NDEE's guidance document 18-006, Haul Road Q&A for Air Quality Permitting was published April 2018 and details general permit conditions for haul roads based on facility size.

  • Large sized facilities (>20,000 vehicle miles traveled [VMT] per year for production related vehicles)
    • All haul roads must be paved
    • Develop a fugitive dust control plan (FDCP)
    • Visible emissions monitoring
    • Recordkeeping requirements
  • Medium sized facilities (>2,000 VMT per year)
    • Develop a FDCP or demonstrate use of Best Management Practices (BMP) on haul roads
    • Visible emissions monitoring
    • Recordkeeping requirements
    • Additional supplemental requirements could include:
      • Paving
      • Silt loading limitations
      • Emissions testing
  • Small sized facilities (<2,000 VMT per year)
    • Use of BMP on haul roads
    • Visible emissions monitoring
    • Recordkeeping requirements

While these permit conditions are general guidelines, they are commonly included in construction permits and, for large facilities, road paving is considered a default requirement that must be followed. Haul road emissions are typically excluded from air dispersion modeling analyses in Nebraska; however, projects subject to EPA's Prevention of Significant Deterioration (PSD) permitting will likely require haul road emissions included in any dispersion modeling analyses.

If you have any questions on haul road requirements or need help preparing a construction permit for your facility, contact Trinity's Kansas City office at (913) 894-4500.