons, while the milestone is
446,908 tons. Therefore, the report
demonstrates that emissions in the five states are 72% of the milestone and the
states have met the requirements of the plan for 2003.
Requests for copies of the final report may be submitted by electronic mail to Rita Bates at rita.bates@state.nm.us or may be mailed to:
Rita Bates Air Quality Bureau New Mexico Environment Department 1301 Siler Rd., Building B Santa Fe, NM 87507 ATTN: SO2 Milestone Report
Draft 2007 Regional SO2 Emissions and Milestone Report available for public review and comment - click here
The Federal Regional Haze Rule and Fact Sheet (Adobe Acrobat Format)
Annex to the Regional Haze Rule and Fact Sheet (Adobe Acrobat Format)
Additional Recommendations Report
The Grand Canyon Visibility Transport Commission (GCVTC) issued in 1996 a set of recommendations for protecting visibility in mandatory federal Class I areas on the Colorado Plateau in its report entitled Recommendations for Improving Western Vistas. Many, but not all, of the GCVTC recommendations were included in the Regional Haze Rule. The report below describes measures being taken in New Mexico to implement the GCVTC recommendations that were not in the Regional Haze Rule. Although not a part of New Mexico's SIP, this report was compiled in accordance with Section 309(d)(9) of the Regional Haze Rule and will be updated periodically.
New Mexico's Progress on GCVTC Report Recommendations, December 2003
