Regulatory Alert- May 2022

Good Neighbor FIP


The Environmental Protection Agency (EPA) has proposed a plan to cut down on air pollution emissions from power plants and other industrial sources. This Federal Implementation Plan (FIP) will address twenty-six states’ obligations to reduce the amount of nitrogen oxide (NOx) emissions allowing them to resolve their Clean Air Act “good neighbor” obligations for the 2015 National Ambient Air Quality Standard (NAAQS) in downwind states.


Along with reducing NOx emissions, the EPA is proposing an allowance-based ozone season trading program with NOx emissions budgets for electric generating unit (EGU) sources in twenty-five states beginning in 2023. Nitrogen Oxide emissions limitations related to certain other non-EGU sources are also proposed for twenty-three states with an estimated compliance date of 2026. Some of the industrial source types that will have introduced NOx emissions include paperboard mills; petroleum and coal products manufacturing; and burners and furnaces in iron mills, steel mills, and ferroalloy manufacturing.

Control technologies for non-EGUs will potentially be implemented starting in 2026. The industries involved will be broken down into Tier 1 and 2 industries, based on their potential impacts. A few of the proposed required control technologies include: natural gas reburn, oxygen-enriched air staging, selective catalytic reduction, and non-selective catalytic reduction.

Comments regarding this proposed plan are to be received by the EPA on or before June 6, 2022. You may send comments to

“Good Neighbor Plan for 2015 Ozone NAAQS.” EPA, Environmental Protection Agency,


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