Should Texas Be Included in the Cross-State Air Pollution Rule?

The document examines the debate over the EPA's Cross-State Air Pollution Rule (CSAPR) and its application to Texas. It refutes arguments from Texas officials and energy companies regarding grid reliability, compliance timelines, and the validity of emission data. The brief highlights that many Texas coal plants already possess the necessary control technology and that the rule's implementation would provide significant public health benefits for both downwind states and Texas communities.

• Claims by the Electric Reliability Council of Texas (ERCOT) that CSAPR could cause blackouts and a capacity reduction of 1,200-6,000 megawatts (MW) lacked unit-specific supporting information and ignored potential new capacity additions that could offset coal plant closures.
• The EPA provided options to avoid plant closures, including technical adjustments that would grant Texas and Luminant "thousands of additional tons of pollution allowances to reduce required emissions reductions."
• The assertion that the SO2 program was 'sprung' on Texas is contradicted by the 2010 Proposed Rule, which explicitly asked stakeholders for comment on Texas's inclusion in the SO2 program because projected emissions would exceed the 0.15µ.m3 threshold for annual PM 2.5.
• Arguments against inclusion based on 2010 emissions data are flawed because emissions from Texas coal units without scrubbers were lower in 2009 and 2010 than in previous years; for example, Luminant's Monticello units emitted 45 percent more SO2 annually between 2003 and 2008 than they did in 2010.
• Compliance was feasible because 30 of the 48 Texas electric generating coal units had already installed the necessary control equipment by 2011, meaning they only needed to activate the scrubbers to meet the new SO2 limits.
• The compliance deadline for Texas emitters was not January 2012, as claimed by some critics, but rather March 2013 to fully comply.
• EPA estimates suggest that stricter pollution limits under the rule would benefit Texas communities by reducing annual cases of premature death by 13,000-34,000, aggravated asthma by 400,000, and missed work days by 1.8 million.

APA

Johnson, M., & Cross, J.-M. (2013). Should Texas Be Included in the Cross-State Air Pollution Rule? Environmental and Energy Study Institute. https://www.eesi.org/files/IssueBrief_Texas_CSAPR_Updated_120913.pdf

Chicago

Johnson, Matthew, and John-Michael Cross. Should Texas Be Included in the Cross-State Air Pollution Rule? Environmental and Energy Study Institute, 2013. https://www.eesi.org/files/IssueBrief_Texas_CSAPR_Updated_120913.pdf.

Wikipedia

{{cite report |last1=Johnson |first1=Matthew |last2=Cross |first2=John-Michael |title=Should Texas Be Included in the Cross-State Air Pollution Rule? |publisher=Environmental and Energy Study Institute |date=December 2013 |url=https://www.eesi.org/files/IssueBrief_Texas_CSAPR_Updated_120913.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{johnson2013should, author = {Johnson, Matthew and Cross, John-Michael}, title = {{Should Texas Be Included in the Cross-State Air Pollution Rule?}}, institution = {Environmental and Energy Study Institute}, year = {2013}, month = dec, url = {https://www.eesi.org/files/IssueBrief_Texas_CSAPR_Updated_120913.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }