EPA has announced their new PM NAAQS Standard. As expected, they have significantly lowered the primary PM2.5 annual limit from 12 ug/m3 to 9 ug/m3. The good news is that they did not change the primary 24-hour PM2.5 or PM10 limits, or any of the secondary limits.
We are digging through the details of this proposed standard as we speak, but thought it was important to give you all an idea of what this ruling will entail. First of all, this rule will be fully implemented in 2032, so we have some time to determine how it will affect each of our members. There is really nothing to be done in the immediate future to get ready for this.
On a longer-term basis, this rule will significantly impact portions of Texas. Right now, we have no PM2.5 non-attainment areas affecting any gins in Texas. This will change when this new standard is implemented. According to EPA, Bowie, Cameron, Dallas, El Paso, Harris, Hidalgo, Kleberg, Tarrant, Travis, and Webb Counties are currently posting numbers greater than 9 ug/m3. The folks we are working with on this issue believe that more counties will be declared non-attainment when the final numbers are calculated over the next year or so. I would keep a very close eye on this issue if you are in a county anywhere near the ones listed above.
If your county becomes a non-attainment county there will be significant additional requirements to expand your existing permit or to get a new permit. We will be working through these issues as time moves forward, but we do have a few years to work through these issues.
Even if you are in an attainment county, we will have to be much more careful in how we keep our permits up to date, and it may become more of a challenge to build a new gin in some parts of Texas – we will just have to see how all this plays out.
This rule will be challenged in court, and there are many more hoops to jump through before we need to take action but be sure to keep this issue on your radar – this is a very significant change to the PM standard. We will plan to have a much more thorough explanation in our February newsletter – stay tuned!
