Cross-State Air Pollution Rule (CSAPR) Update - Finalized on September 7th, 2016
Due to recent EPA findings indicating that ozone season NOx emissions from fossil fuel fired electricity generating units (EGUs) are severely affecting the ability of downwind states to meet and maintain the 2008 ozone National Ambient Air Quality Standards (NAAQS), as well as the Agency’s obligations under the Clean Air Act to address interstate transport of ozone air pollution, an update to the original 2011 Cross-State Air Pollution Rule (CSAPR) was finalized on September 7th, 2016.
This CASPR Update aims to adjust the existing CSAPR NOx ozone season emission budgets for each state’s fleet of EGUs through adoption of new Federal Implementation Plans for each of the 22 states affected by the update. These new budgets, which will be in place for the upcoming ozone season starting May 2017, are projected to affect 2,875 EGUs at 886 coal-, gas-, and oil-fired facilities in 22 eastern states, including Alabama, Arkansas, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maryland, Michigan, Mississippi, Missouri, New Jersey, New York, Ohio, Oklahoma, Pennsylvania, Tennessee, Texas, Virginia, West Virginia, and Wisconsin.
In order to establish the updated ozone season NOx emission budgets (i.e., tonnage- based, state-level emission limits), the Agency focused on NOx reductions that can be made quickly, such as “simply turning on or optimizing existing pollution control technology”. In doing so, they concluded that the power sector should be able to achieve a substantial amount of cost-effective 2017 ozone season NOx emissions reductions while reliably maintaining the electric grid and ensuring Americans continue to have access to affordable electricity.
The rule offers significant flexibility for facility owner/operators to determine their own compliance path by not requiring any particular facility to make specific reductions or use certain pollution controls, instead utilities can make use of the Ozone Season CSAPR allowance trading program that has been in place since inception of the original CSAPR rule. However, these credits are expected to increase in cost as the demand increases with the CSAPR Update. Where credits may have cost around $300 in the past, the EPA is estimating a credit will cost about $1300 in 2017 and beyond. Due to the uncertainty in the costs of these credits, complying with the CSAPR update using this option could be risky.
If you are weighing the options of combustion tuning, increasing the usage of air pollution controls, and/or purchasing ozone season NOx credits for your facility, consider Neundorfer as a resource for reducing risk and allowing your facility to comply with the rule cost effectively and efficiently. Neundorfer can help by applying our proven holistic approach to problem solving.
For additional information about the CSAPR Update, follow the links below: