Environmental Permitting

Cross-State Air Pollution Revisited—Emissions, Benefits, and Costs

Despite the many court challenges to both the Clean Air Interstate Rule (CAIR) and the Cross-State Air Pollution Rule (CSAPR), power plants are cleaning up their act. According to information from the U.S. Energy Information Administration (EIA), electric power plant emissions of sulfur dioxide (SO2) and nitrogen oxide (NOx) dropped to their lowest levels since the 1990 Clean Air Act Amendments were passed. This steady decline is the direct result of several regulatory moves, including retrofitting coal-fired power plants with flue-gas desulfurization (FGD) “scrubbers,” switching to low-sulfur fuels and implementation of selective catalytic reduction (SCRs), selective noncatalytic reduction (SNCR), or low NOx burners. By the end of 2011, 60 percent of U.S. coal-fired plants were using FGD scrubbers to remove SO2 while 67 percent were using either an SCR or an SNCR to limit NOx.

Another big factor in controlling emissions is the recent natural gas boon. In 2013, according to the EIA, slightly more than 50 percent of new utility-scale power capacity was natural-gas fired, which amounted to 6,861 megawatts (MW), while new coal-fired capacity was just 1,507 MW. Also contributing to lower emissions are other regulations, most notably the Mercury and Air Toxics Standards (MATSs) that will require emissions control technologies the EIA says may also help remove SO2, which is projected to be 52 percent below the 2012 level by 2040.

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Even as the power sector is making improvements, however, the wind continues to blow and emissions continue to find their way into neighboring states. The results are not only noncompliance with federal or state implementation plans but also a range of health concerns that can affect people hundreds of miles from the source. If the CSAPR goes forward as written, however, EPA’s established requirements will result in significant reductions in cross-state SO2 and NOx emissions. In its original estimates, the EPA had planned to begin emissions reductions on January 1, 2012, for annual SO2 and NOx reductions and with summertime ozone season reductions beginning May 1, 2012. Over the next 2 years, the EPA projected that the CSAPR, in combination with other state and federal actions (excluding MATS), would have reduced SO2 emissions by 73 percent and NOx emissions by 54 percent from 2005 levels in the covered region.

Based on EPA’s projections for the CSAPR, decreased cross-state air pollution will result in the following numbers of avoided cases of adverse health effects in impacted states*:

  • Premature mortality—13,000 to 34,000
  • Nonfatal heart attacks—15,000
  • Hospital and emergency department visits—19,000
  • Acute bronchitis—19,000
  • Upper and lower respiratory symptoms—420,000
  • Aggravated asthma—400,000
  • Days of missed work or school—1.8 million

In addition, the EPA also foresees impacted states benefiting from improved visibility in national and state parks, as well as better protection for sensitive ecosystems in forests, lakes, streams, and coastal areas.

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Like all regulations, especially those that spend time in court, the costs of implementation vs. the benefits are very important. According to the EPA, the final CSAPR would have, in 2014, yielded “$120 to $280 billion in annual health and environmental benefits.” In comparison, the annual costs of the rule were estimated at $800 million in 2014. This is in addition to the $1.6 billion in capital investments mandated by the CAIR and which were completed or underway when the CSAPR was first promulgated.

To view an interactive map showing affected states and upwind-downwind linkages for different pollutants, go to http://www.epa.gov/crossstaterule/whereyoulive.html.

*Impacts avoided due to improvements in PM 2.5 and ozone air quality in 2014.

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