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The Cross‐State Air Pollution Rule (CSAPR)

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The Cross‐State Air Pollution Rule was proposed in 2011 as a replacement for CAIR, but was in turn vacated by the D.C. Circuit Court of Appeals in 2012 after judicial review. The U.S. Supreme Court reversed the decision of the Court of Appeals in April of 2014 and the stay was lifted in October 2014. Phase I of CSPAR began on 1 January 2015, but an update to the rule (the CSAPR Update) was finalized in September 2016.

CSAPR differs from CAIR in its level of stringency and trading restrictions. In CSPAR, allowance allocations are reduced from those in CAIR, and interstate trading is restricted. Despite the legal issues and shifting bases of the NOx control programs, using cap‐and‐trade policies as a tool, they have been successful in decreasing NOx emissions below the original target levels (Shouse 2018).

Ultimately, this history is not important to the CEM engineer, particularly since CEM requirements, based on Part 75, were not affected by the judicial issues. In the end, with the addition of control equipment and the increasing availability of natural gas over the decade, the electric utilities were able to meet NOx emission limitations.

Continuous Emission Monitoring

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