PM2.5 and NAAQS Update | Emissions Watch Blog

Published February 15th, 2023 | Tom Bausemer | Blog Postemissions-watch

EPA Proposed rule on NAAQS for Particulate Matter 2.5

On January 6, 2023, the U.S. Environmental Protection Agency (EPA) issued a proposed rule to strengthen the primary (health-based) annual National Ambient Air Quality Standards (NAAQS) for fine particle pollution, or soot (PM2.5).

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Specifically, the EPA is proposing to revise the primary annual standard from 12.0 µg/m3 to a value within the range of 9.0 and 10.0 µg/m3.  Since a lower PM2.5 NAAQS will require emission reductions across multiple sectors, there will likely be implications for some plant owners located in to be designated nonattainment areas.

Current PM NAAQS vs. Jan 2023 Proposed Revisions

Current PM NAAQS vs. Jan 2023 Proposed Revisions

Implications for power plant owners and developers

As outlined in ESAI’s Emissions WatchTM, when NAAQS are strengthened, there are several potential implications for plant owners and developers. For example, plant developers may face more rigorous permitting requirements when seeking to construct fossil fuel-fired plants located in areas that the EPA determines are not in attainment with the revised NAAQS. These more rigorous permitting requirements also apply to existing plants for which the owner is seeking modifications (i.e., uprates) that will lead to an increase in emissions.

The EPA will issue its final rule in Q3 2023. Following the issuance of this final rule, the EPA will issue nonattainment designations within two years. Then, eighteen months following the effective dates of the nonattainment designations, states must submit final nonattainment State Implementation Plans (SIPs) detailing their strategies to attain the NAAQS.

If the EPA approves all or part of a SIP, those control measures are enforceable in federal court. If a state does not submit an approvable plan or if the agency disapproves a plan, the EPA is required to develop a federal implementation plan (FIP). An example of a FIP to address previous PM2.5 NAAQS is the Cross State Air Pollution Rule.

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