CAIR
vs
BART
in
Texas
SO2
Emissions
(
thousand
tons)
2000­
2003
Ave
2015
Texas
IPM
SO2
emissions
without
CAIR
5552
4183
Texas
IPM
SO2
emissions
with
CAIR
N/
A
3523
Texas
IPM
SO2
emissions
achievable
with
BART1
N/
A
175­
222
1
Net
85%
reduction
applied
to
all
coal
plants
in
Texas
that
began
commercial
operation
between
1971
and
1980
(
assumes
construction
took
at
least
3
years
such
that
construction
would
have
commenced
in
1977
or
earlier).
2
CAIR
2001
emissions
inventory
estimate
is
546,000
tons
from
"
IPM"
sources
3
EPA
projections
from
CAIR
Emissions
Inventory
Technical
Support
Document,
March
2005
Strict
application
of
BART
could
yield
much
greater
SO2
reductions
than
CAIR
and
other
preexisting
programs
(
alternative
baseline
1:
average
emissions
during
2000­
2003)
 
CAIR
and
other
preexisting
programs
produce
203,000
tons
of
SO2
reductions
by
2015,
a
37%
reduction
compared
to
2000­
2003
average
emissions
 
We
estimate
BART
and
other
preexisting
programs
could
reduce
SO2
emissions
by
342,000
tons
compared
to
2000­
2003
levels;
two­
thirds
more
than
would
be
achieved
by
CAIR
and
other
preexisting
programs
 
The
CAIR
scenario
predicts
a
controlled
SO2
emissions
rate
at
all
units
of
0.46
lb/
mmBtu);
the
BART
scenario
predicts
a
controlled
SO2
emissions
at
BART
units
of
0.13
lb/
mmBtu)
1
 
Alternatively,
assuming
all
BART
units
achieve
0.15
lb/
mmBtu,
BART
would
reduce
SO2
emissions
by
333,000
tons
compared
to
2000­
2003
levels.

Strict
application
of
BART
could
yield
much
greater
SO2
reductions
than
CAIR
alone
(
alternative
baseline
2:
EPA's
estimate
of
2015
Texas
emissions
without
CAIR)
 
CAIR
alone
produces
66,000
tons
of
SO2
reductions
by
2015
(
16%
of
2015
base
IPM
emissions)
 
Assuming
80%
reductions
from
projected
base
2015
levels
due
to
BART
control
requirements,
we
estimate
BART
could
reduce
SO2
emissions
by
244,000
tons;
nearly
4
times
more
than
would
be
achieved
by
CAIR
alone
Key
data
on
TX
coal
power
plants
 
21
units
that
began
operating
1980
or
earlier
(
which
we
estimate
would
be
BART
eligible);
average
SO2
rate
2000­
2003
=
0.85
lb/
mmBtu
 
15
units
began
operation
after
1980;
average
SO2
rate
2000­
2003
=
0.50
lb/
mmBtu
 
73%
of
TX
SO2
emissions
come
from
units
that
began
operating
1980
or
earlier
1
The
average
rate
for
all
TX
units
assuming
only
the
BART
units
are
controlled
at
85%
(
with
no
additional
reductions
being
made
at
other
units)
would
be
0.28
lb/
mmBtu
 
still
lower
than
accomplished
by
CAIR
