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The New Federal Cross-State Air Pollution Rule

On July 6, 2011, the USEPA finalized a rule intended to reduce emissions from power plants of fine particulate matter and pollutants that are precursors to smog, indicated by ambient ozone. This new Cross-State Air Pollution Rule (CSAPR) will replace current Clean Air Interstate Rule (CAIR) on Jan. 1, 2012, and will require 27 states to regulate power plant emissions that are normally transported to and affect other states.

The Problem

Recent medical research has demonstrated that emissions of fine PM (particles with an aerodynamic diameter of 2.5 microns or less, PM2.5) may be causing greater adverse health effects in the U.S. than previously thought. PM2.5 can penetrate past our natural defenses (i.e., bronchial tube cilia) and get lodged within lung vesicles, in many cases leading to their reduced function. Also, with a large surface area to volume, PM2.5 can attract and ultimately transport other toxic pollutants deep into the lungs which can then be exchanged into our bloodstream for transport throughout the body. Some examples include sulfur dioxide (SO2, which in our blood is converted to the acidic form, sulfuric acid) and metals, causing greater exposure to these than in a PM2.5-free environment.

Nitrogen oxides (“NOx”) are known precursors of smog. Catalyzed by the sun, smog is composed of thousands of compounds, many of them toxic. Ozone is a lung irritant.

The Clean Air Act requires states generate real-time data of ambient air concentrations of these pollutants to determine whether regions attain national ambient air quality standards (NAAQS) or not. Much of the U.S. is non-attainment for ozone NAAQS, and has been so for decades despite stringent rules to reduce NOx emissions. There is evidence that continued elevated ozone levels are due to transport of NOx from other states, many of which are in attainment with ozone NAAQS and have little reason to stringently regulate emissions from power plants, a major source of these compounds.

What CSAPR Intends to Achieve

Basic information about CSAPR, including which states are covered, may be found at: http://www.epa.gov/airtransport/basic.html. CSAPR requires 23 states to reduce annual SO2 and NOx emissions to help downwind areas attain the PM2.5 NAAQS. 20 states are required to reduce NOX emissions during peak (summer) ozone season only to help downwind areas attain the 8-hour ozone NAAQS. CSAPR divides the states required to reduce SO2 into two groups with Group 1 states required to achieve additional emission reductions by 2014 because of their large contribution to downwind air quality problems.

CSAPR allows allowance trading among covered sources, utilizing an allowance market infrastructure based on allowances given to states based on the estimated baseline downwind impacts of their sources. The final rule allows sources to trade emission allowances with other sources within the same program (i.e., ozone season NOx) in the same or different states, while firmly constraining emission trading that may occur by requiring a strict emission limit in each state based on its budget plus a variability limit.

For prompt implementation, the USEPA is adopting a federal implementation plan (FIP) for each affected state; a state may replace its FIP with a State Implementation Plan (SIP) should it choose by 2014. The rule allows a state to modify its FIP, such as allowance allocations (crediting sources for allowances banked under earlier programs).

What This Means

As is commonplace in these days of political attacks on the USEPA, the agency has published substantial data to justify the new CSAPR on sound economic and health bases. According to the USEPA, CSAPR will, by 2014, reduce SO2 emissions from target power plants by 73% and NOx by 54% (2005 baseline) and annually avoid:
• 13,000 to 34,000 premature deaths
• 19,000 hospital and emergency room visits
• 1.8 million lost work days or school absences

Emission reductions will also lead to improvements in visibility in parks, and increased protection for ecosystems including lakes, streams, coastal waters, and forests.

The USEPA estimates that, by 2014, CSAPR will result in $120-$280 billion in annual health benefits, far outweighing its estimated additional annual cost of $800 million.

Marc Karell is the owner of Climate Change & Environmental Services. Read more useful material in the company’s blog: www.CCESworld.com/blog. CCES has the technical knowledge and real life experience to help all kinds of firms set up “green”, climate change, and sustainability programs that result in many of the benefits listed here. We can help you organize your program, as well as gain the maximum financial benefits possible. And we can help you get the most publicity out of the program results and train you to run your own program independently in the future. Get more useful information in our blog.

Marc Karell
Marc Karell is the owner of Climate Change & Environmental Services. Get more useful information in our blog: www.CCESworld.com/blog.
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