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GAO-09-788R: 

United States Government Accountability Office: 
Washington, DC 20548: 

July 27, 2009: 

Congressional Addressees: 

Subject: Air Pollution: Air Quality, Visibility, and the Potential 
Impacts of Coal-Fired Power Plants on Great Basin National Park, 
Nevada: 

Great Basin National Park encompasses over 77,000 acres of White Pine 
County in east-central Nevada and is home to diverse geologic, 
topographic, and wildlife resources--including ancient bristlecone 
pines, the world's longest living tree species. The park was created to 
preserve a representative segment of the Great Basin Region and 
receives about 80,000 visitors annually. The park features numerous 
scenic areas with views of the surrounding landscape, which includes 
both deserts and mountains. The National Park Service (NPS), within the 
Department of the Interior, is responsible for managing the park, and 
the park's management plan lists both air quality and visibility as 
outstanding resources. This plan identifies threats to air quality and 
visibility--including air pollution from the possible development of 
coal-fired power plants in the region--and states that even slight 
increases in air pollution could cause major decreases in visibility. 

In 2004 and 2006, two companies each initiated the process to build new 
coal-fired power plants about 55 miles northwest of Great Basin 
National Park, near the city of Ely, Nevada.[Footnote 1] While the 
development of these new power plants would provide jobs, needed 
electric power, and other benefits, they have also drawn attention to 
the possibility of adversely affecting air quality and visibility in 
and around the park. However, in early 2009, both companies publicly 
stated they have indefinitely postponed development of their plants due 
to environmental, regulatory, and economic uncertainties. 

Under the Clean Air Act, to protect human health and welfare, the 
Environmental Protection Agency (EPA) establishes national air quality 
standards for six pollutants that specify the allowable level of each 
pollutant in the ambient air. The six pollutants, also known as 
criteria pollutants, are carbon monoxide, nitrogen oxides, sulfur 
dioxide, particulate matter, lead, and ozone.[Footnote 2] Coal-fired 
power plants are major sources of several of these criteria pollutants 
(i.e., nitrogen oxides, sulfur dioxide, and particulate matter). In 
addition, nitrogen oxides combine with other chemicals in the air and 
sunlight to form ozone.[Footnote 3] EPA increased the stringency of its 
primary standard for ozone in 2008, changing it from 84 parts per 
billion to 75 parts per billion. 

In addition to the Clean Air Act, the two proposed coal-fired power 
plants are also subject to requirements of the National Environmental 
Policy Act of 1969 (NEPA) because the companies proposed to build their 
plants on federal land administered by the Bureau of Land Management 
(BLM). BLM is authorized to issue rights-of-way on federal land for the 
construction of the plants and, subsequently, to arrange for the sale 
of the land to the companies.[Footnote 4] NEPA requires BLM to evaluate 
the likely effects of the issuance of the rights-of-way using an 
environmental assessment or, if the environmental effects are likely to 
be significant, using a more detailed environmental impact statement 
(EIS).[Footnote 5] 

This report responds to a congressional directive in the Joint 
Explanatory Statement accompanying the Consolidated Appropriations Act 
for fiscal year 2008. The report describes (1) current air quality and 
visibility in and around Great Basin National Park and (2) 
stakeholders' views about the potential impacts of the proposed coal- 
fired power plants on air quality and visibility in and around the 
park. 

To respond to these objectives, we reviewed relevant rules and policies 
to provide background information on federal air quality requirements 
overall and as they relate to national parks. We also obtained and 
analyzed data from air quality and visibility monitoring networks. We 
determined that the data were sufficiently reliable for the purposes of 
this report. Additionally, we interviewed relevant agency officials, 
stakeholders, and organizations about the potential individual and 
cumulative impacts of proposed new coal-fired power plants on the park. 
Because BLM's Record of Decision on the EIS for one of the proposed 
plants that fell under our review is the subject of an administrative 
appeal, we did not assess the permit applications, the quality of the 
modeling conducted by the applicant, or the quality of the data used to 
conduct the modeling analysis. Finally, we visited Great Basin National 
Park, where we observed air quality monitoring equipment and air 
quality and visibility in and around the park. We conducted our work 
from September 2008 to July 2009 in accordance with all sections of 
GAO's Quality Assurance Framework that are relevant to our objectives. 
The framework requires that we plan and perform the engagement to 
obtain sufficient and appropriate evidence to meet our stated 
objectives and to discuss any limitations in our work. We believe that 
the information and data obtained, and the analysis conducted, provide 
a reasonable basis for any findings and conclusions in this product. 
(See enclosure I for a more detailed description of our scope and 
methodology.) 

Summary: 

According to data collected from federal agencies, Great Basin National 
Park and the surrounding area currently have some of the best air 
quality and visibility in the United States. The park has an extensive 
monitoring network that is used to track air pollutants and weather 
information. Current data show the park and surrounding areas meet 
national air quality standards for all six criteria pollutants. 
Nonetheless, ozone levels at the park have remained relatively constant 
over the past 15 years and have exceeded the new air quality standard 
once, despite data that show recent notable declines in ozone for most 
of the United States. Visibility at the park, however, has improved 
over the last 10 years. Monitoring data for 2007 show average 
visibility of over 130 miles--the best visibility in the continental 
United States and well above visibility in other national parks. For 
context, visibility averages about 98 miles at Yosemite National Park 
in California and about 35 miles at the Great Smoky Mountains National 
Park in Tennessee and North Carolina. Additionally, both high 
visibility and the remote location of the park contribute to some of 
the best nighttime views of the Milky Way in the country. 

Stakeholders' views differ on the potential impacts on air quality and 
visibility of building two coal-fired power plants near Great Basin 
National Park. Several groups thought the likely benefits from the 
plants would outweigh any negative impacts on the park. The companies 
that proposed the two power plants have each conducted modeling of the 
potential air quality and visibility impacts of the proposed plants on 
the park. According to company officials, the potential air quality 
impacts are within federal limits--the companies examined the potential 
impacts and reported no adverse impacts on Great Basin National Park. 
In addition, BLM's final EIS for one of the plants found that they 
would cause no adverse impacts on the park. This EIS is now the subject 
of administrative appeal, and BLM has not issued a final EIS for the 
other plant. Further, some local government leaders and residents 
consider the proposed plants necessary for economic development and 
told us that federal and state air quality and visibility standards are 
sufficient to protect the park and the surrounding area. Moreover, 
these stakeholders, as well as officials at the Public Utilities 
Commission of Nevada, said that the plants would help meet electricity 
demands in Nevada and the West. Other stakeholders have concerns about 
the potential impacts of the proposed plants. For example, the NPS-- 
which conducted its own modeling analysis--reported potentially severe 
impacts from even one proposed plant on air quality, visibility, and 
dark night skies. NPS officials also disagree with BLM's EIS analysis. 
In addition, some residents living close to the park, three regional 
Indian tribes, various local and national environmental groups, and 
other stakeholders are concerned that the proposed plants could, among 
other things, adversely impact air quality, visibility, human health, 
and the Great Basin ecosystem. 

Background: 

Under the Clean Air Act, Great Basin National Park, which was created 
in 1986, is designated a Class II area, as are most other areas in the 
country. Parks that encompass more than 6,000 acres and were in 
existence when the Clean Air Act Amendments of 1977 were enacted, such 
as the Grand Canyon and Great Smoky Mountains National Park, are 
designated as Class I areas.[Footnote 6] These areas have the most 
restrictive limits on maximum allowable increases in nitrogen oxides, 
sulfur dioxide, and particulate matter, which affect both air quality 
and visibility.[Footnote 7] Class I areas are areas of environmental 
concern in which little or no growth could occur, while Class II areas 
were designed to allow for orderly, well-controlled growth. 
Additionally, Class II areas are areas that have less restrictive 
limits on allowable increases in nitrogen oxides, sulfur dioxide, and 
particulate matter (as shown in enclosure II, table 1), and states are 
not required to develop and implement control strategies to protect 
visibility in Class II areas. 

The Clean Air Act also established the New Source Review Program to 
address the construction of new sources of air pollution. EPA has 
delegated authority to the Nevada Division of Environmental Protection 
(NDEP) to implement this program, thereby allowing NDEP to review 
applications for permits to build and operate proposed power plants, 
establish emissions limits for the plants, and ensure that the plants 
use appropriate air pollution control technologies. In areas that meet 
federal air quality standards, the Clean Air Act permitting process 
includes a Prevention of Significant Deterioration review to ensure 
that the emissions from a new plant will not exceed maximum allowable 
increases for three of the criteria pollutants--nitrogen oxides, sulfur 
dioxide, and particulate matter. Additionally, under New Source Review, 
applicants estimate through modeling the maximum potential impacts of 
new sources of air pollution for all six of the criteria pollutants. 
The models used to estimate future air quality impacts of power plants 
are highly dependent on the relationships they model, the assumptions 
and data used, and how the results are interpreted. 

In the electricity industry, utility companies and regulators make 
judgments about demand for electric power well into the future because 
new power plants can cost hundreds of millions of dollars and 
projections of future electricity demand can affect the financial 
viability of a new plant. The Department of Energy predicts that demand 
for electricity will increase nationally by 26 percent between 2007 and 
2030. In 2008, Nevada's public utilities projected their peak summer 
electricity demand would increase 49 percent over the next 20 years. 
However, long-range projections of electricity demand are inherently 
uncertain and their accuracy depends on, among other things, 
unforeseeable changes in economic conditions and related fluctuations 
in demand for electricity. For example, the recent economic downturn 
prompted the Department of Energy and the Nevada Public Utilities 
Commission to revise their energy projections. 

Great Basin National Park and Surrounding Areas Currently Meet Federal 
Air Quality Standards and Have Excellent Visibility: 

According to data collected from federal agencies, Great Basin National 
Park and the area around it have some of the cleanest air and best 
visibility in the country. The park is part of the Department of the 
Interior's NPS network of air quality and weather monitoring systems. 
Through agreements with other federal agencies, such as EPA, BLM, and 
the Department of Commerce's National Oceanic and Atmospheric 
Administration, the NPS uses these systems to collect air quality data 
to establish baseline concentrations of air pollution, assess trends in 
air quality, and determine compliance with national ambient air quality 
standards.[Footnote 8] Figure 1 shows a map of the area. 

Figure 1: Map of Nevada and White Pine County: 

[Refer to PDF for image: map of Nevada and White Pine County] 

Noted on the map of White Pine County are locations of the following: 

Proposed White Pine Energy Station; 
Proposed Ely Energy Center; 
Great Basin National Park. 

Sources: Map Info and Map Resources (maps). 

[End of figure] 

According to EPA, the park and surrounding areas currently meet the 
standards for the six criteria pollutants--carbon monoxide, nitrogen 
oxides, sulfur dioxide, particulate matter, lead, and ozone. Although 
the park meets the standards for the criteria pollutants, ozone levels 
are close to reaching the newly revised EPA standard. Ozone is a gas 
that is usually not emitted directly into the air, but rather is 
created by a reaction between nitrogen oxides and volatile organic 
compounds in the presence of sunlight. According to EPA, when ozone is 
located close to the earth (ground-level ozone) at concentrations above 
the EPA standard, it can trigger a variety of human health problems, 
including chest pain, congestion, and coughing. Breathing ozone can 
also worsen bronchitis and asthma and has been shown to reduce lung 
function and inflame the lining of the lungs. Motor vehicle exhaust and 
industrial emissions, including emissions from power plants, contain 
chemicals that can contribute to the formation of ozone, which is the 
primary component of smog. Many urban areas tend to have high levels of 
ground-level ozone, but even remote areas such as Great Basin National 
Park are subject to increased ozone levels because wind can carry ozone 
and the pollutants involved in its formation miles from their original 
sources. Coal-fired power plants also emit particulate matter, one of 
the criteria pollutants regulated by EPA. According to EPA, numerous 
scientific studies have linked particulate pollution exposure to a 
variety of health problems including increases in respiratory symptoms 
such as irritation of the airways or difficulty breathing, aggravated 
asthma, irregular heartbeat, heart attacks, and premature death. 

Nationally, average ozone levels declined in the 1980s, leveled off in 
the 1990s, and declined steeply after 2002. Nonetheless, over the past 
15 years, ozone levels at Great Basin National Park have remained 
relatively constant. Specifically, over the past few years, ozone 
concentrations at the park have been consistently high and are close to 
reaching the revised air quality standard. For example, according to 
data collected by NPS, on one day in 2008, the highest 8-hour average 
ozone level at the park was 76 parts per billion, which exceeds the new 
8-hour ozone standard set by EPA of 75 parts per billion.[Footnote 9] 
NPS officials told us the ozone levels at the park are surprising, 
considering the remoteness of the park. Compared with other national 
parks, Great Basin National Park is one of the best for visibility, yet 
near the middle for ozone concentrations. Figure 2 shows the annual 
fourth-highest daily maximum 8-hour ozone concentrations at Great Basin 
National Park over the last 15 years. 

Figure 2: Annual Fourth-Highest 8-Hour Ground-Level Ozone 
Concentrations at Great Basin National Park, 1994 to 2008: 

[Refer to PDF for image: line graph] 

Year: 1994; 
Ozone concentration (parts per billion): 69. 

Year: 1995; 
Ozone concentration (parts per billion): 67. 

Year: 1996; 
Ozone concentration (parts per billion): 74. 

Year: 1997; 
Ozone concentration (parts per billion): 74. 

Year: 1998; 
Ozone concentration (parts per billion): 70. 

Year: 1999; 
Ozone concentration (parts per billion): 72. 

Year: 2000; 
Ozone concentration (parts per billion): 77. 

Year: 2001; 
Ozone concentration (parts per billion): 67. 

Year: 2002; 
Ozone concentration (parts per billion): 74. 

Year: 2003; 
Ozone concentration (parts per billion): 71. 

Year: 2004; 
Ozone concentration (parts per billion): 72. 

Year: 2005; 
Ozone concentration (parts per billion): 73. 

Year: 2006; 
Ozone concentration (parts per billion): 72. 

Year: 2007; 
Ozone concentration (parts per billion): 75. 

Year: 2008; 
Ozone concentration (parts per billion): 71. 

Source: GAO analysis of NPS data. 

[End of figure] 

Despite the relatively high ozone levels at the park, visibility at the 
park is excellent and has improved over the last 10 years. According to 
visibility monitoring data for 2007, the best visibility in the 
continental United States exists in an area centered around Great Basin 
National Park--where visibility averages range seasonally between about 
60 and 200 miles, with summer having the haziest conditions. Figure 3 
shows photographs of a high-visibility day at the park and a reduced- 
visibility day--a day with low visibility due to haze. 

Figure 3: Observed High-and Reduced-Visibility Days at Great Basin 
National Park: 

[Refer to PDF for image: two photographs] 

Great Basin National Park, day with high visibility; 
Great Basin National Park, day with reduced visibility. 

Note: These pictures represent a spectrum series of regional haze 
visibility conditions observed at Great Basin National Park for the 
selected monitoring time period, 1986 to 1995. 

Source: NPS. 

[End of figure] 

On several of the clearest days in 2007, views of up to 180 miles were 
possible at Great Basin National Park--and on a day in October 2007, 
visibility was about 214 miles. In contrast, on several of the haziest 
days in 2007, views of only about 60 miles were possible. See figure 4 
for annual visibility trends at the park for the past 10 years. 

Figure 4: Annual Visibility Trends at Great Basin National Park, 1998 
to 2007: 

[Refer to PDF for image: multiple line graph] 

Year: 1998; 
Mean of the cleanest one-fifth of sample days: 155 miles; 
Mean of the haziest one-fifth of sample days: 85 miles; 
Mean of all sample days: 116 miles. 

Year: 1999; 
Mean of the cleanest one-fifth of sample days: 157 miles; 
Mean of the haziest one-fifth of sample days: 80 miles; 
Mean of all sample days: 116 miles. 

Year: 2000; 
Mean of the cleanest one-fifth of sample days: 157 miles; 
Mean of the haziest one-fifth of sample days: 80 miles; 
Mean of all sample days: 119 miles. 

Year: 2001; 
Mean of the cleanest one-fifth of sample days: 167 miles; 
Mean of the haziest one-fifth of sample days: 86 miles; 
Mean of all sample days: 125 miles. 

Year: 2002; 
Mean of the cleanest one-fifth of sample days: 175 miles; 
Mean of the haziest one-fifth of sample days: 73 miles; 
Mean of all sample days: 122 miles. 

Year: 2003; 
Mean of the cleanest one-fifth of sample days: 171 miles; 
Mean of the haziest one-fifth of sample days: 87 miles; 
Mean of all sample days: 129 miles. 

Year: 2004; 
Mean of the cleanest one-fifth of sample days: 182 miles; 
Mean of the haziest one-fifth of sample days: 96 miles; 
Mean of all sample days: 135 miles. 

Year: 2005; 
Mean of the cleanest one-fifth of sample days: 185 miles; 
Mean of the haziest one-fifth of sample days: 74 miles; 
Mean of all sample days: 129 miles. 

Year: 2006; 
Mean of the cleanest one-fifth of sample days: 177 miles; 
Mean of the haziest one-fifth of sample days: 86 miles; 
Mean of all sample days: 132 miles. 

Year: 2007; 
Mean of the cleanest one-fifth of sample days: 180 miles; 
Mean of the haziest one-fifth of sample days: 85 miles; 
Mean of all sample days: 133 miles. 

Source: GAO analysis of NPS data. 

[End of figure] 

For context, average visibility (the mean of all sample days) at Great 
Basin National Park in 2007 was 133 miles, compared to 98 miles on 
average in Yosemite National Park in California and 35 miles on average 
at the Great Smoky Mountains National Park in Tennessee and North 
Carolina. For a multiyear comparison of mean visibility trends at Great 
Basin National Park and other national parks, see figure 5.[Footnote 
10] 

Figure 5: Mean Annual Visibility Trends at Selected National Parks, 
1998 to 2007: 

[Refer to PDF for image: multiple line graph] 

Year: 1998; 
Great Smoky Mountains National Park, Tennessee and North Carolina: 31 
miles; 
Yosemite National Park, California: 98 miles; 
Bryce Canyon National Park, Utah: 119 miles; 
Great Basin National Park, Nevada: 116 miles; 
Denali National Park and Preserve, Alaska: 151 miles. 

Year: 1999; 
Great Smoky Mountains National Park, Tennessee and North Carolina: 30 
miles; 
Yosemite National Park, California: 82 miles; 
Bryce Canyon National Park, Utah: 115 miles; 
Great Basin National Park, Nevada: 116 miles; 
Denali National Park and Preserve, Alaska: 142 miles. 

Year: 2000; 
Great Smoky Mountains National Park, Tennessee and North Carolina: 30 
miles; 
Yosemite National Park, California: 94 miles; 
Bryce Canyon National Park, Utah: 121 miles; 
Great Basin National Park, Nevada: 119 miles; 
Denali National Park and Preserve, Alaska: 158 miles. 

Year: 2001; 
Great Smoky Mountains National Park, Tennessee and North Carolina: 35 
miles; 
Yosemite National Park, California: 103 miles; 
Bryce Canyon National Park, Utah: 119 miles; 
Great Basin National Park, Nevada: 125 miles; 
Denali National Park and Preserve, Alaska: 159 miles. 

Year: 2002; 
Great Smoky Mountains National Park, Tennessee and North Carolina: 34 
miles; 
Yosemite National Park, California: 92 miles; 
Bryce Canyon National Park, Utah: 119 miles; 
Great Basin National Park, Nevada: 122 miles; 
Denali National Park and Preserve, Alaska: 158 miles. 

Year: 2003; 
Great Smoky Mountains National Park, Tennessee and North Carolina: 39 
miles; 
Yosemite National Park, California: 98 miles; 
Bryce Canyon National Park, Utah: 128 miles; 
Great Basin National Park, Nevada: 129 miles; 
Denali National Park and Preserve, Alaska: 156 miles. 

Year: 2004; 
Great Smoky Mountains National Park, Tennessee and North Carolina: 34 
miles; 
Yosemite National Park, California: 103 miles; 
Bryce Canyon National Park, Utah: 120 miles; 
Great Basin National Park, Nevada: 135 miles; 
Denali National Park and Preserve, Alaska: 160 miles. 

Year: 2005; 
Great Smoky Mountains National Park, Tennessee and North Carolina: 32 
miles; 
Yosemite National Park, California: 103 miles; 
Bryce Canyon National Park, Utah: 127 miles; 
Great Basin National Park, Nevada: 129 miles; 
Denali National Park and Preserve, Alaska: 162 miles. 

Year: 2006; 
Great Smoky Mountains National Park, Tennessee and North Carolina: 35 
miles; 
Yosemite National Park, California: 101 miles; 
Bryce Canyon National Park, Utah: 127 miles; 
Great Basin National Park, Nevada: 132 miles; 
Denali National Park and Preserve, Alaska: 152 miles. 

Year: 2007; 
Great Smoky Mountains National Park, Tennessee and North Carolina: 35 
miles; 
Yosemite National Park, California: 98 miles; 
Bryce Canyon National Park, Utah: 120 miles; 
Great Basin National Park, Nevada: 133 miles; 
Denali National Park and Preserve, Alaska: 157 miles. 

Source: GAO analysis of NPS data. 

[End of figure] 

The high visibility at Great Basin National Park, as well as its remote 
location--away from large sources of artificial nighttime lighting-- 
contributes to clear views of the night sky. However, light pollution 
has increased in many national parks. According to the NPS Night Sky 
Team,[Footnote 11] light pollution--defined as the illumination of the 
night sky caused by artificial light--has been growing over the years 
because of the increased use of artificial lighting to, for example, 
light facilities, roads, and homes. Light pollution affects not only 
humans, but also nocturnal animals, which depend on the darkness to 
hunt, conceal their location, and reproduce. The Night Sky Team visited 
the park from 2004 to 2006 and collected baseline data to determine the 
darkness of the night skies. The team found that the park's night skies 
are among the nation's darkest--these near-pristine nighttime 
conditions provide one of the best nighttime views of the Milky Way in 
the country. 

Stakeholders' Views Differ on the Extent to Which Two Proposed Coal- 
Fired Power Plants Could Affect Air Quality and Visibility in and 
around the Park: 

Stakeholders' views differ on the potential impacts of proposed coal- 
fired power plants on Great Basin National Park. In particular, several 
stakeholder groups told us that the likely benefits from the proposed 
plants would outweigh any negative impacts on the park. The two 
companies that proposed building power plants near the park each 
conducted modeling to determine potential air quality and visibility 
impacts of the plants, as required by NDEP.[Footnote 12] According to 
company officials, their modeling showed the plants' air quality 
impacts would be within allowable federal limits. Additionally, NDEP 
completed its independent technical evaluation for each proposed plant 
and determined that all potential air quality and visibility impacts 
would be within allowable state and federal limits. NDEP made available 
for public review and comment draft permits and supporting technical 
review documents that provided the basis for its determination that the 
proposed plants would comply with all applicable state and federal air 
quality requirements. Although states are not required to develop and 
implement control strategies to protect visibility in Class II areas 
such as Great Basin National Park, according to the modeling conducted 
by these companies, visibility at the park would not be adversely 
impacted by the addition of two new power plants. 

The companies proposing the two power plants postponed their projects 
in early 2009 due to environmental, regulatory, and economic 
uncertainties.[Footnote 13] In response to the companies' 
announcements, NDEP suspended its review of each project. NDEP 
officials said if the companies decide to resume plans to develop their 
proposals, NDEP would require significant revisions to each permit 
application--such as updating models with more recent data, changing 
analyses to reflect any regulatory changes that have occurred in the 
intervening time period, or revising the proposals to reflect updated 
technologies incorporated into the design of each plant. 

To satisfy NEPA requirements, BLM completed an EIS for one of the power 
plants and issued its Record of Decision in late 2008 authorizing the 
issuance of the right-of-way and eventual sale of land to the company. 
However, BLM's decision is the subject of an administrative appeal by a 
coalition of environmental advocacy and other groups. BLM was in the 
process of developing an EIS for the second plant when, in early 2009, 
both companies publicly stated they have indefinitely postponed 
development of these plants. 

In the final EIS for one of the proposed plants, BLM summarized the 
findings of the modeling conducted by the company and contributed its 
own analysis. BLM assessed the potential impacts of one of the proposed 
plants on air quality and visibility in and around the park. BLM's 
analysis also involved a cumulative analysis that included the second 
plant, because at that point, BLM described the second plant as a 
reasonably foreseeable future action. According to the final EIS, 
results show that predicted impacts are less than national air quality 
standards and, therefore, are not expected to result in adverse impacts 
to human health or the environment. The final EIS' cumulative analysis 
also stated that the area is not expected to experience significant 
deterioration in air quality and the impacts from the cumulative 
emissions are less than the limits established to protect against 
decreased visibility. Nevertheless, BLM's Record of Decision required 
the company to incorporate best practices into the design and operation 
of the plant to mitigate the plant's potential visibility impacts, as 
well as lighting requirements to limit impacts to dark night skies, and 
to provide for future sequestration of carbon emissions. 

In January 2009, a coalition of environmental advocacy and other groups 
appealed this Record of Decision on several grounds, including that 
BLM's air quality analysis did not satisfy the requirements of NEPA, in 
part because BLM did not independently analyze potential air quality 
impacts. Additionally, the appeal states that visibility impacts are 
likely to be greater than BLM's analysis showed. For the second plant, 
BLM was in the process of developing an EIS; however, the company 
postponed plans to develop its plant, and BLM has since stopped working 
on the EIS. If the company decides to continue pursuing the plant as 
proposed, BLM would then resume work on an EIS--and could require the 
company to reinitiate the entire EIS process. A timeline of the 
development process for each plant is shown in figure 6. 

Figure 6: Timeline for Proposed Coal-Fired Power Plants near Ely, 
Nevada: 

[Refer to PDF for image: time line] 

White Pine Energy Station: 
* August, 2004: BLM begins work on EIS; 
* December, 2007: Company submits permit application to NDEP; 
* October, 2008: BLM completes EIM; 
* December, 2008: BLM issues Record of Decision; 
* January, 2009: Groups appeal BLM decision; 
* March, 2009: Company postpones project. 

Ely Energy Center: 

* January, 2007: BLM begins work on EIS; 
* October, 2007: Company submits permit application to NDEP; 
* February, 2009: Company postpones project. 

Source: GAO. 

[End of figure] 

Further, some local government leaders, as well as residents, told us 
and as reflected in public comments that the proposed plants are 
necessary for economic development and that the Great Basin Region is 
sufficiently protected by federal and state air quality and visibility 
standards. Local government leaders and one local Indian tribe support 
building the power plants as a way to provide jobs to area residents, 
increase the local tax base, and diversify the local economy. For 
example, according to a local government official, area job 
opportunities are generally limited to the mining industry, a maximum 
security prison, and other public sector jobs, and the local tax base 
is weak. According to officials of both companies, the plants would 
provide both temporary and permanent job opportunities. Each company 
projected to offer over 1,000 temporary positions during the roughly 5- 
year construction period and estimated approximately 150 permanent jobs 
once the plants are completed. City officials told us they are 
especially interested in the permanent positions associated with the 
projects, and other local government leaders view the industry as a way 
to keep young residents within the community. Additionally, in the 
final EIS, BLM analyzed possible socioeconomic benefits--projecting the 
proposed plant would generate over $129 million in tax revenue during 
its 5-year construction period and an average of more than $16.5 
million in tax revenue during each of its first 5 years of operation-- 
all of which would be a major fiscal benefit to the state and local 
government agencies, particularly those in White Pine County.[Footnote 
14] 

In addition, these stakeholders and officials from the Public Utilities 
Commission of Nevada said the plants are needed to help meet the 
expected growth in electricity demand in Nevada and the West in 
general. According to the companies, the combined electric generation 
capacity of the two proposed plants would be about 3,000 megawatts 
[Footnote 15]. Such additional capacity could increase Nevada's 
electricity generation capability by about 31 percent from its 2007 
level, contributing significantly to the state utilities' expected 
demand growth of 49 percent from 2008 to 2028. However, long-range 
projections of electricity demand are inherently uncertain and their 
accuracy depends on, among other things, unforeseeable changes in 
economic conditions and related fluctuations in demand for electricity. 
For example, the recent economic downturn prompted the Department of 
Energy and the Nevada Public Utilities Commission to revise their 
projections. 

Other stakeholders, including the NPS, some residents living near the 
park, local and national environmental groups, and three regional 
Indian tribes, have concerns about the impacts of the proposed plants 
on air quality and visibility. For example, the officials of the NPS 
are concerned about the potential air quality impacts of ozone, as well 
as emissions of nitrogen oxides, sulfur dioxide, and mercury on the 
park and surrounding areas. In enclosure II, tables 2 and 3 list top 
major sources of nitrogen oxides and sulfur dioxide emissions within 
approximately 200 miles of Great Basin National Park, including the 
potential emissions of the two proposed power plants. According to the 
NPS's modeling, emissions from even one of the new plants could have 
significant negative impacts on air quality in the park and the 
surrounding area, and both plants would have a more severe impact. 

Regarding visibility, stakeholders differ on their interpretation of 
modeling results. While EPA's Regional Haze Rule requires states to 
develop plans to prevent future or remedy existing visibility 
impairment in mandatory Class I federal areas, neither states nor EPA 
are required to develop and implement control strategies to protect 
visibility in Class II areas such as Great Basin National Park. 
However, NPS officials identified the park as a sensitive area and 
requested the companies and BLM to analyze potential visibility impacts 
of the proposed coal-fired power plants on the park in the same way 
that they would analyze visibility impacts on Class I areas. The NPS 
also conducted its own visibility analysis based on Federal Land 
Managers' guidelines, which includes modeling and analyses to assess 
whether a major new source of air pollution would have an adverse 
impact on air quality and visibility of Class I areas.[Footnote 16] 
According to these guidelines, the federal land manager determines 
adverse impact findings on a project-specific basis, based on reviews 
of the frequency, magnitude, duration, and location of projected 
impacts.[Footnote 17] 

The NPS's analysis showed that operating the two plants would cause 
visibility to deteriorate to the extent that if the park were a Class I 
area, NPS officials would have encouraged a finding of adverse impact 
on air quality and visibility. However, since Great Basin National Park 
is a Class II area, they could not make this adverse impact finding. 
Specifically, its analysis showed that annually, one of the plants 
would cause noticeable changes in visibility at the park for about 20 
percent of days and the two plants combined would cause noticeable 
visibility changes for about 32 percent of days. This screening 
analysis was based on the federal land managers' guidance for mandatory 
Class I federal areas, assuming "natural" background and visibility 
conditions and seasonal average relative humidity values.[Footnote 18] 
NPS officials also said the plants--individually or combined--would 
severely impact dark night skies because air pollution particles from 
the plants would increase the scattering of new and existing light in 
the atmosphere and decrease nighttime visibility. 

NPS officials said their analysis and the analysis conducted by one of 
the companies both indicate that visibility impacts from the proposed 
coal-fired power plants would be the most severe NPS officials have 
ever encountered from a proposed new source of air pollution on a 
protected area. In addition, NPS officials disagree with both BLM's 
interpretation of the companies' analysis and BLM's own analysis--that 
is, NPS considers BLM to have understated the severity and magnitude of 
potential impacts on Great Basin National Park. NPS officials told us 
they disagreed with how BLM conducted its analysis and the conclusions 
BLM officials reached about visibility impacts of one of the proposed 
power plants. For example, while BLM's analysis described moderate 
visibility changes at Great Basin National Park, NPS officials say the 
impacts on the park would be unacceptable. According to BLM, this lack 
of consensus between NPS and BLM results, in part, from the choice of 
analysis methods and assumptions used by each agency. For example, in 
interpreting modeling guidance for federal land managers, BLM and NPS 
relied on meteorological data from different years and differed in 
their interpretations of the degree to which projected visibility 
impairments would result from weather conditions versus pollution from 
the plants. 

Finally, some people living near the park, three regional Indian 
tribes, several local and national environmental groups, and other 
stakeholders have concerns that the emissions of the proposed plants 
could, among other things, adversely affect air quality, visibility, 
human health, and the Great Basin ecosystem. For example, in public 
comments on the proposed plants, environmental advocacy groups said 
that criteria pollutants and mercury emissions from the plants could 
lead to adverse health effects in people and animals. Three regional 
Indian tribes echoed these concerns, stating that air pollution from 
the plants would worsen high asthma rates and harm native wildlife and 
traditional foods throughout the region. 

These and other stakeholders are concerned that air pollution from the 
plants could harm sensitive aquatic ecosystems in and around the park 
and could jeopardize populations of cutthroat trout, which has been 
identified as a federally threatened species. In addition, local 
stakeholders told us that tourists come to the area to visit the park, 
fish in local lakes, watch birds, and hunt. According to NPS, in 2007 
the park generated $5.4 million in direct and secondary economic 
benefits to White Pine County. Additionally, a local Indian tribe and a 
national environmental group told us that Nevada has a high potential 
for developing renewable energy sources, and the state should explore 
these options. 

We provided a summary of the findings of this report to representatives 
from the Environmental Protection Agency, the Bureau of Land 
Management, the National Park Service, the Nevada Division of 
Environmental Protection, and to representatives from the proposed 
plants, and incorporated their technical comments, as appropriate. We 
are sending copies of this report to appropriate congressional 
committees and other interested parties. In addition, this report will 
be available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-3841 or stephensonj@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. Key contributors to this report 
include Michael Hix (Assistant Director), Summer Lingard, Heather 
Chartier, Nancy Crothers, Philip Farah, Cindy Gilbert, Jeanette Soares, 
Karen Keegan, Kirk Menard, and Kristin Hughes. 

Signed by: 

John B. Stephenson:
Director, Natural Resources and Environment: 

List of Congressional Addressees: 

The Honorable Dianne Feinstein:
Chairman:
The Honorable Lamar Alexander:
Ranking Member:
Subcommittee on Interior, Environment, and Related Agencies:
Committee on Appropriations:
United States Senate: 

The Honorable Norman D. Dicks:
Chairman:
The Honorable Michael K. Simpson:
Ranking Member:
Subcommittee on Interior, Environment, and Related Agencies:
Committee on Appropriations:
House of Representatives: 

The Honorable Harry Reid:
United States Senate: 

[End of section] 

Enclosure I: Scope and Methodology: 

To answer the first objective, we reviewed relevant rules and policies 
on federal air quality requirements overall and as they relate to 
national parks. We obtained and analyzed data from air quality and 
visibility monitoring networks. To assess the data reliability of the 
National Park Service's Interagency Monitoring of Protected Visual 
Environments (IMPROVE) data, we (1) performed electronic testing of 
required data elements, (2) reviewed existing information about the 
data and the system that produces them, and (3) interviewed agency 
officials knowledgeable about the data. We determined that the data 
were sufficiently reliable for the purposes of this report. 
Additionally, we interviewed relevant agency officials at the 
Environmental Protection Agency, the National Park Service, the Bureau 
of Land Management, and the Nevada Division of Environmental Protection 
regarding current air quality and visibility in the park. 

To answer the second objective and describe stakeholders' views about 
the potential impacts of two proposed coal-fired power plants on air 
quality and visibility in and around the park, we interviewed relevant 
agency officials, stakeholders, and organizations about individual and 
cumulative impacts of two proposed coal-fired power plants on the park. 
We also reviewed public comments and resolutions and reported 
stakeholder analysis. We did not independently review the analysis done 
by stakeholders. 

Some stakeholders we interviewed are members of different 
organizations, including local and national environmental groups, local 
and regional Indian tribes, members of the community surrounding the 
park, representatives of city and county government, and members of the 
Chamber of Commerce. Some of these individuals are members of multiple 
organizations and submitted comments or spoke with GAO on behalf of 
other groups. Additionally, we interviewed all stakeholders when both 
companies were actively pursuing construction and operating permits 
from the Nevada Division of Environmental Protection and rights-of-way 
on the Bureau of Land Management's land. 

Our policy is to avoid taking a position on or addressing matters that 
are pending in litigation. Due to the pending administrative appeal of 
the Bureau of Land Management's Record of Decision on the Environmental 
Impact Statement, GAO did not independently quantify or assess how the 
new plants, if built, could contribute to air quality changes; but 
rather, we reviewed and reported on available information on such 
impacts from the proposed coal-fired power plant permits, and analysis 
conducted by other stakeholders. We did not assess the permit 
applications, the quality of the modeling conducted by the applicant, 
or the quality of the data used to conduct the modeling analysis due to 
the pending appeal. Additionally, we did not solicit the views of 
stakeholders on the appeal or offer opinions on the reliability of any 
air quality modeling performed. 

To gain a better understanding of how coal-fired power plants work, we 
visited a power plant in Maryland and discussed with company officials 
how their coal plant operated. Finally, we visited Great Basin National 
Park, where we observed air quality monitoring equipment and air 
quality and visibility in and around the park, and met with local 
stakeholders. We conducted our work from September 2008 to July 2009 in 
accordance with all sections of GAO's Quality Assurance Framework that 
are relevant to our objectives. The framework requires that we plan and 
perform the engagement to obtain sufficient and appropriate evidence to 
meet our stated objectives and to discuss any limitations in our work. 
We believe that the information and data obtained, and the analysis 
conducted, provide a reasonable basis for any findings and conclusions 
in this product. 

[End of section] 

Enclosure II: Additional Tables: 

As shown in table 1, Class II areas have less restrictive limits on 
allowable increases in nitrogen dioxide, sulfur dioxide, and 
particulate matter. 

Table 1: Prevention of Significant Deterioration Increments for Class I 
and Class II Areas: 

Pollutant: Particulate matter (PM10); 
Measurement[A]: Annual arithmetic mean; 
Class I[B]: 4; 
Class II[B]: 17. 

Pollutant: Particulate matter (PM10); 
Measurement[A]: 24-hour maximum; 
Class I[B]: 8; 
Class II[B]: 30. 

Pollutant: Sulfur dioxide (SO2); 
Measurement[A]: Annual arithmetic mean; 
Class I[B]: 2; 
Class II[B]: 20. 

Pollutant: Sulfur dioxide (SO2); 
Measurement[A]: 24-hour maximum; 
Class I[B]: 5; 
Class II[B]: 91. 

Pollutant: Sulfur dioxide (SO2); 
Measurement[A]: 3-hour maximum; 
Class I[B]: 25; 
Class II[B]: 512. 

Pollutant: Nitrogen dioxide (NO2)[C]; 
Measurement[A]: Annual arithmetic mean; 
Class I[B]: 2.5; 
Class II[B]: 25. 

Source: Clean Air Act. 

[A] For any period other than an annual period, the applicable maximum 
allowable increase may be exceeded during one such period per year at 
any one location. 

[B] Maximum allowable increase (micrograms per cubic meter--g/m3). 

[C] Nitrogen dioxide is one of a group of highly reactive gasses known 
as "oxides of nitrogen," or "nitrogen oxides." While EPA's National 
Ambient Air Quality Standard covers the entire group of nitrogen 
oxides, nitrogen dioxide is the component of greatest interest and the 
indicator for the larger group of nitrogen oxides. 

[End of table] 

Top major sources of nitrogen oxides and sulfur dioxide emissions 
within approximately 200 miles of Great Basin National Park, including 
the potential emissions of the two proposed power plants, are shown in 
tables 2 and 3. 

Table 2: Top 15 Major Sources of Nitrogen Oxides Emissions within 
Approximately 200 Miles of Great Basin National Park: 

Source: Navajo Generating Station; 
Location: Page, Arizona; 
Distance (miles): 210; 
Tons of nitrogen oxides emitted per year: 33,221. 

Source: Intermountain Power; 
Location: Delta, Utah; 
Distance (miles): 97; 
Tons of nitrogen oxides emitted per year: 25,098. 

Source: Hunter Power Plant; 
Location: Castledale, Utah; 
Distance (miles): 173; 
Tons of nitrogen oxides emitted per year: 18,247. 

Source: Huntington Power Plant; 
Location: Huntington, Utah; 
Distance (miles): 172; 
Tons of nitrogen oxides emitted per year: 10,180. 

Source: Sierra Pacific Power; 
Location: Valmy, Nevada; 
Distance (miles): 204; 
Tons of nitrogen oxides emitted per year: 9,380. 

Source: Nevada Power Company; 
Location: Moapa, Nevada; 
Distance (miles): 159; 
Tons of nitrogen oxides emitted per year: 9,015. 

Source: Nevada Power Company; 
Location: Las Vegas, Nevada; 
Distance (miles): 202; 
Tons of nitrogen oxides emitted per year: 5,735. 

Source: As Proposed: Ely Energy Center[A]; 
Location: Ely, Nevada; 
Distance (miles): 48; 
Tons of nitrogen oxides emitted per year: 4,853. 

Source: As Proposed: White Pine Energy Station[A]; 
Location: Ely, Nevada; 
Distance (miles): 61; 
Tons of nitrogen oxides emitted per year: 4,812. 

Source: Bingham Canyon Mine; 
Location: Bingham Canyon, Utah; 
Distance (miles): 156; 
Tons of nitrogen oxides emitted per year: 3,750. 

Source: Carbon Power Plant; 
Location: Helper, Utah; 
Distance (miles): 189; 
Tons of nitrogen oxides emitted per year: 3,409. 

Source: Power Plant and Lab; 
Location: Magna, Utah; 
Distance (miles): 166; 
Tons of nitrogen oxides emitted per year: 2,067. 

Source: Graymont Western U.S.; 
Location: Shafter, Nevada; 
Distance (miles): 130; 
Tons of nitrogen oxides emitted per year: 1,730. 

Source: Sierra Pacific Power; 
Location: Sparks, Nevada; 
Distance (miles): 204; 
Tons of nitrogen oxides emitted per year: 1,578. 

Source: Chemical Lime Company; 
Location: Las Vegas, Nevada; 
Distance (miles): 182; 
Tons of nitrogen oxides emitted per year: 1,566. 

Source: McCarran International Airport; 
Location: Las Vegas, Nevada; 
Distance (miles): 204; 
Tons of nitrogen oxides emitted per year: 1,474. 

Source: Holcim Devil's Slide Plant; 
Location: Morgan, Utah; 
Distance (miles): 205; 
Tons of nitrogen oxides emitted per year: 1,353. 

Source: GAO analysis of EPA 2005 National Emissions Inventory Data. 

[A] These figures represent the potential emissions modeled by the 
companies in their permit applications. 

[End of table] 

Table 3: Top 15 Major Sources of Sulfur Dioxide Emissions within 
Approximately 200 Miles of Great Basin National Park: 

Source: Huntington Power Plant; 
Location: Huntington, Utah; 
Distance (miles): 172; 
Tons of sulfur dioxide emitted per year: 17,364. 

Source: Sierra Pacific Power; 
Location: Valmy, Nevada; 
Distance (miles): 204; 
Tons of sulfur dioxide emitted per year: 9,607. 

Source: Hunter Power Plant; 
Location: Castledale, Utah; 
Distance (miles): 173; 
Tons of sulfur dioxide emitted per year: 6,278. 

Source: As Proposed: White Pine Energy Station[A]; 
Location: Ely, Nevada; 
Distance (miles): 61; 
Tons of sulfur dioxide emitted per year: 6,071. 

Source: Carbon Power Plant; 
Location: Helper, Utah; 
Distance (miles): 189; 
Tons of sulfur dioxide emitted per year: 5,411. 

Source: As Proposed: Ely Energy Center[A]; 
Location: Ely, Nevada; 
Distance (miles): 48; 
Tons of sulfur dioxide emitted per year: 4,628. 

Source: Navajo Generating Station; 
Location: Page, Arizona; 
Distance (miles): 210; 
Tons of sulfur dioxide emitted per year: 3,944. 

Source: Intermountain Power; 
Location: Delta, Utah; 
Distance (miles): 97; 
Tons of sulfur dioxide emitted per year: 3,597. 

Source: Power Plant and Lab; 
Location: Magna, Utah; 
Distance (miles): 166; 
Tons of sulfur dioxide emitted per year: 3,009. 

Source: Chevron USA Products; 
Location: Salt Lake City, Utah; 
Distance (miles): 179; 
Tons of sulfur dioxide emitted per year: 2,201. 

Source: Nevada Power Company; 
Location: Moapa, Nevada; 
Distance (miles): 159; 
Tons of sulfur dioxide emitted per year: 2,094. 

Source: Sunnyside Cogeneration Facility; 
Location: Sunnyside, Utah; 
Distance (miles): 210; 
Tons of sulfur dioxide emitted per year: 933. 

Source: BP Amoco Refinery; 
Location: Salt Lake City, Utah; 
Distance (miles): 178; 
Tons of sulfur dioxide emitted per year: 880. 

Source: Smelter & Refinery; 
Location: Magna, Utah; 
Distance (miles): 164; 
Tons of sulfur dioxide emitted per year: 777. 

Source: Holly Corporation Refinery; 
Location: Woods Cross, Utah; 
Distance (miles): 183; 
Tons of sulfur dioxide emitted per year: 574. 

Source: Big West Oil Company Flying J Refinery; 
Location: North Salt Lake, Utah; 
Distance (miles): 182; 
Tons of sulfur dioxide emitted per year: 361. 

Source: Graymont Western U.S.; 
Location: Shafter, Nevada; 
Distance (miles): 130; 
Tons of sulfur dioxide emitted per year: 251. 

Source: GAO analysis of EPA 2005 National Emissions Inventory Data. 

[A] These figures represent the potential emissions modeled by the 
companies in their permit applications. 

[End of table] 

[End of section] 

Footnotes: 

[1] Both companies proposed to build one coal-fired power plant with 
multiple coal-fired electricity-generating units. A coal-fired power 
plant includes one or more electricity-generating units, in addition to 
land and auxiliary equipment--such as boilers, turbines, heat 
exchangers, condensers, fabric filters, and other equipment. 

[2] Ozone is a gas that occurs both in the earth's upper atmosphere and 
at ground level. In the upper atmosphere, ozone occurs naturally and 
protects life on earth from the sun's harmful rays. In the lower 
atmosphere, ground-level ozone is caused by, among other things, motor 
vehicle exhaust, industrial emissions, gasoline vapors, as well as 
natural sources that emit nitrogen oxides and volatile organic 
compounds. 

[3] Nitrogen oxides, sulfur dioxide, particulate matter, and ozone can 
travel for many miles and may create compounds which decrease the 
distance we can see, as well as degrade the color, clarity, and 
contrast of scenic vistas. 

[4] A right-of-way is an easement, lease, permit, or license to occupy, 
use or traverse public lands for a specified purpose. 

[5] An environmental assessment generally includes a brief discussion 
of the need for the proposal, alternatives to the proposal, the 
environmental impacts of the proposed action and alternatives, and a 
listing of agencies and persons consulted. A more detailed EIS should 
include a discussion of the purpose of and the need for the proposed 
action, alternatives to the proposed action, the affected environment, 
and the environmental consequences of the proposed action, among other 
things. 

[6] These parks are known as mandatory Class I federal areas. 

[7] As they deem appropriate, states may submit proposals to the EPA 
Administrator to have any area, including a national park, redesignated 
as Class I. Before submitting a proposal, states must (1) consult with 
the elected local government officials in the area proposed to be 
redesignated; (2) prepare a publicly available description and analysis 
of the health, environmental, social, and energy effects of 
redesignation; (3) hold at least one public hearing on the proposed 
redesignation; (4) notify other states and Indian tribes whose lands 
may be affected by the redesignation at least 30 days before the public 
hearing; and (5) provide the appropriate federal land manager, if 
applicable, with written notice and allow the federal land manager 
adequate opportunity, but not more than 60 days, to respond to the 
proposal with comments or recommendations. If the federal land manager 
responds, the state must publish a list of any inconsistencies between 
the redesignation and the federal land manager's response, together 
with the reasons for making the redesignation against the 
recommendation of the federal land manager. The EPA Administrator may 
disapprove a state's proposed redesignation only if the state fails to 
follow these procedural requirements or has proposed redesignating 
certain areas as Class III. 

[8] The monitoring systems at Great Basin National Park are the 
National Atmospheric Deposition Program/National Trend Network, Clean 
Air Status and Trends Network, and Interagency Monitoring of Protected 
Visual Environments. The weather data networks at Great Basin National 
Park are the National Oceanic and Atmospheric Administration's National 
Weather Service and Climate Reference Network, the U.S. Geological 
Survey's High Elevation Precipitation Network, two Remote Automatic 
Weather Stations managed by BLM for the National Interagency Fire 
Center, and the Natural Resources Conservation Service's Snow Course 
Program. 

[9] The national 8-hour air quality standard for ozone is 0.075 parts 
per million, daily maximum 8-hour average. The standard is met at a 
monitoring site when the 3-year average of the annual fourth-highest 
daily maximum 8-hour average ozone concentration is less than or equal 
to 0.075 parts per million (0.075 parts per million is the same as 75 
parts per billion). 

[10] Visibility conditions in the eastern and western United States are 
inherently different because of factors such as climate conditions and 
concentrations of air pollution. 

[11] The NPS Night Sky Team works in parks across the country to 
document the effects of light pollution. Great Basin National Park is 
one of 67 NPS units where baseline data have been collected or data 
collection is under-way. 

[12] White Pine Energy Associates, LLC (an affiliate of LS Power 
Development, LLC) proposed the White Pine Energy Station, and Sierra 
Pacific Resources (now NV Energy, or NVE) proposed the Ely Energy 
Center. 

[13] Since announcing the indefinite postponement of their power 
plants, each company has moved forward with plans to develop a north- 
south electricity transmission line in Eastern Nevada. Both 
transmission lines would provide a first-time connection between the 
northern and southern Nevada service areas and deliver renewable energy 
to market. Additionally, one of the companies would have upgraded the 
existing Nevada Northern Railway to accommodate coal trains into the 
area and restored access for future freight traffic in White Pine and 
surrounding counties. 

[14] BLM's socioeconomic analysis in the EIS cited figures in 2006 
dollars. 

[15] A watt is the basic unit used to measure electric power. A 
kilowatt (kW) equals 1,000 watts, and a megawatt (MW) equals 1,000 kW 
or 1 million watts. Electricity production and consumption are measured 
in kilowatt-hours, while generating capacity is measured in kilowatts 
or megawatts. An average U.S. household consumes roughly 10,000 kWh a 
year. 

[16] These Federal Land Managers' Air Quality Related Values Workgroup 
(FLAG) guidelines are only guidance and not regulations and do not 
provide a universal formula for evaluating impacts. Federal land 
managers that use FLAG guidelines include the NPS and the Fish and 
Wildlife Service in the Department of the Interior and the Forest 
Service in the Department of Agriculture. BLM does not participate in 
FLAG, but rather addresses Prevention of Significant Deterioration 
permit applications on a case-by-case basis. 

[17] The federal land manager for lands administered by the Department 
of the Interior, which NPS is a part of, is the Department's Assistant 
Secretary for Fish and Wildlife and Parks. 

[18] If a single emission source is predicted to exceed a 5 percent 
change in conditions, or a group of two or more sources are predicted 
to exceed a 10 percent change in conditions, FLAG guidance states: 
"then the federal land manager will consider the magnitude, frequency, 
duration, and other factors to assess the impact, but is likely to 
object to the issuance of the permit." The BLM analysis identified that 
up to 66 days per year (18 percent of the days from all sources 
combined) could have a "just noticeable change" in visibility at Great 
Basin National Park. However, the Final EIS stated: "Because of the 
highly conservative nature of the assumptions used for this assessment, 
the actual number of days when perceptible cumulative visibility 
impacts would occur would be considerably lower than these figures." 

[End of section] 

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