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Balancing power generation with air quality compliance

Balancing power generation with air quality compliance

For the electric power generation industry, 2023 has already come with numerous proposed air quality rules that could have significant impacts on electric generating utilities now and in the years to come. These regulatory updates add to the competing priorities of reliability, maintenance, and replacement of aging infrastructure and environmental, social, and corporate governance (ESG) goals, making the job of delivering clean and affordable power to rate payers more challenging. These wide-ranging updates are summarized below.

2023 proposed greenhouse gas standards

This spring, the EPA published their latest approach to regulating greenhouse gas (GHG) emissions from the fossil fuel-fired power generation industry. The proposed new standards would limit GHG from the electric power generation sector for the following:

  • Certain new natural gas-fired combustion turbines

  • Existing fossil fuel-fired electric generating units (EGUs)

  • Existing large baseload stationary combustion turbines

This is the third of the EPA’s attempts to regulate GHG from the power generation sector and, like the other attempts, it is likely to face litigation. In the meantime, it will be important for power generation facility operators to understand the proposed requirements as they are currently written in order to identify and vet compliance options ahead of time, understanding that some of the options may require significant investment. Read a more detailed summary of the proposed rulemaking.

Clean Air Act’s “Good Neighbor” requirements

The EPA also finalized its Good Neighbor Plan this spring, which has impacts for both power plants and industrial facilities. The plan requires 23 U.S. states to reduce pollution that interferes with downwind states meeting and maintaining the EPA’s health-based air quality standard for ground-level ozone (smog). The requirements include enforceable NOx (nitrogen oxides) emissions control requirements in industries that have significant impacts on downwind air quality and for which cost-effective pollution controls are possible, such as reciprocating internal combustion engines in the pipeline transportation of natural gas. The NOx emissions control requirements will take effect in 2026.

As is often the case with significant regulation in this industry, the Good Neighbor Plan and its administrative structure are currently encountering significant litigation and, in some areas, implementation delays. Check back here for future updates to requirements and implementation dates.

Proposed updates to the Mercury and Air Toxics Standards (MATS)

To reflect recent developments in control technologies and plant performance, the EPA proposes to strengthen the MATS for power plants. This would further limit the emission of hazardous air pollutant (HAP) metals by reducing the emission standard for filterable particulate matter by two-thirds.

Contact our team to learn more about our services, including Barr’s climate impact mitigation and carbon management services. Barr's integrated team of experienced engineers, scientists, and regulatory experts stand ready to help you better understand these regulatory compliance issues moving forward.

Plus, join us at two Air & Waste Management Association (A&WMA) conferences this month:

On September 12, Adam Driscoll, vice president, senior environmental engineer, will present on air quality regulatory updates for the electric power industry and PFAS multimedia regulatory developments. Kevin Solie, senior environmental engineer, will also present on the EPA’s Legacy CCR Rule. On September 26–27, Adam will again present on air quality regulatory updates for the electric power industry, as well as provide a comparative review of state-level actions on environmental justice issues.

About the author

Adam Driscoll, vice president, senior environmental engineer, has more than 15 years of experience with environmental permitting and compliance, primarily involving petroleum refining, mining, power generation, and manufacturing. He spent three of those years working at a global manufacturing corporation, where he acquired critical experience with environmental permitting, led cross-functional EHS audits, and negotiated issues of noncompliance with regulatory agencies. Adam’s areas of expertise are complex air-quality permitting and environmental auditing and compliance.


Adam Driscoll, Vice President, Senior Environmental Engineer
Adam Driscoll
Vice President, Senior Environmental Engineer
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