EPA Seeks Comment on CSAPR Update for 2008 Ozone NAAQS

On 12/3/15, the EPA proposed updates to the Cross State Air Pollution Rule (CSAPR) in order to incorporate the 2008 NAAQS for ozone. The rule is proposing to update the CSAPR NOx ozone-season budgets for 23 states that affect downwind states’ ability to comply with the 2008 ozone standard. The EPA would issue a Federal Implementation Plan, or FIP, for meeting these budgets if the state does not have a SIP submitted by the finalization of the rule. Implementation would start with the 2017 ozone season.


The EPA seeks comment on some specific parts of the rule:


  • The EPA would like input on whether short-term NOx concentrations from EGU’s disproportionally affect downwind ozone concentrations. If so, what type of short-term emission limits (daily, monthly, etc.) would be appropriate to limit this impact?


  • The EPA would like comments on what types of mitigation strategies for reducing EGU NOx by the 2017 ozone season are reasonable. Options may include:
    • Turning on idling SCR and SCNR’s
    • Upgrade, replace or install state-of-the-art combustion controls such as low-NOx burners or over-fire air
    • Shifting generation towards lower NOx-emitting EGU’s


  • Whether or not non-EGU controls are feasible by the 2017 ozone season (this rule does not propose any, at this point)


Comments must be received by January 19, 2016.


For questions, feel free to contact Air Tox.