Final Examination ReadingsWRC 1023: Environmental Issues (Ratcliffe)

Spring 2012

1) Please write your name on this packet of readings and bring the readings to the finalexam. You may underline, highlight and annotate the readings, but you may not bringthesis statements, outlines, or drafts in any form to the final.

2) As you read, be aware that you will be writing a persuasive essay, not an informativeessay. Be sure to know all sides of the issue so you can respond to the opposition.

3) You may bring a dictionary (in print form, not electronic form) to the final.

4) Please use MLA in-text citation format on the final, and verify that the MLA WorksCited page has printed out along with this packet.

5) No class time will be allotted for discussion of the readings. You may, if you wish,discuss the readings outside of class with your classmates; however, you may not discussthem with your instructor.

6) If you haven't done so already, tum in a blank test book to your instructor (or two testbooks if you think you may need more than one). You will write your final essay in thistest book. Your instructor will return it to you on the day of the final.

7) Your final exam will be in the same room as your class has been held.

8) Be sure to confirm the date and time of your final. You can check your syllabus or theASAP home page, ask your instructor, or check the postings outside the Writing Programoffice (NP 1.1l8).

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Texas figfrts EPA over clean-air rule - San Antonio Express-News h@://www.mysanantonio.com/living_green_sa/articlelTeyas-figlrts-...

Texas fights EPA over clean-air ruleBy lvlaffitel/v TresaugueUpdated 12:03 a.m., Thursday, April 12,2012

HOUSTON - In a federal appeals court Friday, Texas will take aim at acontroversial rule that requires aging power plants to sharply reduce

emissions that cause smog and soot in neighboring states.

The latest round in the state's fight with the Environmental Protection

Agency will be heanl by the U.S. Court of Appeals for the District ofColumbia, often considered the nation's most influential afterthe Supreme

Court.

Industry groups and 14 states led by Texas are challenging the legality ofthe Cross-State Air Pollution Rule, which

imposes caps on nitrogen oxide and sulfur dioxide from coal-fired power plants in Eastern states. Texas, for one, fearssome utilities will shutter plants to comply with the rule, threatening the state's ability to "keep the lights on."

The EPA says the nrle is necessary to reduce lung-damaging pollution that causes thousands of prematurt deaths andrespiratory illnesses each year around the power plants and in downwind states.

"This is a classic instance of why air pollution cleanup cannot be left solely to the states," said Frank O'Donnell, head of

the environmental group Clean AirWatch.

The oral arguments come nearly four months after a three-judge panel put the mle on hold while tlle federal appeals

court considers its legality.

The drallengers, which include Energy Future Holdings, formerly TXU, say the EPA overstepped its authority andprovided too little time to comply. Energy Future Holdings-owned Luminant - Texas'largest powerprovider - has said

the rule will force it to idle units at one of its coal-fired plants and three nearby mines.

The rule creates a 27-state trading pnogram to reduce lung-damaging emissions. To comply with the regulation, power

companies may purchase credits or install smokestack scrubberc and other new pollution controls.

The EPA issued the regulation last year in response to the federal appeals court, which told the regulator to fix the"fundamental flaws" of an earlierversion bythe Bush administration.

The reworked rule remains flawed, the Texas Commission on Environmental OualiVs chief engineertold state

lawmakers Wednesday.

At a Senate committee hearing, TCEQ's Susana Hildebrand said the EPA still exceeds its authority with the trading

system to reduce emissions because the federal Clean Air Act gives the states primary responsibility for tackling airquality problems.

"The EPA usurped our role, and that is why we are asking the courts to look at it," she said.

Texas officials and industry representatives raised concerns about electric reliability under the rule after the state'spower grid was pushed to the brink last year.

"We do not have a megawatt to spare," said Michael Nasi, an attorney for Balanced Energy for Texas, an industry group

that indudes Luminant. "We should fight the EPA over good science even if we did, but we do not."

matth ew.tr e saugue @ ehr on,com

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07 / 07 / 20 1I : EPA Reduces Smokestack Pollution Protectins American.. http://yosemite.epa.gov/opa,/admpress.ns f/ 6424acl caa800aab85257...

359003f5337/cedd944b946fdc5f852578c60055e8 1 8! Open Document

Newsroom

News Releases - Air

EPA Reduces Smokestack Pollution, Protecting Americansn Health from

Soot and Smog/Clean Air Act protections will cut dangerous pollutionin communities that are hom e to 240 million Americans

Release Date: 07 107 120 1 1Contact lnformation: Enesta Jones, jones.enesta@epa.gov, 202-5U-7873,202-564-4355

WASHINGTON - Building on the Obann Administration's strong record of protecting the public's health throughcomrnon-sense clean air standards - including proposed standards to reduce emissions of mercury and other air toxics, aswell as air quality standards for sulfur dioxide and nitrogen dioxide - the U.S. Environnental Protection Agency (EPA) todayfinalized additional Clean Air Act protections that will slash hundreds of thousands of tons of smokestack emissions thattravel long distances through the air leading to soot and smog, threatening the health of hundreds of millions of Americansliving downwind. The Cross-State Air Pollution Rule will protect communities that are home to 240 million Americans fromsmog and soot pollution, preventing up to 34,000 premature deaths, 15,000 nonfatal heart attacks, 19,000 cases of acutebronchitis,400,000 cases of aggravated asthma, and 1.8 million sick days a year beginningin20ft -achieving up to $280billion in annual health benefits. Twenty seven states in the eastern half of the country will work with power plants to cut airpollution under the rule, which leverages widely available, proven and cost-effective control technologies. Ensuring flexibilityEPAwill work with states to help develop the most appropriate path fonrtrard to deliver significant reductions in harrnfulemissions while minimizing costs for utilities and consumers.

"No community should have to bear the burden of another community's polluters, or be powerless to prevent air pollution tdleads to asthma, heart attacks and other harrnful illnesses. These Clean Air Act safeguards will help protect the health ofmillions of Americans and save lives by preventing smog and soot pollution from traveling hundreds of miles andcontaminating the air they breathe," said EPAAdministrator Lisa P. Jackson. "By maximizing flexibility and leveraginO existinytechnology, the Cross-State Air Pollution Rule will help ensure that American families aren't suffering the consequences ofpollution generated far from home, while allowing states to decide how best to decrease dangerous air pollution in the mostcost effective way.'

Carried long distances across the country by wind and weather, power plant emissions of sulfur dioxide (SOr) and nitrogenoxide (NOr) continually travel across state lines. As the pollution is transported, it reacts in the atmosphere and contributesto harrnful levels of smog (ground-level ozone) and soot (fine particles), which are scientifically linked to widespread illnessesand premature deaths and prevent many cities and communities from enjoying healthy air quality.

The rule will improve air quality by cutting SO, and NO, emissions that contribute to pollution problems in other states. By2014, the rule and other state and EPA actions will reduce SO, emissions by 73 percent from 2005 levels. NO, emissionswill drop by 54 percent. Following the Clean Air Act's "Good Neighbor" mandate to limit interstate air pollution, the rule willhelp states that are struggling to protect air quality from pollution emitted outside their borders, and it uses an approach thatcan be applied in the future to help areas continue to meet and maintain air quality health standards.

The Cross-State Air Pollution Rule replaces and strengthens the 2005 Clean Air Interstate Rule (CAIR), which the U.S. Cour*of Appeals for the D.C. Circuit ordered EPAto revise in 2008. The court allowed CAIR to remain in place temporarily whileEPAworked to finalize today's replacement rule.

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07 / 07 I 20 ll : EPA Reduces Smokestack Polhf i on, Protecting American... http://yosemite.epa.gov/opa./adnpress.ns fl 6424ac1caa800aab85257...

The rule will protect over 240 million Americans living in the eastern half of the country, resulting in up to $280 billion in

annual benefits. The benefits far outweigh the $800 million projected to be spent annually on this rule in 2014 and the

roughly $1.6 billion per year in capital investments already underway as a result of CAIR- EPA expects pollution reductionst,

occur quickly without large expenditures by the power industry. Many power plants covered by the rule have already made

substantial investments in clean air technologies to reduce SO, and NO" emissions. The rule will level the playing field for

power plants that are already controlling these emissions by requiring more facilities to do the same. ln the states where

investments in control technology are required, health and environmental benefits will be substantial.

The rule will also help improve visibility in state and national parks while better protecting sensitive ecosystems, including

Appalachian streams, Adirondack lakes, estuaries, coastal waters, and forests. In a supplernental rulemaking based on

further review and analysis of air quality information, EPA is also proposing to require sources in lowa, Kansas, Michigan,

Missouri, Oklahoma, and \Msconsin to reduce NO*emissions during the summertime ozone season. The proposal would

increase the total number of states covered by the rule from 27 to 28. Five of these six states are covered for other pollutant9

under the rule. The proposal is open for public review and comment for 45 days after publication in the Federal Register.

More information : http.//www. epa. gov/crossstateru le/

Receive our News Releases Automatically by Email

Last updated on Thursday, April 26, 2Q12

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Basic Inforrnation lAir Transport IUS EPA

Cross-State Air Pollution Rule (CSAPR)

Basic InformationThe United States Court of Appeals for the D.C. Circuil issued its rulinq to stay he CSAPR pendingjudicial review The courts decision is not a decision on the nErits of the rule. EPA is ensuring thetansition back to the Clean Air lnterstate Rule (CAIR) occurs as searnlessly as possible. Please see ourBulletins page for updates on CSAPR and the continuing implernentation of CAIR.

On July 6,2011, the US Environnental Protection Agency (EPA) finalized a rule that protects thehealth of millions of Americans by helping states reduce air pollution and attain the 1 997 ozone and fine particle and 2006 fineparticle National Ambient Air Quality Standards (NMQS). This rule, known as the Cross-State Air Pollution Rule (CSAPR), requiresstates to significantly improve air quality by reducing power plant emissions that cross state lines and contribute to ozone and fineparticle pollution in other states. In a separate, but related, regulatory action, EPAfinalized a supplernental rulemaking on December'15,201'l to require five states - lowa, Michigan, Missouri, Oklahoma, and Wisconsin - to make sumrnertime NOx reductions underthe CSAPR ozone season control program. CSAPR requires a total of 28 states to reduce annual SO, emissions, annual NO*

emissions and/or ozone season NO* emissions to assist in attaining clean air standards. To speed implernentation, EPA is adoptingfederal implementation plans, or FlPs, for each of the states covered by this rule. EPA encourages States to replace these FlPs with

State fmplementation Plans, or SlPs, starting as early as 2013. On February 7 , 2012, EPA issued two sets of minor adiustnBnts to

the Cross-State Air Pollution Rule (CSAPR).

EPA, states, tribes and local governments all play important roles in reaching clean air goals. With this rule, the Agency is renewingits commitrnent to implement the Clean Air Act's "good neighbor" provision, which requires states to address the problem of interstate

kansport of air pollution. At the sarne tirne, states, tribes, and local agencies continue to work on local pollution control measures.

Cross-State Air Pollution Rule States

The CSAPR requires 23 states to reduce Click on the map to see a larger image I Mew this map as a table

annual SO, and NOx emissions to help

downwind areas attain the 24-Hour and/or . t

Annual PM2.5 NMQS. Twenty-five states are I

required to reduce ozone season NO"

emissions to help downwind areas attain the't997 8-Hour Ozone NMQS. The rule fully

addresses all upwind states' transport

obligations under the 1997 annual PM2.5 and2006 24-hour PM2.5 standards. For 14 states,it will also fully address upwind state transportobligations underthe 1997 ozone NAAQS. Forthe rest ofthe upwind states covered by theCSAPR ozone program, the rule makes asubstantial "down payment" on emissionreductions while EPA continues to evaluatewhat, if any, additional emission reductionsmight be needed.

The final CSnpR divides the states required toreduce SO, into two groups. Both groups must

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reduce their SO, emissions beginning in2O12. Group 1 states must make additional reductions in SO, emissions by 2014 in order toeliminate their significant contribution to air quality problems in downwind areas.

Annual Public Health and Environmental Benefits

Click on the-Dap",la,-s-e-e,a,larcerLnocqe I Mew this data as an Excel Spreadsheet (23 Kb)

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Basic Inforrnation I Air Transport IUS EPA

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The Cross-State Air Pollution Rule will help

avoid tens of thousands of premature deaths

and i l lnesses, achieving bi l l ions of dol lars in

public health benefits. By 2014, the required

emissions reductions wil l annuallv avoid:

13,000 to 34,000 premature deaths

15,000 nonfatal heart attacks

19,000 hospital and emergency room

visits

1.8 mil l ion lost work days or school

absences

400,000 aggravated asthma attacks

Pollution reductions will also lead to

improvernents in visibility in national and

state parks, and increased protection for

sensitive ecosystems including Adirondack

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lakes and Appalachian streams, coastal waters and estuaries, and forests.

Air Quality lmprovements

The Cross-State Air Pollution Rule will improve air quality in thousands of counties throughout the

eastern, central, and southern U.S. - counties that are home to over 75oh of the U.S. population.

State, local and federal actions have already improved air quality so that many counties meet the

National Ambient Air Quality Standards for ozone and fine particle pollution. Many areas have

already been brought into attainrnent with these standards. This rule will help bring several more

areas into attainment and help many more areas continue to meet the level of the standards.

Most of the counties with monitors in the region covered by the CSAPR are projected to rneet the 1997 and 2006 ozone and fine

particle standards in 2014. Mew a PDF: lmpacts of the CSAPR on Counties with Monitors Proiected to have Ozone and/or Fine

Particle Air Qualitv Problems. (PDF 8pp 143 kb)

Emission Reductions

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Emission reductions will take effect quickly, starting

January 1 , 2012 for SO, and annual NO" reductions

and May 1,2012 for ozone season NO* reductions.

Significant additional SO, emission reductions in

Group 1 states will be required in 2014. Compared to

2005, EPAestimates that by 20'14 this rule and other

federal rules will lower power plant annual emissions

in the CSAPR region by:

6.4 million tons per Vear of SO, - a 73 percent

reduction

1 .4 million tons per year of NO" - a 54 percent

reduction

Including 340,000 tons per year of NO" during

the ozone season

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kAir Quality lmprovements and Emission Reductions at a Low Cost

The final rule yields $120 to $280 billion in annual health and welfare benefits in 2014, which far outweigh the estimated annual

costs of CSAPR of $800 million in 2014, along with the roughly $ 1.6 billion per year in capital investrnents already under way as a

result of CAIR.

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Basic Information I Air Tiansport IUS EPA h@ : //www. epa. gov/airf ansport/basic.htnl

The high benefits and low costs of the rule are achieved through implementing an air qualig-assured trading program for states in

the CSAPR region. EPAsets a pollution limit (or budget) for each of the states covered by this rule. The rule allows sources in each

state to rneet those budgets in any way they see fit, including unlimited trading of emissions allowances between power plants within

the san€ state. Interstate trading is also permitted. However, the rule includes provisions to assure that each state will rneet itspollution control obligations. This structure reduces the cost of complying with the rule while ensuring that each state eliminates the

SO, and NO^ emissions that significantly contribute to downwind nonattainnpnt or interfere with maintenance of the 1997 and 2006

NAAOS,

The Cross-State Air Pollution Rule (CSAPR) and the Clean Air lnterstate Rule (CAIR)

This rule replaces a 2005 rule known as the Clean Air Interstate Rule (CAIR). A December 2008 court decision kept the requirenentsof CAIR in place temporarily, but directed EPAto issue a new rule to implernent the Clean Air Act requirements concerning thetransport of air pollution across state boundaries. This Cross-State Air Pollution Rule is designed to implernent these Clean Air Actrequirements and respond to the courts concerns. The CSAPR takes effect January 1,2012; CAIR will be implernented through the2011 compliance periods, and then replaced by the CSAPR.

By 2014, power plants in states comrnon to both the Cross-State Air Pollution Rule and CAIR will achieve annual SO, emissionsaround 1.8 million tons lower and annual NO" emissions around 76,000 tons lower than what would have been achieved at that tirneunder CAIR.

Last updated on Tuesday, February 07, 2012

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Large Map ofEffected States lAir Transport IUS EPA

$m\iffi*li,''*.,,-,."Air Transport Rule

Large Map of Transport Rule Statesthe United States Court of Appeals for the D.C. Circuit issued its ruling to stay the CSAPR pending judicial revia/v The courts decisionis not a decision on the merits of fre rule. EPA is ensuring the transition back to the Clean Air Interstate Rub (CAIR) occurs asseaniessly as possible. Please see our Bulletins page for updates on CSAPR and the continuing implenentation 0f CAIR.

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l-__l $ates controlled for both flne particles (annual SO2 and NOx) and ozone (ozone season NOx) (20 States)

l----l State. controlled for fine particles only (annual SO2 and Nox) (3 States)

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Sr"t"r controlled for ozone only (ozone season NOx) (5 States)

l--_l States not "overed

by the Cross-State Air Pollution Rule

View this map as a table

This rnap includes states covered in the supplemental notice of proposed rulemaking

Last updated on Thursday, January 19,2012

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I^arge Map of Health and Environmental benefits I Air Transport I US EPA http : //www.epa. gov/airfr ansport/benefi cmap.htnl

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$ffi iii::"':::i,,'.....',^Cross-State Air Pollution Rule (CSAPR)

Large Map of Public Health and Environmental Benefitslhe United States Court ol Appeals for the D.C. Circuit issued its rulinq to stay the CSAPR pending judicial reMaru. The courts decisionis not a decision on the rnerits of the rule. EPA is ensuring the transition back to the Clean Air Interstate Rule (CAIR) occurs asseanlessly as possible. Please see our Bulletins page for updates on CSAPR and the continuing inplenentatjon of CAIR

Cross-State Air Pollution Rule (CSAPR) RlA, Table 1-1 and -2; mortality impacts estimated using Laden et al. (2006), Levy et al(2006), Pope et al. (2002) and Bell et al. (2004); monetized benefits discounted at 3%

View the information on this map as an Excel Spreadsheet (23 Kb)

Last updated on Thursday, January 19,2012

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Testimony of David Campbell, Luminant CEO

Before House State Affairs Committee

Thursday, September 22, 201l

Good morning. My name is David Campbell, and I am the CEO of Luminant. I amhonored to be here representing Luminant's 4,400 employees in Texas. We are allproud of our long history of providing safe, reliable, and affordable electric generationto Texas.

At the outset, I'd like to emphasize that we support continued efforts to improve airquality across the state and nation. We've put our money and actions behind efforts todo that.

. Since 2005, Luminant has achieved a21, percent reduction in SOz emissioru and a9olo decrease in NOx emissions. At the same time, we've invested billions in newplants, increasing our generation by 16 percent. We also added nearly 700 newjobs, all in Texas.

r And the Texas power sector's emissions rates are significantly better than theU.S. average - 2[percent better for SOz, and 42 percent better for NO,,.

I am here to explain the requirements of the EPA'S Cross-State Air Pollution Rule,known as CSAPR. Unless there are changes made to the rule, CSAPR's drasticrequirements and unrealistic timeline will force us to take steps that will result in job

losses and reduced generation. Specifically, we plan to

. Cease operations at three lignite mines in East Texas; ande Idle two electric generating units in East Texas, called Monticello Units 7 and2.

Those actions will result in the elimination of between 400 and 450 full-time jobs byearly 2012, and the eventual elimination of more than 500 jobs.

. Our employees are dedicated, capable, and good people. Many have worked forthe company for decades. And these jobs are typically among the highest payingand most sought-after, stable jobs in their communities.

o During these difficult economic times, job opportunities for these workers maybe extremely limited, particularly in the rural communities in which our facilitiesare located.

r Unfortunately, the burden of CSAPR's aggressive timeline and mandates will fall

on the same employees who worked tirelessly through the hot sufiuner to keepthe lights on.

And that is why we are working so hard to get this rule changed. We are fighting topreserve hundreds of jobs for our employees, to keep open facilities that are importantto the local communities, and to preserve reliability of the Texas electric system.

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We are not alone in our concern about this rule, and its effects on Texas. Many electedofficials from both sides of the aisle, community leaders, and consumer advocates havetaken action to express their serious concems. In these partisan times, this is one topicthat has generated widespread agreement among Texas leaders.

We are working hard on two {ronts to get this rule changed - we are continuing ourdiscussions with EPA and we're also seeking judicial action to stay the rule. No onewould be happier than Luminant if changes are made to CSAPR that allow us to keepour mines open, our plants online, and our people employed. Itwould be a great day ifI could appear before this panel,later this fall, and describe exact$ that outcome. Wewill work around the clock and keep our door open to EPA to continue our efforts tomake that happen.

Today, I'11 describe three aspects of the CSAPR rule and its effect on Texas:

o First, the magnitude of the challenge that we face.. Second, some of the fundamental flaws in the process that created the CSAPR

mandates for Texas.r Third, the unfortunate impacts that the rule as it currently stands will have on

jobs and reliability.

First, as finalized by the EPA, this rule imposes severe limits on Texas power plants,and requires compliance in an unprecedented timeframe of less than six months.

r CSAPR requires that Texas reduce its SOz emissions by 47 percent. Luminantfaces a 64 percent reduction.

o CSAPR further requires that Texas reduce its NOx emissions by 8 percent.Luminant faces a 22 percent reduction

o Some, including the EPA, would like to imply that these reductions would besimple to achieve. The reality is that there are no easy paths to reducingemissions by 64 percent this fast. New environmental control equipment takesyears to put in place. Reducing emissions this much, this soon, will requiresignificant operational changes. There is no way around it.

r Despite what the EPA has been saying about 2013, the rule takes effect onjanuary 1,2012. The limits apply to actual emissions in the 2012calendar year.March 1,2013 is the date that power generators will have to report their 2012emissions for the annual NOx and SOz programs * it's like April 15 for last year'staxes.

. The installation of controls cannot be done by January 2012,because the timelineto design, permit, construct and install new emissions control equipment istypically 3 or more years. We can't be sure what allowances will be available in atrading market * and the CSAPR places significant restrictions on trading as acompliance tool. In this context, we must take immediate steps to comply during

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calendar year 2072 and meet that reporting deadline. If the 2012 emissions arenot immediately and drastically reduced, and we cannot buy enough credits inthe trading market, then the rule imposes massive penalties.

o There are those who will also say that we should have known this was coming.My answer is simple. EPA's own draft rule, issued in 2010, did not include Texasin the annual SOz and NOx programs. Texas was not included because EPA'sown modeling did not support it. A year later, EPA suddenly switched course.It decided not only to include Texas, but to require massive reductions in lessthan six months. That is the opposite of a stable and predictable regulatoryframework

My second point summarizes the fundamental flaws in the process and inputs thatwere used to develop CSAPR.

o The development of CSAPR involved serious process flaws. Since Texas was notin the draft rule, this meant there was no meaningful opportunity for notice andcomment on annual reduction requirements. In fact, never before has a statebeen included in a major EPA rule when no budget for the state was included forcomment in the draft rule.

o There are also serious questions about whether Texas should be in the annualprogram, and if so, whether the required reductions are in any proportion to themodeled downwind impacts. There were good reasons why EPA concluded inthe draft rule that Texas had no need to be in CSAPR's annual programs.

o Finally, there are fundamental data errors as well. The easiest example to pointout is that EPA's modeling asstrnes the use of three scrubbers in Texas that donot, in fact, exist. But that's just one example of many. This is what happenswhen you don't go through a notice and comment process.

o We've started a dialogue with EPA about these flaws and errors. We're pleasedthat we've made some initial progress, and we greatly appreciate theengagement of EPA leadership on the topic. As of yet, there have been nochanges to CSAPR's requirements or deadline, though we certainly hope thosewill be forthcoming. We'll continue that dialogue with EPA and hope that it canlead to corrections, and changes, to the rule, allowing us to keep facilities openand all our people on the job.

o Ultimately, we will comply with the rule, as we comply with all rules that governour industry. We have no choice but to make plans to meet CSAPR's currentrequirements. We are obligated to notify ERCOT, employees, suppliers, andothers of those plans. If the rule is changed, as we hope, we'll be equallyforthcoming about how we can alter our implementation plan.

My third, and final, point relates to how we will achieve the CSAPR mandates.

In our evaluation process, we explored all options. These include switching fuelsources, reducing power generation, purchasing emissions allowances, installing newequipment, upgrading existing equipment, implementing new emission reduction

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technology such as dry sorbent injectiory and many other options.

The bottom line is that all these alternatives have significant near-term limitations,given CSAPR's imminent deadline.

o Installing additional emissions controls is not a solution. The minimumstandard timeline for permitting, constructing and installing new controls is 3 ormore years, and we were given less than 6 months.

o Purchasing additional emissions allowances is not a complete solution. In thenear term, there will be far more demand than there is supply for emissionscredits. Betting on a trading market is as risky as it sounds. Plus, by desigoCSAPR sets limits on the use of trading as a compliance option.

. Fuel switching is a solution that would result in increased job losses - simplyput, switching from lignite coal to PRB coal means the elimination of hundredsof Texas jobs. And switching to natural gas is not possible - we cannot runnatural gas in the existing facilities. Permitting and building new gas units willtake years.

r Increasing scrubber utilization is not a complete solution - existing scrubbersalone cannot achieve the required reductions. On this point, it's worth notingthat even the widely-cited Bernstein report, which assumes scrubber efficiencyIevels that can't be achieved with current equipment, still assumes extensive fuelswitching to comply with CSAPR. In other words, the Bernstein report assumesmajor job losses.

The compliance plan that we will implement includes investing close to $300 million bythe end of next year to help reduce emissions as much as we can in this short timeframe. Unfortunately, it won't be enough. Closing mines and idling plants are the laststeps that we want to take. But without changes to the rule and its timeline, they aresteps that we will have to take.

While Luminant supports continued efforts to improve air quality, we cannot supportCSAPR's timing, process, or methodology. \A/hile we are preparing to comply with therule as it stands, we are also pursuing administrative steps with EPA, and a legalchallenge, to protect our facilities and employees.

We have more incentive than anyone to figure out how to comply with this rule whilekeeping our plants open and our people at work. Unfortunately, such an option simplyisn't there, unless changes are made to the rule. We will work around the clock topursue changes to the rule, and we will keep our door open to EPA to continue ourefforts to make that happen.

I'd be huppy to take questions.

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EPA's Bad Science to Blame for State's Iatest Challense - Texas Co...

TEXAS COtrrr r9AlOirOX ENVIRONI IENTAL G IUAL IYY

htp : //www.tceq.texas. gov/agency/shaw- editorial

EPA's Bad Science to Blame for State's LatestChallengeAn editorial by Bryan W. Shaw, Ph.D., Chairman, Texas Commission on Environmental Quality, on Oct. 4,2()11.

The state of Texas is again being forced to take legal action against the federal EPA, this time to stop enforcemeut of the newCross-State Air Pollution Rule (CSAPR). EPA apologists continue to demonstrate a lack of basic understanding of the rule anda dangerous, misguided belief that CSAPR should be accepted without the scrutiny of law, science, and common sense.

When the EPA puts forward a regulation that is not based on facts, doesn't follow its own rules and will have significantadverse impacts to this state, Texas has the right and the obligation to its citizens to pursue legal remedies. Texas mustprotect Texans from the real, immediate harm this rule will inflict. Blame EPA's insistence on using bad science and flawedlegal arguments forTexas'need to stand up and challenge EPA's actions yet again.

Iet's be very clear about the facts. The last-minute inclusion of Texas in the sulfur dioxide portion of the rule is based onmodeling that says an Illinois monitor, located across the street from a steel mill, shows a theoretical reading that is slightlyabove attainment. Actual data from zoog forward shows that this monitor is meeting the federal air quality standards today.And eveu if the feds relied on their own computer simulated modeling predictions, that monitor would be iu attainment inzor4 without any reductions from CSAPR So does Texas'tenuous link to this monitor justifr the state's inclusion in CSAPR?No.

The EPA stridently insists the law doesn't go into effect until March zorg, and this gives companies plenty of time to comply.This is patently wrong, so let's clear the air on this misrepresentation as well. Fines, and even criminal penalties fornoncompliance, will be based on how plants operate starting January 2or2. March zor3 is merely the due date for thepaperwork that demonstrates compliance. And since installing equipment to achieve compliance can take years, companieswill have to depend on "credits" being available for purchase at a reasonable, predictable cost... an enormous gamble to take inthe real world.

The EPA continues to throw out theoretical numbers showing impressive health effects from these initiatives, but federallegislators are growing increasingly short-tempered over the EPA's refusal to provide the data and studies to back theseprojections.

And while the EPA and its defenders cast doubts that these rules will really cost jobs and impact the state's supply ofelectricity, both the PUC and ERCOT have testified repeatedly that the power grid will be negatively impacted by CSAPRLuminant was forced to make a business decision to comply with this rule, leading the company to announce that it will needto lay off 5oo employees and shut down two of its units. Other companies are facing similar business decisions and theirimpacts will be felt throughout Texas.

The State of Texas cannot ignore the flaws of this rule. It would be irresponsible to simply accept that there are Texans whowill lose air conditioning during the hottest hours of the hottest months next summer because an EPA computer model showsan air monitor in Illinois may exceed the standard.

While individuals can reach different conclusions based upon the same set of facts, defenders of the EPA should seriouslyconsider the consequences of blindly endorsing bad law just because it comes out of Washington, D.C.

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BET Statement on EPA's Cross State Air Pollution Rule I Balanced E... http://www.balancedenergdortexas.org/blog/bet-statement-on-epas-c...

Balanced Energv for Texas( http : //www. ba la nced e ne rqvfo rtexa s. o rq/)

BET Statement on EPA's Gross State Air pollution RuleFebruary 27, 2012

Balanced Energy for TexasStatement on EPAs Cross-State Air pollution Rule:

Reliability and the Texas Economy Put in Jeopardy by EPA's |lth Hour Decision to Force Texas to Carry EmissionReduction Burden for Other States

Balanced Enerqv for Texas

o Balaneed Energy for Texas is a statewide coalition of energy consumers, producers and providers, committed tosupporting policies that preserve and promote our state's leading role in energy and economic development. BalancedEnergy for Texas believes that energy is the backbone of Texas' economy and that economic prosperity is contingentupon the adoption of sensible policies that maximize the use of our state's abundant, diverse and affordable energyportfolio, specifically oil, natural gas and coal. This balanced portfolio, based on free market principles and a soundregulatory framework, is critical to Texas' continued profitability, competitiveness and economic strccess.

Cross-State Air Pollution Rule Overview

e On August 8,2011, EPA finalized the Cross-State Air Pollution Rule (CSAPR), setting emissions caps for NOx and/orSO2 in 27 states with the purpose of reducing impacts to downwind states' ability to comply with pM2 5 and ozonestandards.

o While Texas was only included for a limited, seasonal, NOx program in the proposed rule, the final rule requires Texasto comply with both the NOx and SO2 annual programs.

' The rule has a Januarv 1, 2012 compliance date, with21o/o of the 2012 nationwide SO2 emissions reductions to bemade in Texas. These limits require a 47Yo redudion in Texas SO2 emissions relative to 2010 actual emissions levels.

o The extremely abbreMated timeline for compliance will force some plants to derate or idle operations, as there is notsufficient time to install sufficient control technologies, switch to low-sulfur coals, or purchase affordable allowances.

EPA Incorrectlv Cites a Compliance Obliqation Date of March 1 . 2013

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BET Statemer$ on EPA's Cross State Air Pollution Rule I Balanced E... http://www.balancedenergdortexas.org/blog/bet-statement-on-epas-c...

o EPA Assistant Administrator Gina McCarthy testified recently that "although the [CSAPR] program starts in 2012,power plants'first compliance obligation is not until March 1, 2013," and the compliance is "quite feasible and can be

done to achieve the requirements by the time the first compliance period is required to be met which, for SO2, is

March of 2013." This completely mischaracterizes the situation. The March 1, 2013, date is simply the day that

facilities must submit their report summarizing the emissions reductions made during 2012.

. EPAs logic is akin to Congress instructing EPA to cnt its 2012 budget in half, but suggesting that there is no immediateproblem because EPA does not have to report back to Congress about those cuts until March 2013.

Job Losses Are Potentiallv Severe

o On September 12,2011, Luminant announced that CSAPR will force Luminant, by January 1, 2012, to idle Monticello

Units 1 and 2, cease use of Texas lignite at Monticello Unit 3, Big Brown Units 1 and 2, and cease mining lignite at the

Thermo, Winfield and Big Browry'Turlington mines.

r ldling Luminant's plants and mines will resuh in approximately 500 lost Luminant jobs.

. Going forward, job losses will rrot be limited to Luminant. Luminant was only the first, of what may be marry, that will

undergo similar cut-backs in workforce due to CSAPR.

. Jobs will not only be lost when plants are idled or permanently shut down. Jobs will also be lost when plants derate

due to CSAPR, as reduced power or.rtput means reduced demand for lignite, and ultimately, fewer individuals who can

be employed supplying that lignite.

r In addition to lost jobs, idling and derating plants and ceasing mining activity will result in the down-stream negative

economic effects of lost local tax contributions, lost indirect employment, and other lost economic activity.

. In addition to CSAPR caused idling and derating, due to the entire suite of EPA regulations, American Electric Power

on June 9,2011, announced the retirement of Welsh Unit 2 by December 31,2014, and City Public SeMce (CPS) on

June 20, 2011, announced the shutdown of the Deely Power Plant's two units by 2018.

Electric Reliabilitv lmpacts are lmminent and Could Be Devastatinq

r On September 1, 2011, the Electric Reliability Courcil of Texas (ERCOT) published a report concluding that CSAPR

will result in a 1,200 to 1,400 MW reduction in generation capacity at peak times and between a 3,000 MW to 6,000

MW reduction in nonpeak times. ERCOT found that "even in the best-case scenario," had the 1,200-1,400 MW

"redrrction been in place in 2011, ERCOT would have experienced rotating outages during days in August." ERCOT

also predicts that the off-peak reductions of 3,000 to 6,000 MW when coupled with the annual maintenance outages

and weather variability, place ERCOT at increasing risk of emergency events, including rotating outages of customer

load.

o CSAPR's impacts are in addition to 11,000 MW of additional retirements by 2016, which ERCOT anticipates willresult

from EPAs other major proposed regulations impacting power plants. Those 11,000 MW of redrctions would result in

a reserve margin of negative 2.3%, which would only fall lower with the addition of CSAPR reductions.

r Luminant's announced idling and derating of units by January 2O12 will result in 1,300 MW of lost generation - roughly

9 percent of Luminant's total production. This retirement alone falls directly into ERCOT's range of what would cause

rolling blackouts, and this does not include the numerous other Texas units which may derate or idle.

o In the longer term, AEP's retirement of Welsh Unit 2 will remove 528 MW of capacity from the grid by 2014, and CPS'

Deely Power Plants'932 MW of installed capacity will be retired by 2018.

Substantive lssues with EPAs Rule Finalization Process and Rule Content

o Unlike every other state impacted by this rule, EPA included Texas in the final rule's annual SO2 and NOx programs

wlthont notice or opportunity for comment.

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BET Statement on EPA's Cross State Air Pollution Rule I Balanced E.'. http://www.balancedenergfortexas.org/blog/bet-statement-on-epas-c. "

r The rule has a compliance window of only five months, which is absolutely unprecedented for a rule of this size and

scope. lt does nct allow adequate time for an emissions trading market to develop or for the finarning, permitting, and

constructing required to install additional emissions controls.

r EPA has bypassed the states' Clean Air Act secured rigfrts to propose their own State lmplementation Plans (SlPs)

and has proceeded directly to EPA implemented Federal lmplementation Plans (FlPs).

Texas is Being Forced to Solve an Alleqed Problem that Texas is not Causinq

r As the graphs below make clear, CSAPR will lrave a disproportionate impact on Texas, especially given how little

impact Texas is having on other CSAPR states.

. For example, despite the fact that Texas's SO2 emissions make up only 11 percent of the SO2 emissions for the

states covered by the rule, EPA is mandating that 25 percent of total required reductions under the rule be made in

Texas -much more than Texas's fair share.

Administrative and Leqal Challenqes

o Given the very short compliance window for this rule and resulting catastrophic reliability impacts and job losses, the

first priority is to obtain a stay of the rule either from the EPA directly through an administrative process or from the

D.C. Court of Appeals. During a stay, substantive issues regarding the rule can be addressed.

. Administrative petitions for Ree,onsideration filed with the EPA and suits filed in the D.C. Court of Appeals must be filed

within 60-days from the August 8, 2011 publication of the rule in the Federal Register (by October 7,2011).

o Luminant, Southwestern Public Service Company (Xcel), and San Miguel Electric Cooperative, Inc' have joined the

State of Texas in petitioning the EPA to reconsider and stay the rule. Several other such Petitions from across the

country are anticipated.

. Texas, Kansas, Luminant, and out of state power generating companies have already filed suit with the D.C. Court of

Appeals.

Texas's Share of Alleged Problem

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Texas' Share of the Mandated Solution

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Source: Rad./cdons arc the dtrercncas balt,F,en 2012 state budgets from Fedenl Registerryol 76, No. 152, ,€g€s /A2d aN .18262, and the actual 2O1O orn6sior?s tion?

EPAs Clean Nr Ma*ets Division, Data & Maps, Quick ReWfts

1 The chalbnges ot nr,eling fututa oteciliw demand arc disctrssed ln-depth in Ealanced Enery for Tens'Energy Weekly enfr'ded

Categories: Bloq (http://www.balancedenergvfortexas.ors/catesorvlbloq/l . Permalink(http:r/www.balancedenerqvfortexas.orq/blog/bot-statement-on-epas-cross-state-air-pollution-rule/) . No Gomments >(http://www.balancedenerqvfortexas.org/bloo/bet-statement-on-epas-cross-state-air-pollution-rule/#respond)

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Cross-State Air Polldion Rule enerry warnings rmfounded http://www.statesman.com/opinior/cross-state-air-pollution-rule-ene...

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Cross-State Air Pollution Rule energ:F warnings unfoundedJim Marston, Local Contributor

Published: 9:14 p.m. Friday, Oct. 7, 2011

Oscar season is months away, but the Texas Legislature and regulators are doing their best to canpaign for Best Picture.

A hearing before the Texas House State Affairs Conrnittee in Septenber played like a horror movie - a scary script about a federaltakeover of the Texas econonry, starring everybody's favorite bad guy, the Environrnental Protection Agency.

Jobs will be lost, they said. Blackouts will result. And the only way to stop this nightnare is to overturn laws designed to protect ourhealth and promote clean air.

Mind you, this is pure fantasy. Vrtually every rnajor utility in every state in the union - Exelon, PPL Generation, NRG - is workingto conply with these clean air laws without blackouts or layoffs. "NRG can comply through an integrated strategy," a companyspokesman said this week. 'We do not anticipate any plant closures nor layoffs."

The sarne is true for rnost utilities in Texas, including Dynegy.

In fact, these energy providers are worried about the inpact of delaying new clean air rules. Dynegy CEO Robert Flexon recentlysaid that "any efforts to delay or derail the Cross-State Air Pollution Rule would undermine the reasonable, investrnent-basedexpectations of Dynegy."

There are just two Texas utilities, Luminant and GenOn, fighting the new clean air laws, and an awful lot of politicians are piling on. lftheir dire warnings sound familiar, it's because we've seen this movie before, and we know how it ends.

ln 2006, Luminant was still called TXU, and its position was that Texas needed more coal plants. The state's largest grid operator,the Electric Reliability Council of Texas, jumped on board, warning of blackouts if TXU didn't get to build all 11 of the new coal plantsit wanted. Gov. Rick Perry signed an executive order, speeding up TXU's permit process so that Texans wouldn't suffer electricityshortages.

And then a funny thing happened. TXU was bought, and plans for eight of the 1'1 new plants were scrapped. You'd expect ERCOTand state officials to panic, right? What about all those blackouts that were coming? Well, no one panicked, and the blackouts nevercame.

In fact, just a few months after the TXU buyont, ERCOT said to Rep. Joe Barton, "ERCOT is confident that even without the eightnew coal plants previously announced by TXU, adequate reserye margins will be nret."

There was no crisis. The npvie flopped.

Yet here we are again.

This go-round, Luminant has spent nearly a decade fighting new clean air laws instead of planning for the future.

And now that the future has arrived, and as the EPAdeadline approaches, the company is turning up the volume, claiming thatconplying will require it to close its dirtiest plants and lay off 500 enployees. Never mind that other Texas utilities are able to conply.Never mind that these rules have been in the works for years - since George W. Bush was president. Never mind that EPA isrequired to take imrnediate action to protect human health and has already demonstrated its willingness to adjust the rule as betterinformation beconres available.

The truth is that the Texas power grid will be fine without the dirty plants that Luminant says it will close rather than clean up. There'splenty of new power to nEet the demand - in fact, energy providers are preparing to interconnect to the Texas grid four tirnes asmuch new generation as ERCOT will need through 2015.

But that's not as exciting to our elected officials and regulators. They are making dranntic speeches about how'\i/e can't let thishappen, sornething must be done," and issuing dire warnings about how following the law will cripple Texas.

Sarne movie. Sane tired plot. That approach might work for Hollywood sequels, but the people of Texas deserve better from theirelected officials, regulators and local enployers.

Marston is regional director of the Environmental Defense Fund.

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Cross-State Air Pollufion delay would help Texas workers h@ : //www. statesman. com/opinion/cross- state-air-pollution- delay-w...

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Cross-State Air Pollution delay would help Texas workersBecky Moeller, Local Contributor

Published: 9:14 p.m. Friday, Oct. 7, 2011

Working families in Texas want to fight industrial pollution. Working families need jobs. With the rlght policies, we have no doubt thatwe can achieve success in rneeting both goals.

Workers suffer on two fronts when industrial operations threaten our air and water. We live in communities that support industry, andwe work at the plants themselves. That is why we have consistently led the fight for clean and safe workplaces, leading to thefornntion of agencies such as the Occupational Safety and Health Administration, and why we support effective regulation ofindustry practices.

But workers in Texas are also threatened by a recession that has been tough to shake off, as well as outsourcing, downsilng andmovenent of jobs offshore. Simply put, working families face an era of economic insecurity, and we need to do everything to keepthe good jobs that we already have.

Against this backdrop, the schedule for the Cross-State Air Pollution Rule proposed by the Environnental Protection Agency ishasty. The rule, adopted in a way that unfairty minimired public conrnent, requires power generators in this state - most prominentlyLuminant - to rneet new requirenents for emission reductions by Jan. 1, 2012. Failure to comply would result in substantialpenalties and fines.

We have no problem with the nrandate to clean up the air. In fact, the unions of the Texas AFL-CIO have been working with Luminantto do just that for years, and we have nnde significant progress. The problem is that it is sinply impossible for Luminant to install theequipnent necessary to reduce sulfur dioxide emissions to the required levels by Jan. 1. That rneans if the rule is implemented, atleast 500 and most likely more than 1,000 jobs will vanish permanently" Luminant already has announced plans to close severalfacilities to comply with the rule.

What is frustrating is that if given the appropriate tinE to make the necessary changes, we can reach and exceed the targets theEPA has set. Luminant has committed to do so and has proved to be good to its word since taking over from fiU. lt makes nosense to sacrifice a critical portion of the economic backbone of this state to rneet a hastily imposed, artificial deadline.

The impact if Luminant closes two generating plants and idles three Texas coal mines would reach far beyond the economicdevastation in affected conununities. Texas would lose 1,300 rnegawatts of electricity on the heels of a brutal sumrer in whichdennnd for electricity reached historic levels. lt would be a mistake to sacrifice the reliability of our power supply to meet anunnecessary deadline.

State officials must play a rnore constructive role in this debate. Too often, Texas officials have turned a blind eye to issues of airand water quality, and the related issue of workplace safety, and now sorne have sought to turn this into an "us versus them"partisan political battle. Workers are not interested in such a spectacle. Texas should work in good faith with the company, the EPAand the workers involved toward a compromise that cleans the environnpnt without sacrificing economic opportunity.

Resolving the dispute over this rule won't end the issue. All of us have a role to play in creating jobs while working for a cleanerenvironrnent. Unions in Texas already have taken significant steps in that direction. The Texas AFL-CIO is a leader in the TexasBlueGreen Apollo Alliance, a diverse coalition of businesses, organized labor and community organizations working to catalyze aclean energy revolution that will put millions of Arnericans to work in a new generation of high-quality, green-collar jobs. This is ourlong-term future.

In the nreantine, we call on the EPAto recognize the dire consequences of an ill-considered tirnetable and to delay implenrentationof the rule.

With a reprieve, we should all corne together to forge a new energy future that effectively balances the economic and environrnentalneeds of our state.

Moeller is president of the Texas AFL-CIO.

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EPA Cross-State Air Polhfion rule adoption update - You Houston ... h@://www.yourhoustonnews.com/pasadena/opinion/epa-cross-state-...

EPA Cross-State Air Pollution rule adoption updateByKEil LEGLER

State Representative I Posted: Thursday, SeptenSer 22,20'11 11:38 am

In July, the Environmential Protection Agency (EPA) adopted a new rule that addresses cross-stiate air pollution. The new draconian rule replaces the EPA

Clean Air Interstate Rule, issued in 2005 under the Bush administration. Beginning January 2012 the cross-state air pollution rule will require 27 states,

including Texas, to significanfly reduce sulfur dioxide (SO2) and nitrogen oxide (NOx), common power plant emissions, which cross state lines and allegedly

contribute to ozone and fine particulate pollution in other stiates.

While the other 27 states impacted by the ruling were given notice earlier this year, Texas; however, was not added until July 6th, resulting in a 6 month

timefame for plants to comply in order to meel the January 2012 deadline. States afiected by similar EPA rule adoptions are normally given at least one year

to comply. The justification the EPA uses for suddenly adding Texas to the list of states impacted by the rule is that an air quality monitor located in lllinois in

an area within attiainment-registered levels of emissions commonly emitted by coal plantg

Not only is time an issue, but such rules will require costly improvements to older plants. Direct costs to power plants to implement forced improvements as

a result of the rule are estimated to cost $800 million by 2014, not including a $1.6 billion per year cost in capital investments. The cost-prohibitive nature of

implementing the necessary changes in order to be in compliance with the rule threaten Texas jobs, as some plants will be forced to choose between

shutting down the power plant or implementing the costly changes, which could result a significant loss in power. The negative impact of the rule has already

been felt, as recent figures indicate that 500 Texas coal-mining jobs have already been lost. Studies have also shown that Texas could be in jeopardy of

losing up to 12 coal-fired plants, resulting in the loss of additional Texas jobs.

The rule aims to reduce soot and smog causing pollutants associated with coal and other fossil fuels by curtailing sulfur dioxide and nitrogen oxide

emissions by 73 percent and 54 percent, respectively, by 2014 compared to levels measured in 2005. The impact of the rule could result in the closure ofpower plants across Texas if the plants do not take measures, some of which could be cost prohibitive, to reduce pollution. Achange to cleaner burning

fuels, such as natulal gas, is expected, and favored by the EPA. However, such a rapid change could result in negative consequences for Texans and Texasjobs.

Arother potential consequence of the implementation of the rule is an escalating cost of electricity to Texas consumers, as those plants that elect to make

the necessary modifications to comply with the rule will be forced to determine a \ ray to recover the cost of the retroftts. Such an avenue is an increase in

the cost of electricig to consumers.

Texas generators and businesses deserve a predictable regulatory environment and a realistic timeline to comply with the new rules issued by the EPA. In

my opinion, this is the wrong policy at the worst possible time, and | tully support the State's petition requesting the EPAto reconsider its adoption of the

cross-state air pollution rule. And possibility of rationing electricity with more rolling blackouts in our cities.

Editor's note: State Rep. Ken Legler (R-Pasadena) is the representative for Dist. 144.

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Works Cited

"Air Transport Rule I Large Map of Public Health and Environmental Benefits." EPA.gov. United States

Environmental Protection Agency, l9 Jan. 2012. Web. 26 Apr.2012.

"Air Transport Rule lU.ge Map of Transport Rule States." EPA.gov. United States Environmental

Protection Agency, 19 Jan. 2012.Web.26 Apr.2012.

*BET Statement on EPA's Cross State Air Pollution Rule.'o Balancedenergtfortexas.org. Balanced

Energy For Texas, 27 Feb.20l2. Web. 26 Apr.2012.

Campbell, David. Speech. 'oTestimony [...]" Texas House of Representatives Committee on State Affairs,

22 Sept. 201 l. Web. 26 Apr. 2012.

"Cross-State Air Pollution Rule (CSAPR) I gasic Information ." EPA.gov. United States Environmental

Protection Agency, 7 Feb. 2012. Web. 26 Apr.2012.

Jones, Ernesta. EPA Reduces Smokestack Pollution, Protecting Americans' Healthfrom Soot and

Smog/Clean Air Act Protections Will Cut Dangerous Pollution in Communities thot are Home to

240 Million Americans. Washington: United States Environmental Protection Agency (EPA), 7

Jul. 201l. Web.

Legler, Ken. "EPA Cross-State Air Pollution Rule Adoption Update." The Pasadena Citizen.The

Pasadena Citizen, 22 Sept. 201 1 . Web. 26 Apr. 2012.

Marston, Jim. "Cross-State Air Pollution Rule Energy Warnings Unfounded." Austin American-

Statesman. Austin American-Statesman, 7 Oct.201 l. Web. 26 Apr.2012.

Moeller, Becky. "Cross-State Air Pollution Delay Would Help Texas Workers." Austin American-

Statesman. Austin American-Statesman, 7 Oct.20l1. Web. 26 Apr.2012.

Shaw, Brian W. "EPA's Bad Science to Blame for State's Latest Challenge." TCEQ.Texas.gov. Texas

Commission on Environmental Quality,4 Oct.2011. Web. 26 Apr.2012.

Tresaugue, Matthew. "Texas Fights EPA Over Clean-Air Rule.oo San Antonio Express-News. San Antonio

Express-News, 12 Apr.2012. Web. 26 Apr.20l2.

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