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

The document argues that claims by Texas Governor Rick Perry and Luminant Generation Co. regarding the Cross-State Air Pollution Rule (CSAPR) are misleading. It contends that the rule does not jeopardize grid reliability, as new capacity additions would offset coal plant closures and many plants already possess the necessary scrubbers. The briefing further asserts that Texas was properly notified of its inclusion in the sulfur dioxide (SO2) program and that the compliance deadline is March 2013, not January 2012. It concludes that the rule is necessary for public health, estimating that by 2014 it would reduce premature deaths by 13,000-34,000.

• The Electric Reliability Council of Texas (ERCOT) claimed the CSAPR could cause blackouts and a capacity reduction of 1,200-6,000 megawatts, but the briefing notes ERCOT provided no unit-specific information to support this estimate.
• Luminant Generation Co. announced plans to close a lignite coal mine and idle two coal-fired units, potentially costing 500 jobs, but the EPA offered technical adjustments to provide "thousands of additional tons of pollution allowances" to avoid these closures.
• The EPA's decision to include Texas in the SO2 program was based on projections that Texas emissions would exceed the 0.15µ.m3 threshold for annual PM 2.5 in 2012, and stakeholders were asked for comment on this in the 2010 Proposed Rule.
• The briefing disputes the claim that 2010 emissions data should be the basis for exclusion, noting that emissions from units without scrubbers were lower in 2010 than the 2003-2008 average; for example, Monticello units emitted 39,032 tons in 2010 compared to an average of 56,673 tons per year from 2003-2008.
• Contrary to claims of an impossibly short deadline, Texas emitters have until March 2013 to fully comply, with the end of 2012 being the deadline to install equipment or change operations.
• Compliance is feasible because 30 of the 48 Texas electric generating coal units already have the necessary capital expense of control equipment installed and only need to operate the scrubbers.
• EPA estimates indicate that by 2014, stricter pollution limits would result in 1.8 million fewer missed work days, 400,000 fewer cases of aggravated asthma, and 13,000-34,000 fewer premature deaths.

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} }