EPA Dishes Out 2025 Pollution Credits to New Power Plants
Published Date: 3/2/2026
Notice
Summary
The EPA just shared the first numbers for how pollution allowances will be handed out to new power units in 2025 under the Cross-State Air Pollution Rule. Power plants that qualify can get these special allowances, but the EPA is open to hearing any objections until April 1, 2026, before finalizing the amounts. This helps keep pollution in check while giving new units a fair shot at trading pollution credits.
Analyzed Economic Effects
7 provisions identified: 3 benefits, 4 costs, 0 mixed.
Preliminary 2025 NUSA Allocations Posted
If you operate a qualifying new power unit, the EPA posted preliminary 2025 new unit set-aside (NUSA) allowance calculations online showing each unit's proposed 2025 allocation (generally equal to that unit's 2025 control period emissions reported under 40 CFR part 75). These are preliminary numbers for the 2025 control periods that the EPA may finalize after considering timely objections.
Pro-Rata Reductions If NUSA Oversubscribed
If the sum of eligible new-unit allocations exceeds the amount of allowances in a state's 2025 NUSA, the EPA will reduce each new unit's allocation on a pro-rata basis. That means your proposed allocation for 2025 could be cut back proportionally if the pool is oversubscribed.
Allocations May Be Corrected or Rescinded
The EPA says that an allocated allowance, or lack of one, does not determine whether a trading program applies to a unit, and allocations can be corrected if a unit with allocated allowances is not an 'affected unit' at the start of the 2025 control period. That means your allocation could be changed or removed if the unit's status changes.
NOX Ozone Season Group 3 Stayed for 2025
The EPA states it has no current plans to determine NUSA allocations for the 2025 control period under the CSAPR NOX Ozone Season Group 3 Trading Program because implementation of that program remains administratively stayed. Units that would fall under Group 3 should note this stay for 2025.
Early Emissions Excluded From Allocations
The EPA will not count emissions that occur before a unit's monitor certification deadline when calculating that unit's 2025 NUSA allocation. If your unit emitted before its monitor was certified, those early emissions will not increase your 2025 allocation.
Remaining Allowances Go To Existing Units
After the EPA allocates allowances to eligible new units for 2025, any allowances left in a state's NUSA are allocated to that state's existing units in proportion to those units' prior allocations from the non‑NUSA portion of the emissions budget. If you operate an existing unit, you may receive some of the leftover 2025 allowances based on past allocation shares.
Separate Indian Country NUSA Exists
For states that include Indian country, the CSAPR programs generally have a separate Indian country NUSA that reserves a portion of the emissions budget for units located in Indian country. Units located in Indian country are considered for allocations from that separate NUSA for the 2025 control periods.
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