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

This briefing examines the dispute over the EPA's Cross-State Air Pollution Rule (CSAPR) in Texas. It counters claims from state officials and Luminant Generation Co. that the rule would cause blackouts and job losses, arguing that many plants already have the necessary scrubbers installed and that compliance deadlines extend to March 2013. The document asserts that Texas's inclusion in the SO2 program is justified by historical emission averages and will lead to significant public health improvements by 2014.

• Texas officials and the company Luminant Generation Co. claimed the CSAPR would jeopardize electric grid reliability and cause job losses, with the Electric Reliability Council of Texas (ERCOT) estimating a capacity reduction of 1,200-6,000 megawatts (MW). However, the briefing notes ERCOT provided no unit-specific information to support this, and an Environmental Defense Fund analysis suggested new capacity additions would offset coal plant reductions.
• Luminant announced plans to close a lignite coal mine and idle two coal-fired units, potentially resulting in 500 job losses. The EPA responded by offering technical adjustments to provide Texas and Luminant with thousands of additional tons of pollution allowances to reduce required emissions reductions and avoid these closures.
• The briefing disputes claims that the CSAPR was 'sprung' on Texas, noting that the 2010 Proposed Rule specifically asked for comments on including Texas in the sulfur dioxide (SO2) program. Additionally, Texas had been included in the SO2 and annual NOx programs of the previous 2005 Clean Air Interstate Rule (CAIR).
• The briefing argues that 2010 emissions data is an inaccurate basis for excluding Texas from the SO2 program because emissions were lower that year than in previous periods. For example, Luminant's two Monticello units emitted 39,032 tons of SO2 in 2010, compared to a yearly average of 56,673 tons from 2003 through 2008.
• Contrary to claims that the compliance period was too short, Texas emitters have until March 2013 to fully comply. While the first compliance period began in January 2012, companies had until the end of 2012 to install equipment or change operations.
• Many Texas coal plants already possess the necessary emission control technology. 30 of the 48 Texas electric generating coal units have already made the capital expense of installing control equipment (scrubbers), which some operators leave off to reduce variable costs.
• The EPA estimates that stricter pollution limits under the CSAPR would provide significant public health benefits by 2014, including the reduction of 13,000-34,000 premature deaths, 400,000 cases of aggravated asthma, and 1.8 million missed work days.

APA

Johnson, M. (2011). Should Texas Be Included in the Cross‐State Air Pollution Rule? Environmental and Energy Study Institute. https://www.eesi.org/files/texas_csapr_brief_100311.pdf

Chicago

Johnson, Matthew. Should Texas Be Included in the Cross‐State Air Pollution Rule? Environmental and Energy Study Institute, 2011. https://www.eesi.org/files/texas_csapr_brief_100311.pdf.

Wikipedia

{{cite report |last1=Johnson |first1=Matthew |title=Should Texas Be Included in the Cross‐State Air Pollution Rule? |publisher=Environmental and Energy Study Institute |date=October 2011 |url=https://www.eesi.org/files/texas_csapr_brief_100311.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{johnson2011should, author = {Johnson, Matthew}, title = {{Should Texas Be Included in the Cross‐State Air Pollution Rule?}}, institution = {Environmental and Energy Study Institute}, year = {2011}, month = oct, url = {https://www.eesi.org/files/texas_csapr_brief_100311.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }