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Aug 28, 2023

It’s time to become EPA’s good neighbor

By Robynn Andracsek, PE, Providence Engineering and Environmental Group LLC

By Robynn Andracsek, PE, Providence Engineering and Environmental Group LLC contributing editor, and Tim Girard, Affiliated Engineers, Inc.

The Environmental Protection Agency (EPA) has spoken: the Good Neighbor Plan was finalized on March 15, 2023. This rule continues EPA's Cross-State Air Pollution Rule (CSAPR) for the 2015 ozone National Ambient Air Quality Standards (NAAQS) and requires initial reductions from Electric Generation Units (EGUs) beginning in the 2023 ozone season (May 1-September 30). The rule pulls in other industries, such as steel, glass, and paper production, which we won't discuss here. Requirements vary in the 23 states affected – see Figure 1.

The rule reduces the number of ozone season allowances, which in turn reduces emissions, using a phased-in approach. The operator of each emission unit subject to the rule must hold sufficient allowances to cover their ozone season nitrogen oxide (NOx) emissions.

2023

2024

2026 – EPA reduces allowances by an amount that assumes:

2027 and beyond

Beware of the Prevention of Significant Deterioration (PSD) permitting implications. EPA states "The actual compliance requirement that the EGUs must meet is simply to hold sufficient allowances to cover emissions during a given control period, not to undertake any specific compliance strategy…Those costs could, in turn, result in a reduction in electricity generation from higher-emitting sources and an increase in electricity generation from lower-emitting or zero-emitting generators, but that kind of generation shifting (not mandated but occurring as an economic choice by the regulated sources) is consistent, and in no way interferes with, the existing security-constrained economic dispatch protocols of the modern electrical grid." Many previous PSD lookback enforcement cases originated from maintenance projects that occurred prior to an increase in capacity factor. Defending causality becomes the responsibility of the EGU.

What should you do?

About the Authors:

Robynn Andracsek, PE, is a Senior Air Quality Engineer at Providence Engineering and Environmental Group LLC with 26 years of experience in air permitting for utilities and district energy facilities. Providence is an employee-owned, multidisciplinary engineering and environmental consulting firm. Our work has taken us across the United States and beyond in support of our governmental and industrial clients’ goals and challenges all the while holding an unwavering dedication to our founding principles – to take care of our clients, make a little money, and have fun while doing it. Her email address is [email protected].

Tim Girard is a Project Manager at Affiliated Engineers, Inc. with 24 years of experience in air quality equipment assessment, engineering and construction projects for industrial and electrical generation facilities. Affiliated is a multidisciplinary engineering and consulting firm with 19 offices in the United States. Our mission drives us to find unique solutions to solve our clients’ challenges and our dedicated team of engineering professionals use industry knowledge, innovative technology and practical solutions to complete complex projects. His email address is [email protected].