The following can be attributed to Luke Bellsynder, executive director of the Texas Association of Manufacturers regarding the Environmental Protection Agency’s proposed Clean Air Transport Rule.

“The Texas Association of Manufacturers (TAM) has profound concerns with the U.S. Environmental Protection Agency’s proposed Clean Air Transport Rule (CATR).  This program, which limits sulfur dioxide (S02) and nitrogen oxide (NOx) emissions to downwind states, has been under development since 2008.

During the development of this rule and three notices requesting comments, the EPA did not include Texas in the CATR SO2 program.  As such, there was never a comment period for a state reduction budget for Texas, nor was there any guidance from the EPA as to potential SO2 control measures for Texas.  However, it appears Texas will be included in the final CATR rule SO2 program. 

Significant reductions and adherence would then be required in an extremely short time period – as early as January 2012.  Should this final rule be published with Texas included, it could have a far-reaching impact throughout the state.  Effects could include:
- The loss of thousands of well-paying jobs and in rural areas.
- An increase in wholesale and consumer electricity prices.
- A negative impact on the state’s electric reliability.
- The loss of indirect and third-party jobs and services which support the state’s electric industry.