As of January 1, 2015 the U.S. Environmental Protection Agency (U.S. EPA) has been implementing the Cross-State Air Pollution Rule (CSAPR) through a Federal Implementation Plan (FIP) that primarily impacts electric generating units (EGUs).
This article reviews the transition of the Clear Air Interstate Rule and nitrogen oxide (NO2), sulfur dioxide (SO2) allowances to CSAPR allowances and rules. Read on for an explanantion of how this affects the state and local air pollution control agencies, specifically how Pennsylvania Department of Environmental Protection (PADEP) will react.
The transition from the Clean Air Interstate Rule (CAIR) and its nitrogen oxide (NOX) and sulfur dioxide (SO2) Allowances to CSAPR Allowances and rules has been fairly smooth so far. The state and local air pollution control agencies do have the opportunity to adopt their own regulations to implement CSAPR with the accompanying revisions to their State Implementation Plans (SIPs). However, there has been no indication from the Pennsylvania Department of Environmental Protection (PADEP) that they are actively working on such a regulatory revision. For 2015 and 2016 Phase 1 CSAPR Allowance requirements, all indications are that the allowances requirements will easily be met by the EGUs. However, in 2017 the Phase 2 allowance allocations are significantly reduced. For NOXAllowances there is not a dramatic drop in allocations. But for SO2 Allowances, the allocations are cut in half or more in most cases. The present relative surplus of SO2 Allowances will get much tighter with time.