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Economic Impact Analysis for the New
Source Performance Standards Review for
Stationary Combustion Turbines: Final Rule


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EPA-452/R-26-002
January 2026

Economic Impact Analysis for the New Source Performance Standards Review for
Stationary Combustion Turbines: Final Rule

U.S. Environmental Protection Agency
Office of Clean Air Programs
Impacts and Ambient Standards Division
Research Triangle Park, NC

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CONTACT INFORMATION

This document has been prepared by staff from the Office of Clean Air Programs, U.S.
Environmental Protection Agency. Questions related to this document should be addressed
to U.S. Environmental Protection Agency, Office of Clean Air Programs, C439-02, Research
Triangle Park, North Carolina 27711 (email: OCAPeconomics@epa.gov).

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CONTENTS

List of Tables	vi

List of Figures	vii

1	Introduction	1

1.1	Background	1

1.2	Legal Basis for this Rulemaking	2

1.3	Economic Basis for this Rulemaking	3

1.4	Regulatory History	4

1.5	Final Requirements	8

1.6	Organization of this EIA	14

2	Combustion Turbine Technologies and Costs	15

2.1	Introduction	15

2.2	Simple-Cycle Combustion Turbine Technologies	15

2.3	Combined-Cycle Combustion Turbine Technologies	16

2.4	Capital and Installation Costs	17

2.5	Affected Producers	19

2.6	Projected Growth of Combustion Turbines	22

3	Engineering Cost Analysis	25

3.1	Introduction	25

3.2	Affected Sources	25

3.3	Capital Investment, Annual Costs, and Emissions Reductions	27

3.4	Secondary Impacts	32

3.5	Characterization of Uncertainty	33

4	Benefits of Emissions Reductions	34

4.1	Introduction	34

4.2	Benefits of Nitrogen Oxide Reductions	36

4.3	Benefits of Sulfur Dioxide Reductions	37

4.4	Disbenefits from Increased Ammonia and NOx Emissions	38

5	Economic and Small Business Impacts	39

5.1	Introduction	39

5.2	Screening Analysis	39

5.2.1	Identification of Small Entities	40

5.2.2	Small Business Impacts Analysis	41

5.3	Economic Impacts	43

5.4	Employment Impacts	43

6	References	45

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LIST OF TABLES

Table 1 Current N0X Emission Standards for Stationary Combustion Turbines	6

Table 2 Subcategories and NOx Standards for Subpart KKKKa	13

Table 3 Utility-scale Gas Turbine Power Plant Capital Cost Estimates (million 2022$ unless

otherwise noted)	18

Table 4 Combustion Turbines over 10 MMBtu/h or equivalent by NAICS code	19

Table 5 Number of Firms and Establishments, Employment, and Annual Payroll for Affected

Industries: 2021	22

Table 6 Types of Combustion Turbines Constructed 2020-2024 and Installed Controls	23

Table 7 Estimated Number of New, Modified, or Reconstructed Turbines in Each Year	26

Table 8 Summary of Estimated Affected Units and Emission Reductions in First 8 Years After the

Rule is Final	28

Table 9 Summary of Estimated Costs for Subcategories with Increased Stringency in First 8 Years

After the Rule is Final	28

Table 10 2024 Present Value and Equivalent Annualized Value of Estimated Costs for

Subcategories with Increased Stringency in First 8 Years After the Rule is Final (million

2024$)	29

Table 11 Summary of Estimated Costs Associated with Large, High-Efficiency Turbines in First 8

Years After the Rule is Final	31

Table 12 2024 Present Value and Equivalent Annualized Value of Net Avoided Costs Associated
with Large, High-Efficiency Turbines in First 8 Years After the Rule is Final (million

2024$)	31

Table 13 Summary of Estimated Costs for the Final NSPS for Combustion Turbines from 2025 to

2032 (millions, 2024$)	32

Table 14 Estimated Increased Ammonia Emissions Associated with NOx Emission Reductions with

Applied SCR	33

Table 15 Affected NAICS Codes and SBA Small Entity Size Standards	41

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LIST OF FIGURES	

Figure 1 Simple-Cycle Gas Turbine	16

Figure 2 Combined-Cycle Gas Turbine	17

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1 INTRODUCTION

1.1 Background

The U.S. Environmental Protection Agency (EPA) is finalizing amendments to the
new source performance standards for stationary combustion turbines and stationary gas
turbines pursuant to the technology review required by the Clean Air Act (CAA). As a result
of this review of available control technologies for limiting emissions of certain criteria air
pollutants, specifically nitrogen oxide (NOx) and sulfur dioxide (SO2), the EPA is
establishing size-based subcategories for new, modified, and reconstructed stationary
combustion turbines that recognize distinctions between those that operate at varying
rates of utilization, those with different design efficiencies, those firing natural gas or non-
natural gas fuels, and those that operate in certain locations. In general, the EPA
determines that the continued use of combustion controls is the best system of emission
reduction (BSER) for limiting NOx emissions from most new stationary combustion
turbines in this source category. Specifically, the BSER of combustion controls applies to all
new medium and small stationary combustion turbines and certain new large combustion
turbines. However, for new large combustion turbines with high rates of utilization, the
EPA determines that combustion controls with the addition of post-combustion selective
catalytic reduction (SCR) is the BSER. Lower utilization large turbines are further divided
according to efficiency with separate BSER determinations and associated NOx standards.
For large, low utilization turbines that are more efficient, the EPA determines the BSER is
combustion controls alone, and for lower efficiency designs the BSER is the use of advanced
combustion controls. Based on the application of a particular BSER and other updates in
technical information, the EPA is proposing to adjust the NOx standards of performance for
certain stationary combustion turbines in this source category. Combustion controls
remain the BSER for modified and reconstructed units. In addition, the EPA is maintaining
the current standards for SO2 emissions, because after reviewing the current SO2
standards, we find that the use of low-sulfur fuels remains the BSER. Finally, the Agency
includes a subcategory for temporary stationary combustion turbines as well as
amendments to address specific technical and editorial issues to clarify the existing
regulations.

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1.2 Legal Basis for this Rulemaking

The EPA's authority for this rule is CAA section 111, which governs the
establishment of standards of performance for stationary sources. Section 111(b)(1)(A) of
the CAA requires the EPA Administrator to list categories of stationary sources that in the
Administrator's judgment cause or contribute significantly to air pollution that may
reasonably be anticipated to endanger public health or welfare. The EPA must then issue
performance standards for new (and modified or reconstructed) sources in each source
category pursuant to CAA section 111(b)(1)(B). These standards are referred to as new
source performance standards (NSPS). The EPA has the authority to define the scope of the
source categories, determine the pollutants for which standards should be developed, set
the emission level of the standards, and distinguish among classes, types, and sizes within
categories in establishing the standards.

CAA section 111(b)(1)(B) requires the EPA to "at least every 8 years review and, if
appropriate, revise" new source performance standards. However, the Administrator need
not review any such standard if the "Administrator determines that such review is not
appropriate in light of readily available information on the efficacy" of the standard.

In setting or revising a performance standard, CAA section 111(a)(1) provides that
performance standards are to reflect "the degree of emission limitation achievable through
the application of the BSER which (taking into account the cost of achieving such reduction
and any nonair quality health and environmental impact and energy requirements) the
Administrator determines has been adequately demonstrated." The term "standard of
performance" in CAA section 111(a)(1) makes clear thatthe EPA is to determine both the
BSER for the regulated sources in the source category and the degree of emission limitation
achievable through application of the BSER. The EPA must then, under CAA section
111(b)(1)(B), promulgate standards of performance for new sources that reflect that level
of stringency. CAA section 111(b)(5) generally precludes the EPA from prescribing a
particular technological system that must be used to comply with a standard of
performance. Rather, sources can select any measure or combination of measures that will
achieve the standard.

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Pursuant to the definition of new source in CAA section 111(a)(2), standards of
performance apply to facilities that begin construction, reconstruction, or modification
after the date of publication of the proposed standards in the Federal Register. Under CAA
section 111(a)(4), "modification" means any physical change in, or change in the method of
operation of, a stationary source which increases the amount of any air pollutant emitted
by such source or which results in the emission of any air pollutant not previously emitted.
Changes to an existing facility that do not result in an increase in emissions are not
considered modifications. Under the provisions in 40 CFR 60.15 (subject to any variation in
the category-specific NSPS regulations), reconstruction means the replacement of
components of an existing facility such that: (1) the fixed capital cost of the new
components exceeds 50 percent of the fixed capital cost that would be required to
construct a comparable entirely new facility; and (2) it is technologically and economically
feasible to meet the applicable standards. Pursuant to CAA section 111(b)(1)(B), the
standards of performance or revisions thereof shall become effective upon promulgation.

1.3 Economic Basis for this Rulemaking

This rulemaking weighs several economic considerations in determining how and
whether to update combustion turbine emission standards for the protection of human
health and the environment. Executive Order 12866 directs that, "Each agency shall identify
the problem that it intends to address (including, where applicable, the failures of private
markets or public institutions that warrant new agency action) as well as assess the
significance of that problem." Economic efficiency can generally be achieved from private
competition in free markets, but E.0.12866 recognizes that some markets may not achieve
economic efficiency when there exists some form of market failure. The Office of
Management and Budget's (OMB) Circular A-4 (2003) notes that "the major types of market
failure include: externality, market power, and inadequate or asymmetric information." An
externality occurs "when one party's actions impose uncompensated benefits or costs on
another party. Environmental problems are a classic case of externality." The human health
impacts of NOx emissions from combustion turbines are an example of an externality
where private firms (e.g., the operators of combustion turbines) do not fully account for the

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human health impacts of their operations.1 In the presence of such an externality, Federal
intervention may be warranted. Circular A-4 states, "If the regulation is designed to correct
a significant market failure, you should describe the failure both qualitatively and (where
feasible) quantitatively You should show that a government intervention is likely to do more
good than harm."2

For this final rule, EPA has followed the directions of E.0.12866 and Circular A-4 in
publishing an impact analysis characterizing the costs and benefits of the proposed rule,
soliciting public comment, and now providing an updated analysis in this EIA comparing
the costs of the final rule to a no action alternative in the baseline. Specifically, EPA's
analysis considers the increased compliance costs for the turbine types for which this rule
increases regulatory requirements and cost-savings from the components of this rule that
decrease regulatory requirements. This EIA also describes the broader economic impacts
of this rulemaking, employment effects, and various unquantified impacts. As detailed later
in this EIA, combustion turbines have applications across several sectors, including
electricity, oil and gas, and data centers.

1.4 Regulatory History

A stationary combustion turbine is defined as all equipment, including but not
limited to the combustion turbine; the fuel, air, lubrication, and exhaust gas systems;
control systems (except emission control equipment); heat recovery system (including
heat recovery steam generators (HRSG) and duct burners); and any ancillary components

1	Private firms may account for some of the human health or other impacts of their emissions, but they are
not necessarily incentivized to fully internalize these external costs. For example, some private firms may
be required to address pollution under state or local regulations or as the result of litigation. Some private
firms may also voluntarily control emissions in response to community concerns or other societal
pressures. However, these considerations are not necessarily sufficient to achieve economic efficiency.

2	In addition to the directive that Federal rulemakings establish a justification for intervention, Circular A-4
and E.0.12866 also direct agencies to consider benefits and costs in the rulemaking process. Specifically,
E.0.12866 states, "In deciding whether and how to regulate, agencies should assess all costs and benefits of
available regulatory alternatives, including the alternative of not regulating. Costs and benefits shall be
understood to include both quantifiable measures (to the fullest extent that these can be usefully estimated)
and qualitative measures of costs and benefits that are difficult to quantify, but nevertheless essential to
consider. Further, in choosing among alternative regulatory approaches, agencies should select those
approaches that maximize net benefits (including potential economic, environmental, public health and
safety, and other advantages; distributive impacts; and equity), unless a statute requires another regulatory
approach."

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and sub-components comprising any simple cycle, regenerative/recuperative cycle, and
combined cycle stationary combustion turbine, and any combined heat and power (CHP)
stationary combustion turbine-based system. Stationary means that the combustion
turbine is not self-propelled or intended to be propelled while performing its function.
Certain combustion turbines may, however, be mounted on a vehicle for portability and
still be considered stationary.

Standards of performance for the source category of stationary gas turbines were
originally promulgated in 1979 in subpart GG of 40 CFR part 60 (44 FR 52792). As
promulgated in 1979, the sources subject to the NSPS are stationary combustion turbines
with a heat input at peak load equal to or greater than 10.7 gigajoules (GJ) (10 million
British thermal units per hour (MMBtu/h)), based on the lower heating value of the fuel,
that commenced construction, modification, or reconstruction after October 3,1977.

The EPA last revised the NSPS on July 6, 2006, and subpart KKKK is applicable to
stationary combustion turbines with a heat input at peak load equal to or greater than 10.7
GJ (10 MMBtu/h), based on the higher heating value (HHV) of the fuel, for which
construction, modification, or reconstruction was commenced after February 18, 2005 (71
FR 38482).

The NOx standards in subparts GG and KKKK are based on the application of
combustion controls (as the BSER) and allow the turbine owner or operator the choice of
meeting a concentration-based emission standard or an output-based emission standard.
The concentration-based emission limits are in units of parts per million by volume dry
(ppmvd) at 15 percent oxygen (O2). The output-based emission limits are in units of mass
per unit of useful recovered energy, nanograms per Joule (ng/J) or pounds per megawatt-
hour (lb/MWh). All of the NOx limits in subpart KKKK are based on the application of
combustion controls but individual standards may differ for individual subcategories of
combustion turbines based on the following factors: the fuel input rating at peak load, the
fuel used, the application, the load, and the location of the turbine. The fuel input rating of
the turbine does not include any supplemental fuel input to the heat recovery system and
refers to the rating of the combustion turbine itself.

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Specifically, in subpart KKKK, the EPA identifies 14 subcategories of stationary
combustion turbines and establishes NOx emission limits for each. The size-based
subcategories include less than or equal to 50 MMBtu/h of heat input, greater than 50
MMBtu/h of heat input and less than or equal to 850 MMBtu/h of heat input, and greater
than 850 MMBtu/h of heat input. There are separate subcategories for combustion
turbines operating at part load, for modified and reconstructed combustion turbines, heat
recovery units operating independent of the combustion turbine, and turbines operating at
low ambient temperatures. A specific NOx performance standard ranging from 15 to 150
ppmvd is identified for each of the 14 subcategories and these standards are shown in
Table 1.

Table 1 Current NOx Emission Standards for Stationary Combustion Turbines

Combustion Turbine Type

Combustion Turbine Heat
Input at Peak Load (HHV)

NOx Emission Standard

New turbine firing natural gas, electric
generating

< 50 MMBtu/h

42 ppm at 15 percent oxygen (O2] or
290 ng/J of useful output (2.3 lb/MWh]

New turbine firing natural gas, mechanical
drive

< 50 MMBtu/h

100 ppm at 15 percent O2 or 690 ng/J
of useful output (5.5 lb/MWh]

New turbine firing natural gas

> 50 MMBtu/h and <850
MMBtu/h

25 ppm at 15 percent O2 or 150 ng/J of
useful output (1.2 lb/MWh]

New, modified, or reconstructed turbine
firing natural gas

> 850 MMBtu/h

15 ppm at 15 percent O2 or 54 ng/J of
useful output (0.43 lb/MWh]

New turbine firing fuels other than natural
gas, electric generating

< 50 MMBtu/h

96 ppm at 15 percent O2 or 700 ng/J of
useful output (5.5 lb/MWh]

New turbine firing fuels other than natural
gas, mechanical drive

< 50 MMBtu/h

150 ppm at 15 percent O2 or 1,100 ng/J
of useful output (8.7 lb/MWh]

New turbine firing fuels other than natural
gas

>50 MMBtu/h and <850
MMBtu/h

74 ppm at 15 percent O2 or 460 ng/J of
useful output (3.6 lb/MWh]

New, modified, or reconstructed turbine
firing fuels other than natural gas

> 850 MMBtu/h

42 ppm at 15 percent O2 or 160 ng/J of
useful output (1.3 lb/MWh]

Modified or reconstructed turbine

< 50 MMBtu/h

150 ppm at 15 percent O2 or 1,100 ng/J
of useful output (8.7 lb/MWh]

Modified or reconstructed turbine firing
natural gas

>50 MMBtu/h and <850
MMBtu/h

42 ppm at 15 percent O2 or 250 ng/J of
useful output (2.0 lb/MWh]

Modified or reconstructed turbine firing
fuels other than natural gas

>50 MMBtu/h and <850
MMBtu/h

96 ppm at 15 percent O2 or 590 ng/J of
useful output (4.7 lb/MWh]

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Combustion Turbine Type

Combustion Turbine Heat

Input at Peak Load (HHV) NOx Emission Standard

Turbines located north of the Arctic Circle < 30 MW output

(latitude 66.5 degrees north], turbines

operating at less than 75 percent of peak

load, modified and reconstructed offshore

turbines, and turbines operating at

temperatures less than 0 °F

150 ppm at 15 percent O2 or 1,100 ng/J
of useful output (8.7 lb/MWh]

Turbines located north of the Arctic Circle > 30 MW output

(latitude 66.5 degrees north], turbines

operating at less than 75 percent of peak

load, modified and reconstructed offshore

turbines, and turbines operating at

temperatures less than 0 °F

96 ppm at 15 percent O2 or 590 ng/J of
useful output (4.7 lb/MWh]

Heat recovery units operating independent All sizes
of the combustion turbine

54 ppm at 15 percent O2 or 110 ng/J of
useful output (0.86 lb/MWh]

Regarding SO2, the standards of performance in subpart KKKK reflect the use of low-
sulfur fuels. The fuel sulfur content limit is 26 ng/J (0.060 lb SCh/MMBtu) heat input for
combustion turbines located in continental areas and 180 ng/J (0.42 lb SCh/MMBtu) heat
input in noncontinental areas. This is approximately equivalent to 0.05 percent sulfur by
weight (500 parts per million by weight (ppmw)) for fuel oil in continental areas and 0.4
percent sulfur by weight (4,000 ppmw) for fuel oil in noncontinental areas, respectively.
Subpart KKKK also includes an optional output based SO2 standard.

In subpart GG in 1979, the EPA determined that it was appropriate to exempt
emergency combustion turbines from the NOx limits. These included emergency-standby
combustion turbines, military combustion turbines, and firefighting combustion turbines.
Emergency combustion turbines are further defined in subpart KKKK as units that operate
in emergency situations, such as turbines used to supply electric power when the local
utility service is interrupted. Subpart KKKK also includes exemptions for stationary
combustion turbine test cells/stands and integrated gasification combined cycle (IGCC)
combustion turbine facilities covered by subpart Da of 40 CFR part 60 (the Utility Boiler
NSPS). Furthermore, under subpart KKKK, the HRSG and duct burners continue to be
exempt from subparts Da, Db, and Dc (the Utility Boiler and Industrial, Commercial, and
Institutional Boiler NSPS) while combustion turbines used by manufacturers in research
and development of equipment for both combustion turbine emissions control techniques

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and combustion turbine efficiency improvements are exempt from the NOx limits on a case-
by-case basis only.

On September 5, 2006, a petition for reconsideration of the revised NSPS was filed
by the Utility Air Regulatory Group (UARG). The EPA granted reconsideration of subpart
KKKK and on August 29, 2012, proposed to amend subparts KKKK and GG to address
specific issues identified by the petitioners (77 FR 52554) as well as other technical and
editorial issues.

The 2012 proposed amendments to subparts KKKK and GG of 40 CFR part 60 were
in response to issues raised in the UARG petition for reconsideration discussed above.
Specifically, the EPA proposed to clarify the intent in applying and implementing specific
rule requirements, to correct unintentional technical omissions and editorial errors, and
address various other issues that were identified since promulgation of subpart KKKK. The
EPA did not finalize that rule, but reproposed applicable clarifications and technical
corrections from those proposed amendments in the 2024 NSPS Proposal.

1.5 Final Requirements

Sources subject to the NSPS are stationary combustion turbines with a heat input at
peak load equal to or greater than 10.7 gigajoules per hour (GJ/h) (10 million British
thermal units per hour (MMBtu/h)), based on the higher heating value (HHV) of the fuel,
that commence construction, modification, or reconstruction after December 13, 2024, the
date of publication of the proposed standards in the Federal Register. The applicability of
sources that are subject to subpart KKKKa is similar to that for sources subject to the
existing 40 CFR part 60, subpart KKKK. Stationary combustion turbines subject to the
standards in the new subpart KKKKa are not subject to the requirements of subparts GG or
KKKK; the HRSG and duct burners subject to these standards continue to be exempt from
the requirements of 40 CFR part 60, subpart Da (the Utility Boiler NSPS) as well as subparts
Db and Dc (the Industrial/Commercial/Institutional Boiler NSPS) as previously established
in subpart KKKK. Subpart KKKKa maintains the NOx exemptions promulgated previously in
subparts GG and KKKK. The EPA is amending the applicability of subparts KKKK and
KKKKa to provide that owners and operators of portable combustion turbines that have

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been properly certified as meeting the standards that would be applicable to such
combustion turbines under the appropriate mobile source provisions are not required to
meet any other provisions under subparts KKKK or KKKKa.

After considering comments critical of the proposed size-based subcategory
threshold between small and medium units, the EPA has decided to retain in subpart
KKKKa the general size-based subcategories from subpart KKKK. This includes
subcategories for new, modified, and reconstructed stationary combustion turbines with
base load ratings greater than 850 MMBtu/h of heat input (i.e., large), base load ratings
greater than 50 MMBtu/h and less than or equal to 850 MMBtu/h of heat input (i.e.,
medium), and base load ratings less than or equal to 50 MMBtu/h of heat input (i.e., small).
In addition, certain subcategories of new stationary combustion turbines in subpart KKKKa
reflect the correlation between the utilization of a combustion turbine and the performance
of available control technologies in limiting NOx emissions. Specifically, manufacturers
have continuously strived to increase the efficiency of new turbine designs, but
manufacturer specification sheets show that some models of large, high-efficiency turbines
cannot meet the 15 ppm NOx standard established in subpart KKKK. A review of power
sector data reported to EPA's CAMPD—as well as BACT permits under the NSR program—
shows that many owners/operators of high-efficiency combustion turbines subject to a
NOx limit of 15 ppm have installed SCR. This correlation between high-efficiency
combustion turbines and increased NOx emissions has led to SCR becoming a more utilized
control technology for the source category. Also, for certain large combustion turbines, the
design efficiency of the combustion turbine is also considered—depending on the
utilization of the turbine according to its rolling 12-calendar-month capacity factor. The
EPA sub categorizes large and medium combustion turbines further according to how they
are operated—either at high rates of utilization or low rates of utilization. A new large or
medium combustion turbine with a 12-calendar-month capacity factor greater than 45
percent is subcategorized as a high-utilization source. A new large or medium combustion
turbine with a 12-calendar-month capacity factor less than or equal to 45 percent is
subcategorized as a low-utilization source. Small combustion turbines are not being further
subcategorized based on utilization.

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In addition, taking into consideration public comments in response to the EPA's
discussion of the unique challenges faced by new large, higher efficiency turbines in the
proposal, the EPA is finalizing two subcategories based on the design efficiency of the
combustion turbine, which account for different levels of emissions performance that can
be achieved by combustion controls alone (i.e., without SCR). Specifically, for new large
turbines with low rates of utilization (i.e., a 12-calendar-month capacity factor less than or
equal to 45 percent) and design efficiencies equal to or greater than 38 percent on a higher
heating value (HHV) basis, the EPA is finalizing a determination that the BSER is the use of
combustion controls alone, and for new large turbines with low rates of utilization (i.e., a
12-calendar-month capacity factor less than or equal to 45 percent) and design efficiencies
less than 38 percent, the EPA is finalizing a determination that the BSER is the use of
advanced combustion controls.

In subpart KKKKa, the EPA is finalizing a determination that the BSER is the use of
combustion controls (i.e., without SCR) for all but one subcategory of new, modified, or
reconstructed stationary combustion turbines. For that one subcategory—new large
turbines with high rates of utilization (i.e., a 12-calendar-month capacity factor greater
than 45 percent)—the BSER is combustion controls with SCR. The standards of
performance for each subcategory of stationary combustion turbine in subpart KKKKa
reflect the degree of emission limitation achievable based upon application of the BSER. For
new large, high-utilization turbines firing natural gas with a BSER of combustion controls
with SCR, the NOx standard is 5 ppm. For new natural gas-fired large turbines with low
rates of utilization, the NOx standard is 25 ppm for higher efficiency classes of turbines and
9 ppm for lower efficiency classes. The different NOx standards reflect the performance of
available control technologies and are based on the application of the appropriate BSER for
each subcategory, either combustion controls with SCR, combustion controls without SCR,
or advanced combustion controls without SCR, respectively.

Similarly, for new medium, high-utilization combustion turbines firing natural gas,
the NOx standard is 15 ppm based on the performance of the BSER of dry combustion
controls. For new medium, low-utilization turbines firing natural gas, the NOx standard is
25 ppm based on the performance of water- or steam-injection combustion controls. And

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for all new natural gas-fired small combustion turbines, the NOx standard is 25 ppm based
on the BSER of combustion controls. Subpart KKKKa does not distinguish between
electrical and mechanical drive applications for new sources.

This action also maintains subcategories for modified and reconstructed stationary
combustion turbines that are generally consistent with the subcategories in subpart KKKK.
These subcategories are based on a BSER of combustion controls with associated NOx
standards of performance. The EPA is not finalizing the proposed, category-specific
definition of "reconstruction" for combustion turbines.

Other final determinations reflected in subpart KKKKa include: the creation of a new
subcategory for stationary temporary combustion turbines; lowering the threshold that
defines part-load operations to any hour when the heat input of the combustion turbine is
less than or equal to 70 percent of the base load rating; allowing owners and operators to
petition the Administrator for a site-specific NOx standard when burning by-product fuels;
an exclusion of heat input from utilization-level calculations during periods of Energy
Emergency Alert levels 1, 2, and 3; an exemption from Title V permitting for certain
combustion turbines that are not major sources or located at major sources under CAA
section 502(a) (also added to subparts GG and KKKK); and retention of the SO2 standards
from subpart KKKK for all new, modified, and reconstructed stationary combustion
turbines.

The EPA is finalizing corresponding amendments in subparts GG and KKKK with
respect to several of these ancillary issues, which will be applicable to combustion turbines
subject to those subparts as of the effective date of this final rule. In subpart GG, the EPA is
finalizing that turbines subject to subparts Da, KKKK, or KKKKa are not subject to subpart
GG. In subpart KKKK, the EPA is finalizing a clarification that only the heat input to the
combustion turbine engine is used for applicability purposes and that combustion turbines
regulated under subpart KKKK are exempt from subparts KKKKa and GG. The EPA is also
finalizing that emergency, military, and firefighting combustion turbines are exempt from
the NOx emissions standards in subpart KKKK and KKKKa, carrying over exemptions that
were originally included in subpart GG. Additionally, the EPA is finalizing flexibilities
regarding when performance tests must be conducted after long periods of non-operation

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and that owners and operators can use fuel records to comply with their SO2 standard. The
EPA is finalizing a low-Btu alternative to the SO2 standard in subpart KKKK, as well as a
concentration-based alternate SO2 standard. Finally, the EPA is finalizing the requirement
for state approval for certain monitoring and compliance tasks that are already covered
under Part 75 and specifications about including duct burners in performance tests. In both
subparts GG and KKKK, the EPA is finalizing that as an alternative to being subject to either
of those subparts, owners or operators of combustion turbines that otherwise meet the
applicability criteria of each may petition the Administrator to become subject to subpart
KKKKa instead. The EPA is also finalizing in both subparts GG and KKKK that turbines
subject to subparts J or Ja are not subject to the respective SO2 standard in subparts GG or
KKKK and that NOx continuous emissions monitoring systems (CEMS) installed and
certified according to Part 75 can be used to monitor NOx emissions. The EPA is finalizing
standard electronic reporting requirements for turbines subject to subparts GG or KKKK
and that an additional test method (EPA Method 320) can be used to determine NOx and
diluent concentration in subparts GG and KKKK. It is the EPA's understanding and intention
that none of these changes alter the stringency or increase any regulatory burdens with
respect to the existing combustion turbines subject to these subparts.

This action finalizes standards of performance in subpart KKKKa that apply at all
times, including during periods of startup, shutdown, and malfunction (SSM), and other
changes such as electronic reporting that also apply to previous NSPS subparts GG and
KKKK. These standards are summarized in Table 2.3

3 The removal of the SSM exemption is a legal change from the baseline in that, under subpart KKKK, the SSM
exemption continues to be available. However, this NSPS provides for startup and shutdown through part-
load and blended hourly standards. Generally, the EPA does not believe SSM changes will lead to
quantifiable changes in cost and emissions impacts.

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Table 2 Subcategories and NOx Standards for Subpart KKKKa

Combustion turbine type

Combustion turbine base load rated
heat input (HHV)

NOx emission

standard
(lb/MMBtu)

NOx emission rate
equivalent (ppm at
15 percent O2)

New, firing natural gas with
utilization rate > 45 percent

> 850 MMBtu/h

0.018

5

New, firing natural gas with
utilization rate < 45 percent and
with design efficiency > 38 percent

0.092

25

New, firing natural gas with
utilization rate < 45 percent and
with design efficiency < 38 percent

0.035

9

Modified or reconstructed, firing
natural gas, at all utilization rates
with design efficiency > 38 percent

0.092

25

Modified or reconstructed, firing
natural gas, at all utilization rates
with design efficiency < 38 percent

0.055

15

New, modified, or reconstructed,
firing non-natural gas

0.160

42

New, firing natural gas at utilization
rates > 45 percent

> 50 MMBtu/h and < 850 MMBtu/h

0.055

15

New, firing natural gas at utilization
rates < 45 percent

0.092

25

New, firing non-natural gas

0.290

74

Modified or reconstructed, firing
natural gas

> 20 MMBtu/h and < 850 MMBtu/h

0.150

42

Modified or reconstructed, firing
non-natural gas

0.370

96

New, firing natural gas

< 50 MMBtu/h

0.092

25

New, firing non-natural gas

0.370

96

Modified or reconstructed, all fuels

< 20 MMBtu/h

0.550

150

New, firing natural gas, either
offshore turbines, turbines
bypassing the heat recovery unit,
and/or temporary turbines

> 50 MMBtu/h

0.092

25

Located north of the Arctic Circle
(latitude 66.5 degrees north],
operating at ambient temperatures
less than 0 °F (-18 °C], modified or
reconstructed offshore turbines,
operated during periods of turbine
tuning, byproduct-fired turbines,
and/or turbines operating at less
than 70 percent of the base load
rating

< 300 MMBtu/h

0.55

150

Located north of the Arctic Circle
(latitude 66.5 degrees north],
operating at ambient temperatures
less than 0 °F (-18 °C], modified or
reconstructed offshore turbines,
operated during periods of turbine
tuning, byproduct-fired turbines,
and/or turbines operating at less
than 70 percent of the base load
rating

> 300 MMBtu/h

0.35

96

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Combustion turbine type

Combustion turbine base load rated
heat input (HHV)

NOx emission

standard
(lb/MMBtu)

NOx emission rate
equivalent (ppm at
15 percent O2)

Heat recovery units operating
independent of the combustion
turbine

All sizes

0.20

54

Several statutes and executive orders (EO) apply analytical requirements to federal
rulemakings. This Regulatory Impact Analysis (RIA) presents several of the analyses
required by these statutes and EOs, such as EO 12866 and the Regulatory Flexibility Act
(RFA). The guidance document associated with EO 12866 is OMB's Circular A-4 (U.S. OMB,
2003).

This action is not significant under 3(f)(1) of Executive Order 12866, which specifies
that a rule is significant if it is likely to result in an annual effect on the economy of $100
million or more or adversely affect in a material way the economy, a sector of the economy,
productivity, competition, jobs, the environment, public health or safety, or State, local,
territorial, or tribal governments or communities.4 However, because this rule was
submitted to OMB for review, in accordance with EO 12866 and the guidelines of OMB
Circular A-4, this EIA analyzes the costs of complying with the requirements in this final
rule for regulated facilities.

1.6 Organization of this EIA

The remainder of this report details the methodology and the results of the EIA.
Chapter 2 presents an overview of combustion turbine types and their installation costs, as
well as a brief description of the industries in which they are most prevalent. Chapter 3
describes the emissions and cost analysis prepared for this final rule. Chapter 4 describes
the health effects associated with exposure to NOx and SO2. Chapter 5 presents a discussion
of potential economic impacts, impacts on small businesses and a discussion of potential
employment impacts. Chapter 6 contains the references for this EIA.

4 EO 12866 can be found at https://www.archives.gov/files/federal-register/executive-
orders/pdf/12866.pdf.

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2 COMBUSTION TURBINE TECHNOLOGIES AND COSTS

2.1	Introduction

This section provides background information on combustion turbine technologies.
Included is a discussion of simple-cycle combustion turbines (SCCTs) and combined-cycle
combustion turbines (CCCTs), along with a comparison of fuel efficiency and capital costs
between the two classes of turbines.

2.2	Simple-Cycle Combustion Turbine Technologies

Most stationary combustion turbines use natural gas to generate shaft power that is
converted into electricity by a generator or used to power a mechanical drive device such
as a gas compressor or pump.

Combustion turbines have four basic components, as shown in Figure 1.

1.	The compressor raises the air pressure up to thirty times atmospheric pressure.

2.	A fuel compressor is used to pressurize the fuel.

3.	The compressed air is heated in the combustion chamber at which point fuel is
added and ignited.

4.	The hot, high pressure gases are then expanded through a power turbine,
producing shaft power, which is used to drive the air and fluid compressors of
the combustion turbine as well as a generator or other mechanical drive device.
Approximately one-third of the power developed by the power turbine can be
required by the compressors.

Electric utilities primarily use simple-cycle combustion turbines as peaking or
backup units. Their relatively low capital costs and quick start-up capabilities make them
ideal for partial operation to generate power at periods of high demand or to provide
ancillary services. The disadvantage of simple-cycle systems is that they are relatively
inefficient, thus making them less attractive as base load generating units.

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Fuel-



Combustion
Chamber





	~



Figure 1 Simple-Cycle Gas Turbine

2.3 Combined-Cycle Combustion Turbine Technologies

The combined-cycle system incorporates two simple-cycle systems into one
generation unit to maximize energy efficiency Energy is produced in the first cycle using a
gas turbine; then the heat that remains is used to create steam, which is run through a
steam turbine, which is the second cycle. Thus, two single units, gas and steam, are
combined to minimize lost potential energy. In a CCCT, the waste heat remaining from the
gas turbine cycle is used in a boiler to produce steam. The steam is then put through a
steam turbine, producing power. The remaining steam is recondensed and either returned
to the boiler where it is sent through the process again or sold to a nearby industrial site to
be used in a production process. Figure 2 shows a gas-fired CCCT.

There are significant efficiency gains in using a combined-cycle turbine compared to
simple-cycle systems. With SCCTs, adding a second stage allows for heat that otherwise
would have been emitted and completely wasted to be used to create additional power or
steam for industrial purposes. While SCCTs typically range from 30-40 percent efficiency,
CCCTs typically range from 50-60 percent efficiency (Gas Turbine World, 2023). In addition
to energy efficiency gains, CCCTs also offer environmental efficiency gains compared to
existing coal plants. In addition, efficiency gains associated with the CCCT lead to lower
emissions compared to SCCTs.

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Figure 2 Combined-Cycle Gas Turbine

2.4 Capital and Installation Costs

Table 3 presents capital cost estimates for several types of utility-scale gas turbine
power plants. These estimates are discussed in more detail in Gas Turbine World (2023)
and are based on estimates in U.S. EIA (2020a). Because these estimates are for power
plants, they include the cost of generators, natural gas pipelines, and electrical grid
hookups that are not applicable for all combustion turbine uses. However, these estimates
provide some insight as to the overall cost of combustion turbines.

The first industrial gas turbine began operation in 1939, and the technology has
undergone constant improvement since then. Table 3 shows the capital cost for three types
of turbines, under the broader categories of simple cycle and combined cycle turbines
discussed previously: Aeroderivative, F-Class, and H-Class. Aeroderivative turbines are
lightweight and compact designs adapted from aircraft jet engines. The F-Class turbine was
developed during the 1980s and began to be used in commercial operations in the early
1990s (Eldrid et al., 2001). The H-Class turbine is a more efficient design with a higher

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pressure ratio and higher firing temperature that was introduced in 1995 (Matta et al.,
2000).

Table 3 Utility-scale Gas Turbine Power Plant Capital Cost Estimates (million
2022$ unless otherwise noted)



Simple Cycle

Combined Cycle



100 MW

240 MW

430 MW

1100 MW



Aeroderivative

F-Class

H-Class

H-Class

Engineering, Procurement, and Construction Costs (EPC)

Civil/Structural/Architectural

7.7

15.0

38.1

73.6

Mechanical - Major Equipment

52.8

65.7

159.7

360.8

Mechanical - Balance of Plant

12.0

20.9

89.7

240.5

Electrical

18.7

24.6

34.4

114.1

Project Indirect Costs

18.3

23.0

98.2

184.1

EPC Contracting Fee

10.9

14.9

42.0

97.3

Owner's Costs

Owner's Services

8.4

11.5

32.4

74.9

Land Acquisition

0.7

0.7

2.1

2.1

Electrical Interconnection

1.5

1.5

2.2

3.0

Gas Pipeline Interconnection

5.5

5.5

7.2

7.2

Project Contingency

13.6

18.3

50.6

115.8

Total Plant Cost

150.1

201.6

556.4

1,273.3

Net Plant Rating (kW]

105,100

232,600

418,399

1,083,300

Net Plant Efficiency

41.5%

38.2%

58.9%

59.4%

Installed $/kW

1,428

867

1,330

1,175

Source: Gas Turbine World 2023 Handbook

The capital cost estimates presented in Table 3 are intended to represent a complete
power plant facility on a generic site at a non-specific U.S. location. The
civil/structural/architectural cost includes labor and material for site preparation,
foundations, piling structural steel, and buildings. The major mechanical equipment cost
includes all costs associated with the supply and installation of the turbines and boilers
(where applicable), while the balance of plant mechanical cost includes costs associated
with the supply and installation of pumps and tanks, piping valves, and other necessary
equipment. The electrical cost includes all costs associated with the supply and installation
of generators, transformers, control systems, and other necessary electrical equipment.
Project indirect costs include plant engineering, construction management, and start-up

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and commissioning, as well as contractor fees, overhead, and profit. Owner's costs include
project development, land acquisition, and utility interconnections. A project contingency is
included to account for cost uncertainties (Gas Turbine World, 2023; U.S. EIA, 2020a).

2.5 Affected Producers

As discussed in Section 1.5, the sources subject to the NSPS are stationary
combustion turbines with a heat input at peak load equal to or greater than 10.7 GJ/h (10
MMBtu/h), based on the higher heating value (HHV) of the fuel, that commence
construction, modification, or reconstruction after the publication of the proposed rule in
the Federal Register. This rule applied to any industry using a new stationary combustion
turbine as defined in Section 1.4.

To understand the industries likely to be impacted by this rule, current turbines in
the National Emission Inventory (NEI) were identified. While the design capacity is not
always reported in the National Emission Inventory (NEI), the units identified as
combustion turbines in the 2020 NEI and having a valid design capacity of greater than 10
MMBtu/h or equivalent are summarized in Table 4 by North American Industry
Classification System (NAICS) code (U.S. OMB, 2022).

Table 4 Combustion Turbines over 10 MMBtu/h or equivalent by NAICS code

NAICS

Description

# of Units

# of Facilities

2111

Oil and Gas Extraction

433

132

2211

Electric Power Generation, Transmission and Distribution

2711

968

2212

Natural Gas Distribution

100

26

2213

Water, Sewage and Other Systems

25

15

3112

Grain and Oilseed Milling

7

5

3221

Pulp, Paper, and Paperboard Mills

20

15

3241

Petroleum and Coal Products Manufacturing

38

13

3251

Basic Chemical Manufacturing

93

26

3252

Resin, Synthetic Rubber, and Artificial and Synthetic Fibers and Filaments
Manufacturing

29

11

3253

Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing

9

6

3254

Pharmaceutical and Medicine Manufacturing

9

7

3259

Other Chemical Product and Preparation Manufacturing

8

4

4861

Pipeline Transportation of Crude Oil

7

4

4862

Pipeline Transportation of Natural Gas

650

329

4869

Other Pipeline Transportation

7

4

4881

Support Activities for Air Transportation

5

3

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NAICS

Description

# of Units

# of Facilities

5171

Wired and Wireless Telecommunications (except Satellite]

20

18

5182

Computing Infrastructure Providers, Data Processing, Web Hosting, and
Related Services

5

3

5241

Insurance Carriers

8

2

5311

Lessors of Real Estate

11

3

5622

Waste Treatment and Disposal

22

9

6113

Colleges, Universities, and Professional Schools

52

36

6221

General Medical and Surgical Hospitals

17

14

9241

Administration of Environmental Quality Programs

5

2

9281

National Security and International Affairs

7

7

-

Other industries with fewer than 5 turbines per industry

67

53

Total



4365

1715

Five of these NAICS codes account for over 90 percent of the turbines in the 2020
NEI. They are 2111 (Oil and Gas Extraction), 2211 (Electric Power Generation,
Transmission and Distribution), 2212 (Natural Gas Distribution), 3251 (Basic Chemical
Manufacturing), and 4862 (Pipeline Transportation of Natural Gas). The NAICS codes serve
as a guide for readers outlining the entities that this action is likely to affect. The standards,
once promulgated, will be directly applicable to affected facilities that begin construction,
reconstruction, or modification after the date of publication of the proposed standards in
the Federal Register.

NAICS 2111 comprises establishments that operate and/or develop oil and gas field
properties. Operation and development activities include exploration for crude petroleum
and natural gas; drilling, completing, and equipping wells; operating separators, emulsion
breakers, desilting equipment, and field gathering lines for crude petroleum and natural
gas; and all other activities in the preparation of oil and gas up to the point of shipment
from the producing property. This subsector includes the production of crude petroleum,
the mining and extraction of oil from oil shale and oil sands, the production of natural gas,
sulfur recovery from natural gas, and recovery of hydrocarbon liquids. Establishments in
this subsector include those that operate oil and gas wells on their own account or for
others on a contract or fee basis.

NAICS 2211 comprises establishments primarily engaged in generating,
transmitting, and/or distributing electric power. Establishments in this industry group may

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perform one or more of the following activities: (1) operate generation facilities that
produce electric energy; (2) operate transmission systems that convey the electricity from
the generation facility to the distribution system; and (3) operate distribution systems that
convey electric power received from the generation facility or the transmission system to
the final consumer.

NAICS 2212 comprises: (1) establishments primarily engaged in operating gas
distribution systems (e.g., mains, meters); (2) establishments known as gas marketers that
buy gas from the well and sell it to a distribution system; (3) establishments known as gas
brokers or agents that arrange the sale of gas over gas distribution systems operated by
others; and (4) establishments primarily engaged in transmitting and distributing gas to
final consumers.

NAICS 3251 comprises establishments primarily engaged in manufacturing
chemicals using basic processes, such as thermal cracking and distillation. Chemicals
manufactured in this industry group are usually separate chemical elements or separate
chemically-defined compounds.

NAICS 4862 comprises establishments primarily engaged in the pipeline
transportation of natural gas from processing plants to local distribution systems. This
industry includes the storage of natural gas because the storage is usually done by the
pipeline establishment and because a pipeline is inherently a network in which all the
nodes are interdependent.

The total number of firms and establishments in these five NAICS, as well as their
employment and annual payroll are summarized in Table 5 below. The information in
Table 5 is not meant to serve as an exhaustive presentation for each affected industry but is
instead meant to serve as a high-level summary of potentially relevant information for
these industries.

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Table 5 Number of Firms and Establishments, Employment, and Annual Payroll for
Affected Industries: 2021

NAICS

NAICS Description

Firms

Establishments

Employment

Annual
Payroll
($1,000)

2111

Oil and Gas Extraction

4,337

5,444

88,532

13,164,547

2211

Electric Power Generation, Transmission and Distribution

2,227

12,481

497,375

61,888,671

2212

Natural Gas Distribution

429

2,441

89,775

9,682,205

3251

Basic Chemical Manufacturing

1,245

2,438

154,491

15,922,408

4862

Pipeline Transportation of Natural Gas

117

2,068

26,263

3,274,407

Source: U.S. Census Bureau, 2021 Statistics of U.S. Businesses (U.S. Census Bureau, 2023].

2.6 Projected Growth of Combustion Turbines

Because the date of construction is not available in the NEI and is often not reported
to the EPA Emissions Inventory System (EIS), a separate turbine dataset was created to
assess the number of new turbines constructed within the past five years. This dataset was
created using Form EIA-860 survey data from the Energy Information Administration, the
EPA's Clean Air Markets Program Data (CAMPD), the EPA's National Electric Energy Data
System (NEEDS) database, and existing major sources subject to the National Emission
Standards for Hazardous Air Pollutants (NESHAP) for stationary combustion turbines. A
permit review was also conducted to confirm the construction date and installed emissions
controls for these units. Form EIA-860 collects unit-level information about existing and
planned units and associated environmental equipment at electric power plants with 1
megawatt or greater of combined nameplate capacity. Combustion turbines that are
connected to a generator larger than 250 MMBtu/h generally report emissions and control
technology information to the EPA. The EPA reviewed the reported NOx control technology
from the CAMPD for combustion turbines that commenced operation between 2020 and
2024. NEEDS is an EPA database of electric generators that serves as a resource for
modeling the sector. NEEDS includes source information about existing and planned units,
information about the combustion turbines themselves, and data about their air emissions.
The list of sources compiled for the EPA's review of the NESHAP only includes combustion
turbines that are major sources of toxic air emissions, including industrial sources that do
not appear in NEEDS, CAMPD, or the Form EIA-860 survey data. This dataset was
supplemented with an estimate of the number of new stationary combustion turbines at

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non-major sources, for which we have limited information. The development of this dataset
is discussed in greater detail in the Technical Support Document titled, Combustion Turbine
Inventory and NOx Control Technology Baseline, available in the docket for this rule.

Based on this combined dataset, 221 combustion turbines that would have been
subject to this rule if constructed after this NSPS proposal were constructed within the past
5 years. Electricity Generating Units (EGU) account for approximately 60 percent of the
new units over this timeframe, while industrial sources comprise the remaining
installations. The types of these units and their installed controls are summarized in Table
6.

Table 6 Types of Combustion Turbines Constructed 2020-2024 and Installed
Controls

Number of Number of Number of Number of



Turbine Type



Turbines

Turbines
with SCR

Turbines
with DLN

Turbines
with WI

Electricity
Generating
Units

< 850 MMBtu/h

Simple Cycle
Combined Cycle

77
5

69
5

8
5

52
0

> 850 MMBtu/h

Simple Cycle
Combined Cycle

21
29

4
29

20
27

7
0

Industrial
Sources

< 25 MW

Simple Cycle
Combined Cycle

20
10

2
5

2
8

5
0

> 25 MW

Simple Cycle
Combined Cycle

4
3

1

3

2
0

0
0



Direct Mechanical Drive

Simple Cycle

52

0

5

0

Total



Simple Cycle
Combined Cycle

174
47

76
42

37
40

64
0

Note: Number of controls likely underestimated for industrial sources due to incomplete information. SCR= Selective
Catalytic Reduction, DLN = Dry Low NOx Burners, and WI = Water Injection.

The EPA has used this combined dataset to estimate the potential number of new
combustion turbines that would be affected by this rule and the additional NOx controls
they may be required to adopt. This distribution of new units is assumed to continue in
future years, with the number of new units in each future year calculated as the average of
new units over the 2020-2024 period. However, this combined dataset is a selected sample,
which may not be representative of the entire population of combustion turbines in the
future. In particular, it has greater representation of larger combustion turbines and those
in the electricity sector relative to the general population of combustion turbines. Also,

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using this recent historical data to project future turbine construction may not fully reflect
projected trends, such as recent increases in turbine demand from data centers and the
electric power sector broadly. For example, in the 2025 Annual Energy Outlook, the U.S.
Energy Information Administration projects over 200 GW of new combustion turbine
capacity by 2050 (U.S. EIA, 2025), and industry sources have indicated large increases in
turbine demand since 2022 (e.g., Anderson, 2025).

Nonetheless, because these data sets provide the best information regarding
turbines to date, the following analysis assumes that the units in this dataset are
representative of the population of combustion turbines that the EPA has limited
installation and pollution control information on—in particular smaller combustion
turbines and those used in industrial sectors—as sectors that employ turbines evolve in the
future. These data limitations and assumptions are potentially a notable source of
uncertainty in the following analysis of the benefits, costs, and other impacts of this final
rule.

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3 ENGINEERING COST ANALYSIS

3.1	Introduction

This chapter provides a summary of the cost analysis conducted for this rulemaking.
Section 3.2 describes the affected sources. Section 3.3 briefly describes the methodology
employed in the cost analysis and presents the results of that analysis. Section 3.4 discusses
the secondary impacts of the final rule, and Section 3.5 characterizes the uncertainty in the
cost estimates.

3.2	Affected Sources

As discussed in Section 1.5, sources subject to the NSPS are stationary combustion
turbines with a heat input at peak load equal to or greater than 10.7 GJ/h (10 MMBtu/h),
based on the higher heating value (HHV) of the fuel, that commence construction,
modification, or reconstruction after December 13, 2024, the date of publication of the
proposed standards in the Federal Register. To estimate the projected number of affected
combustion turbines in each year, the dataset described in Section 2.6 was used. Based on
this dataset and assuming the same distribution of units in future years, the number of
new, modified, or reconstructed stationary combustion turbines in each subcategory that
are expected in each year is presented in Table 7. These values were calculated by
rounding the per year estimates of new units over 2020-2024, which were reported in
Table 6. The number of combustion turbines that are expected to incur increased costs
relative to the baseline is estimated by comparing the emissions rates of units constructed
during 2020-2024 to the emissions limits that will be required under this final rule. In this
comparison, units that are unable to meet the revised limit under the final rule are
estimated to need emissions controls if the same type of unit is constructed in the future
under the revised NSPS. We do not expect additional investment above the average rate
from 2020-2024 as a result of this rule. Uncertainties and limitations of this approach are
discussed in Section 2.6 above.

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Table 7 Estimated Number of New, Modified, or Reconstructed Turbines in Each
Year



Turbine Type



New Units per Year

New Units per Year
Expected to Incur
Increased Costs Relative
to Baseline

Electricity
Generating
Units

< 850 MMBtu/h

Simple Cycle
Combined Cycle

15
1

0
0

> 850 MMBtu/h

Simple Cycle
Combined Cycle

4
6

0

1

Industrial
Sources

< 25 MW

Simple Cycle
Combined Cycle

4
2

1
0

> 25 MW

Simple Cycle
Combined Cycle

1
1

1
0



Direct Mechanical Drive

Simple Cycle

10

0

Total



Simple Cycle
Combined Cycle

35
9

2
1

For these affected combustion turbines, the NSPS BSER discussed in Section 1.5 is
the use of combustion controls (i.e., without SCR) for all but one subcategory of new,
modified, or reconstructed stationary combustion turbines. For that one subcategory—
new large turbines with high rates of utilization (i.e., a 12-calendar-month capacity factor
greater than 45 percent)—the BSER is combustion controls with SCR. The SCR process is
based on the chemical reduction of the NOx molecule via a nitrogen-based reducing agent
(reagent) and a solid catalyst. To remove NOx, the reagent, commonly ammonia (NH3,
anhydrous and aqueous) or urea-derived ammonia, is injected into the post-combustion
flue gas of the combustion turbine. The reagent reacts selectively with the flue gas NOx
within a specific temperature range and in the presence of the catalyst and oxygen to
reduce the NOx into molecular nitrogen (N2) and water vapor (H2O). SCR employs a
ceramic honeycomb or metal-based surface with activated catalytic sites to increase the
rate of the reduction reaction. Over time, however, the catalyst activity decreases, requiring
replacement, washing/cleaning, rejuvenation, or regeneration to extend the life of the
catalyst. Catalyst designs and formulations are generally proprietary. The primary
components of the SCR include the ammonia storage and delivery system, ammonia
injection grid, and the catalyst reactor.

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3.3 Capital Investment, Annual Costs, and Emissions Reductions

To comply with the requirements of this rule, some units will incur capital costs
associated with the installation of advanced combustion controls or upgrades to the
controls that would have been installed, while some units are expected to incur increased
operating costs of their controls to meet the requirements. Because SCR has been nearly
universally adopted in recent years within the subcategory for which the BSER is
combustion controls with SCR, affected units in this subcategory are not expected to incur
additional capital costs associated with the installation of SCR as a result of this rule.

The capital and increased operating costs were estimated based on model plants
from NETL (2023). The development of these cost estimates is discussed in detail in the
Technical Support Document titled NOx Mitigation Measures - Selective Catalytic Reduction
for Combustion Turbines, available in the docket for this rule. While the NSPS BSER for
smaller turbines is the use of combustion controls, data limitations did not permit the
calculation of the costs of advanced combustion controls for these units. As a result, the
costs for these units presented in this EIA instead are representative of the costs associated
with the application of SCR on these units. For this reason, the costs and related secondary
impacts for each affected turbine are likely over-estimated.

For the proposed rule, we selected an 8-year analysis period to align with the NSPS
review timing in CAA Section 111(B)(1)(b) and estimated compliance would begin in 2027,
reflecting the time required to complete the construction of a new, modified, or
reconstructed turbine.5 For this final rule, we maintain these assumptions for the sake of
comparability, while acknowledging that this methodology does not account for the entire
stream of operation and maintenance costs over the lifetime of the equipment, or emission
reductions that continue beyond the analysis period. Table 8 summarizes for the period
2025-2032 the number of units expected to be subject to the NSPS, the number of units
expected to incur increased costs relative to the baseline, and the annual NOx emission
changes. The NOx emission decreases from subcategories with increased stringency are

5 Note the EPA used a 30-year useful life when evaluating the BSER and in the consideration of capital
expenditures.

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expected to be partially offset by NOx emission increases from subcategories with
decreased stringency.

Table 8 Summary of Estimated Affected Units and Emission Reductions in First 8
Years After the Rule is Final

Year

Cumulative
New Units
Subject to
NSPS

Cumulative Units
with Increased
Costs Relative to
Baseline

Annual NOx
Emission Changes

Relative to
Baseline (tons) in
Subcategories with
Increased
Stringency

Annual NOx
Emission Changes

Relative to
Baseline (tons) in
Subcategories
with Decreased
Stringency

Net Annual NOx
Emission Changes
Relative to
Baseline (tons)

2025

0

0

0

0 to 0

0 to 0

2026

0

0

0

0 to 0

0 to 0

2027

16

1

-6

47 to 94

41 to 88

2028

61

3

-120

94 to 188

-26 to 68

2029

105

5

-235

141 to 282

-94 to 47

2030

149

8

-349

188 to 376

-161 to 27

2031

193

10

-464

235 to 469

-229 to 5

2032

237

12

-578

282 to 563

-296 to-15

Note: Values may not sum due to rounding. The ranges reflect the assumption of 2 to 4 high efficiency turbines

constructed during the analysis period.

Table 9 summarizes the undiscounted and discounted total annual cost over the
period 2025-2032. For this analysis, it is assumed that the capital cost is completely
incurred in the first year of operation. This is a conservative approach, as capital costs are
often financed over several years.

Table 9 Summary of Estimated Costs for Subcategories with Increased Stringency
in First 8 Years After the Rule is Final

Undiscounted Costs

Total Annual Cost Discounted to
2024

Year

Unannualized
Capital Cost
(million 2024$)

O&M Cost
(million 2024$)

Total Annual Cost
(million 2024$)

3% Discount
Rate

7% Discount
Rate

2025

$0

$0

$0

$0

$0

2026

$0

$0

$0

$0

$0

2027

$0.96

$0.05

$1.01

$0.93

$0.83

2028

$2.55

$0.67

$3.22

$2.86

$2.46

2029

$2.55

$1.28

$3.84

$3.31

$2.74

2030

$2.55

$1.90

$4.45

$3.73

$2.97

2031

$2.55

$2.52

$5.07

$4.12

$3.16

2032

$2.55

$3.13

$5.68

$4.49

$3.31

Note: Values rounded to three significant figures.

28


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Table 10 reports the 2024 present value and equivalent annualized value of the
costs shown in Table 9 at 3 percent and 7 percent discount rates.

Table 10 2024 Present Value and Equivalent Annualized Value of Estimated Costs
for Subcategories with Increased Stringency in First 8 Years After the Rule
is Final (million 2024$)



3% Discount Rate

7% Discount Rate

Present Value

$19.4

$15.5

Equivalent Annualized Value

$2.77

$2.59

Note: Values rounded to three significant figures.

Additionally, there is a deregulatoiy aspect of this rule. Under this final rule, new
natural gas-fired combustion turbines with a base load rated heat input of greater than 850
MMBtu/h, operating at low levels of utilization (i.e., less than or equal to a 12-calendar-
month capacity factor of 45 percent), and with a design efficiency greater than or equal to
38 percent will face a less stringent NOx emission limit than they would have faced under
the existing standard. While the standard is less stringent in subpart KKKKa than in the
existing subpart KKKK for these specific types of turbines, when subpart KKKK was
promulgated in 2006, these types of turbines did not exist. They are a newer technology
that is now commercially available, and the new NSPS seeks to recognize this fact along
with the fact that they are highly efficient.

To account for the rule accommodating these high-efficiency turbines, we conduct
an additional analysis where we compare the construction and operations of these high-
efficiency turbines under the final rule to a baseline where low-efficiency turbines
compliant with the current 2006 standards are constructed instead. However, this analysis
also takes into account improvements in combustion turbines that have occurred since the
promulgation of the 2006 NSPS. Based on EPA's market research, we use a 9-ppm low-
efficiency combustion turbine as the baseline, which is better performing than the 15 ppm
NOx emission standard required under the 2006 NSPS. How many new turbines will take
advantage of this subcategory in the future is uncertain, so we assume two to four turbines
are constructed for each 5-year period beginning in 2027. Specifically, EPA has identified
28 frame-type combustion turbines that have commenced operation in the previous 5
years. One of these turbines was a large high-efficiency combustion turbine with SCR
controls. An additional six large turbines completed during this period have comparable or

29


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higher utilization rates. EPA presumes that a subset of these turbines would have
considered the new large, high-efficiency subcategory had it been available. Therefore, EPA
identified two to four turbines per 5-year period as a likely range for the rate of new
turbines availing themselves of this high-efficiency subcategory. We also assume that each
turbine has a capacity of 370 MW; high-efficiency turbines have 2 percent higher capital
costs; there is no difference in non-fuel operating and maintenance costs; high-efficiency
turbines have 38.8 percent efficiency; and low-efficiency turbines have 34.4 percent
efficiency; and delivered natural gas prices are $3.43/MMBtu.6 We also assume that the
turbines are utilized at 15 percent capacity factor over a 30-year turbine lifespan. While
many simple cycle turbines operate at capacity factors below 10 percent, the subcategory
for high-efficiency turbines in the final rule accommodates utilization up to 45 percent, and
presumably, operators installing large, high-efficiency turbines plan to operate them more
than the typical simple cycle. Other assumptions and methodology are documented in the
Excel workbook titled Turbines NSPS Final Cost Summary 122225.xlsx, available in the
docket for this rule.

Although we assume that the higher-efficiency turbines have more expensive capital
costs, the fuel savings lead to overall cost savings for the turbine operators as shown in
Table 11. However, the higher-efficiency turbines also have higher NOx emissions relative
to the baseline with low-efficiency turbines. More turbines constructed in this subcategory
or higher utilization than assumed in this analysis could increase the avoided costs of this
subcategory above the regulatory costs associated presented in Table 10.

6 As discussed in the preamble, available models of high-efficiency turbines have capacities ranging from
330 to 450 MW. The 2 percent higher capital costs are based on the difference in capital costs in year 2028
of the NREL ATB projection between F-class and H-class turbine configurations. EPA found an average
efficiency of 34.5 percent among 9 models of low-efficiency turbines and an average efficiency of 38.8
percent among 8 models of high-efficiency turbines. This $3.43/MMBtu natural gas price is based on the
AEO 2025 projection of delivered prices to the power sector in 2030.

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Table 11 Summary of Estimated Costs Associated with Large, High-Efficiency
Turbines in First 8 Years After the Rule is Final

Capital and Avoided Fuel Costs

Net Avoided Costs
Discounted to 2024

Year

Unannualized
Capital Costs
(million 2024$)

Avoided Fuel Costs

(million 2024$,
present values, 3%
discount rate)

Avoided Fuel
Costs (million
2024$, present

values, 7%
discount rate)

3% Discount
Rate
(million 2024$)

7% Discount
Rate
(million 2024$)

2025	$0.00 to	$0.00	$0.00	to

2026	$0.00 to	$0.00	$0.00	to

2027	$3.91 to	$7.83	$14.33	to

2028	$3.91 to	$7.83	$14.33	to $28

2029	$3.91 to	$7.83	$14.33	to $28

2030	$3.91 to	$7.83	$14.33	to $28

2031	$3.91 to	$7.83	$14.33	to $28

2032	$3.91 to	$7.83	$14.33	to $28.66

$0.00
$0.00
$28.66
66
66
66
66

$0.00	to

$0.00	to

$9.07	to

$9.07	to

$9.07	to

$9.07	to

$9.07	to

$9.07	to

$0.00
$0.00
$18.14

$18
$18
$18
$18

14
14
14
14

$18.14

$0.00	to

$0.00	to

$9.53	to

$9.26	to

$8.99	to

$8.72	to

$8.47	to

$8.22	to

$0.00

$0.00

$19.07

$18.51

$17.97

$17.45

$16.94

$16.45

$0.00
$0.00
$4.21
$3.94
$3.68
$3.44
$3.21
$3.00

to
to
to
to
to
to
to
to

$0.00
$0.00
$8.42
$7.87
$7.36
$6.88
$6.43
$6.01

Note: Values are rounded to three significant figures. Ranges reflect the assumption of 2 to 4 high efficiency turbines
constructed during the analysis period. The avoided fuel costs account for fuel savings over an entire 30-year
lifespan for each of the turbines constructed between 2025 and 2032. The present values of these fuel savings in
the third and fourth columns are the present values in the year each turbine is constructed. The fifth and sixth
columns then discount the net costs back to 2024, the year of analysis.

Table 12 reports the 2024 present value and equivalent annualized value of the costs
shown in Table 11 at 3 percent and 7 percent discount rates.

Table 12 2024 Present Value and Equivalent Annualized Value of Net Avoided Costs
Associated with Large, High-Efficiency Turbines in First 8 Years After the
Rule is Final (million 2024$)



3% Discount Rate

7% Discount Rate

Present Value

$53.2 to $106

$21.5 to $43.0

Equivalent Annualized Value

$7.58 to $15.2

$3.60 to $7.19

Note: Values rounded to three significant figures. The range reflects the assumption of 2 to 4 high efficiency turbines
constructed during the analysis period.

Table 13 summarizes the estimated costs and cost savings associated with this rule.
Using both 3 and 7 percent discount rates, this rule is estimated to be cost saving.

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Table 13 Summary of Estimated Costs for the Final NSPS for Combustion Turbines
from 2025 to 2032 (millions, 2024$)





3% Discount Rate

7% Discount Rate





PV EAV

PV

EAV

Impacts associated with
subcategories with increased
stringency

Costs

$19.4 $2.77

$15.5

$2.59

Impacts associated with
subcategories with decreased
stringency

Avoided
Costs

$53.2 to $106.4 $7.58 to $15.2

$21.5 to $43.0

$3.60 to $7.19

Net Costs



-$87.0 to-$33.8 -$12.4 to-$4.81

-$27.5 to -$5.98

-$4.60 to-$1.01

Note: Values rounded to three significant figures. The range reflects the assumption of 2 to 4 high efficiency turbines

constructed during the analysis period.

3.4 Secondary Impacts

SCR uses ammonia as a reactant and some ammonia is emitting either by passing
through the catalyst bed without reacting with NOx (unreacted ammonia) or passing
around the catalyst bed through leaks in the seals around the catalysts bed. Both of these
combined are referred to ammonia slip. Ammonia is a precursor to fine particulate matter.
Ammonia slip increases as catalysts beds age and is often limited to 10 ppm or less in
operating permits. Ammonia catalysts are available to reduce emissions of ammonia. The
ammonia catalyst consists of an additional catalysts bed after the SCR catalyst that reacts
with the ammonia that passes through and around the catalyst to reduce overall ammonia
slip. In the NETL (2023) model plants used in the EPA's analysis, no additional ammonia
catalyst was included, and ammonia emissions were limited to 10 ppm at the end of the
catalysts' life. For estimating secondary impacts, the EPA assumed average ammonia
emissions of 3.5 ppm based on information from the EPA Air Pollution Control Cost Manual
(U.S. EPA, 2017a).7 The EPA estimates that for each ton of NOx controlled 0.10 tons of
ammonia are emitted.

7 The EPA Control Cost Manual (U.S. EPA, 2017a) notes that ammonia slip refers to the excess reagent
passing through the reactor. Ammonia in the flue gas causes a number of problems, including health
effects, visibility of the stack effluent, salability of the fly ash, and the formation of ammonium sulfates.
Limits on acceptable ammonia slip, imposed by either regulatory limits or by design requirements, place
constraints on SCR performance. Ammonia slip does not remain constant as the SCR system operates but
increases as the catalyst activity decreases. Properly designed SCR systems, which operate close to the
theoretical stoichiometry and supply adequate catalyst volume, maintain low ammonia slip levels,
approximately 2 to 5 ppm. The 3.5 ppm value used in this analysis reflects the midpoint of this range.

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SCR also reduces the efficiency of a combustion turbine through the
auxiliary/parasitic load requirements to run the SCR and the backpressure created from
the catalyst bed. The EPA used the auxiliary load required by the SCR that was directly
provided in the NETL (2023) report and estimated the loss in output from operation of the
SCR due to backpressure as 0.3 percent of the gross output. The overall result is a reduction
in efficiency of 0.3 percent.

Table 14 summarizes the estimated increases in ammonia emissions with applied
SCR. As previously noted, for purposes of this analysis the estimated reductions on
industrial sources are assumed to be achieved through the application of SCR, given the
lack of data on combustion control costs. Compliance in many cases will likely be achieved
through combustion controls, which would lead to reduced ammonia emissions compared
to these estimates.

Table 14 Estimated Increased Ammonia Emissions Associated with NOx Emission
Reductions with Applied SCR

Year

Ammonia
(tons)

2025

0

2026

0

2027

1

2028

12

2029

22

2030

33

2031

44

2032

54

3.5 Characterization of Uncertainty

It is important to note that the cost estimates presented in this chapter are subject
to multiple sources of uncertainty. The rule does not dictate that any particular controls
must be installed to control pollutants, but rather that new, modified, and reconstructed
combustion turbines must meet emission standards consistent with the BSER for that unit.
If the owners of affected units are able to find alternative, less costly methods to comply,
then the costs presented in this EIA may be overestimated. Further uncertainties and
limitations around the projections of future turbine demand are discussed in Section 2.6.

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4 BENEFITS OF EMISSIONS REDUCTIONS

4.1 Introduction

The pollutants regulated by the combustion turbines NSPS are NOx and SO2. The
health effects of exposure to these pollutants are briefly discussed in this section. Section
3.4 discusses the secondary impacts of this rule, and the projected increases in emissions of
ammonia.

The EPA is obligated to present the Agency's best scientific understanding when
developing policies and regulations and to ensure the public is not misled regarding the
level of scientific understanding. Historically, however, the EPA's analytical practices often
provided the public with a false sense of precision and more confidence regarding the
monetized impacts of fine particulate matter (PM2.5) and ozone than the underlying science
could fully support, especially as overall emissions have significantly decreased, and
impacts have become more uncertain. The EPA has seen the uncertainties expand even
further with the use of benefit-per-ton (BPT) monetized values. Although intended as a
screening tool when full-form photochemical modeling was not feasible, the BPT approach
reduces complex spatial and atmospheric relationships into an average value per ton,
which magnifies uncertainty in the resulting monetized estimates. Examples of
uncertainties include but are not limited to: epidemiological uncertainty [e.g.,
concentration-response functions, mortality valuation); economic factors [e.g., discount
rates, income growth); and methodological assumptions [e.g., health thresholds, linear
relationships, spatial relationships).

However, the EPA historically provided point estimates instead of just ranges or
only quantifying emissions, which leads the public to believe the Agency has a better
understanding of the monetized impacts of exposure to PM2.5 and ozone than in reality.
Therefore, to rectify this error, the EPA is no longer monetizing benefits from PM2.5 and
ozone but will continue to quantify the emissions until the Agency is confident enough in
the modeling to properly monetize those impacts.

Historically, the EPA estimated the monetized benefits of avoided PM2.5- and ozone-
related impacts, which accounted for most, if not all, of the monetized benefits of many air

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regulations-even when the regulation was not regulating PM2.5 or ozone-within Regulatory
Impact Analyses (RIAs).8 Throughout these analyses, the EPA acknowledged significant
uncertainties related to monetized PM2.5 and ozone impacts. The EPA has and is
considering various techniques for characterizing the uncertainty in such estimates, such
as estimating the fraction of avoided health effects occurring at various concentration
ranges, sensitivity analyses, and alternate concentration-response assumptions. Because of
the significant impacts of environmental regulations on the U.S. economy, it is essential that
the Agency have confidence in the estimated benefits of an action prior to utilizing these
estimates in a regulatory context.

In particular, the EPA is interested in evaluating the validity of estimating the
benefits of air quality improvements relative to the National Ambient Air Quality Standards
(NAAQS) for PM2.5 and ozone. These standards, which have been set at a level which the
Administrator judges to be requisite to protect public health or welfare with an adequate
margin of safety, are widely understood to represent the divide between clean air and air
with an unacceptable level of pollution.

The limitations of the BPT approach are even more pronounced due to the
compounding effects of emissions reductions typically occurring across many geographic
areas simultaneously, with varying proximity to population centers; differing atmospheric
transformation pathways for nitrous oxides (NOx), Volatile Organic Compounds (VOCs),
and secondary PM2.5; and region-specific photochemical and meteorological conditions.
Using a national BPT estimate implicitly assumes uniform marginal health benefits for each
ton of reduced emissions, an assumption not supported given heterogeneity in exposure
patterns and atmospheric chemistry. As more areas achieve or maintain attainment with
the NAAQS, the uncertainties associated with low-concentration health effects grow, and
marginal benefits become more difficult to characterize with precision.

8 See OMB's 2017 Report to Congress on Benefits and Costs of Federal Regulations and Agency Compliance
with the Unfunded Mandates Reform Act for fuller discussion on uncertainties, available at
https://trumpwhitehouse.archives.gov/wp-content/uploads/2019/12/2019-CATS-5885-REV_DOC-
2017Cost_BenefitReportll_18_2019.docx.pdf.

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Therefore, it may be appropriate for the EPA to separate exposures and impacts
above the level of the standard from those occurring at lower ambient concentrations. The
EPA will investigate this prior to estimating these impacts in a regulatory analysis even for
informational purposes. The EPA will seek peer review for new methods developed from
this work consistent with the OMB's Peer Review Guidance.9

4.2 Benefits of Nitrogen Oxide Reductions

Nitrogen dioxide (NO2) is the criteria pollutant that is central to the formation of
nitrogen oxides (NOx), and NOx emissions are a precursor to ozone and fine particulate
matter. Based on many recent studies discussed in the ozone Integrated Science
Assessment (ISA), the EPA has identified several key health effects that may be associated
with exposure to elevated levels of ozone (U.S. EPA, 2020a). Exposures to high ambient
ozone concentrations have been linked to increased hospital admissions and emergency
room visits for respiratory problems. Repeated exposure to ozone may increase
susceptibility to respiratory infection and lung inflammation and can aggravate preexisting
respiratory disease, such as asthma. Prolonged exposures can lead to inflammation of the
lung, impairment of lung defense mechanisms, and irreversible changes in lung structure,
which could in turn lead to premature aging of the lungs and/or chronic respiratory
illnesses such as emphysema, chronic bronchitis, and asthma.

Children typically have the highest ozone exposures since they are active outside
during the summer when ozone levels are the highest. Further, children are more at risk
than adults from the effects of ozone exposure because their respiratory systems are still
developing. Adults who are outdoors and moderately active during the summer months,
such as construction workers and other outdoor workers, also are among those with the
highest exposures. These individuals, as well as people with respiratory illnesses such as
asthma, especially children with asthma, experience reduced lung function and increased

9 OMB Memorandum M-05-03, Memorandum for the Heads of Executive Departments and Agencies:
Issuance of OMB's "Final Information Quality Bulletin for Peer Review" (2005), available at
https://www.federalregister.gOv/documents/2005/01/14/05-769/final-information-quality-bulletin-for-
peer-review.

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respiratory symptoms, such as chest pain and cough, when exposed to relatively low ozone
levels during periods of moderate exertion.

NOx emissions can react with ammonia, VOCs, and other compounds to form PM2.5
(U.S. EPA, 2019). Studies have linked PM2.5 (alone or in combination with other air
pollutants) with a series of negative health effects. Short-term exposure to PM2.5 has been
associated with premature mortality, increased hospital admissions, bronchitis, asthma
attacks, and other cardiovascular outcomes. Long-term exposure to PM2.5 has been
associated with premature death, particularly in people with chronic heart or lung disease.
Children, the elderly, and people with cardiopulmonary disease, such as asthma, are most
at risk from these health effects.

Reducing the emissions of NOx from stationary combustion turbines can help to
improve some of the effects mentioned above, either those directly related to NOx
emissions, or the effects of ozone and PM2.5 resulting from the combination of NOx with
other pollutants.

4.3 Benefits of Sulfur Dioxide Reductions

High concentrations of sulfur dioxide (SO2) can cause inflammation and irritation of
the respiratory system, especially during physical activity. Exposure to very high levels of
SO2 can lead to burning of the nose and throat, breathing difficulties, severe airway
obstruction, and can be life threatening. Long term exposure to persistent levels of SO2 can
lead to changes in lung function. Sensitive populations include asthmatics, individuals with
bronchitis or emphysema, children, and the elderly (U.S. EPA, 2017b). PM can also be
formed from SO2 emissions. Secondary PM is formed in the atmosphere through a number
of physical and chemical processes that transform gases, such as SO2, into particles. Overall,
emissions of SO2 can lead to some of the effects discussed in this section—either those
directly related to SO2 emissions, or the effects of PM resulting from the combination of SO2
with other pollutants. Further, SO2 emissions can lead to acid deposition, with adverse
effects on aquatic and terrestrial ecosystems (U.S. EPA, 2020b). Proposing to maintain the
standards of performance for emissions of SO2 from all stationary combustion turbines

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would continue to protect human health and the environment from the adverse effects
mentioned above.

4.4 Disbenefits from Increased Ammonia and NOx Emissions

Ammonia is a precursor to PM2.5 formation and an increase in NH3 formation may
lead to an increase in PM2.5. An increase in PM2.5 is associated with significant mortality and
morbidity health outcomes such as premature mortality, stroke, lung cancer, metabolic and
reproductive effects, among others.

There are also potential NOx disbenefits associated with the use of higher efficiency
combustion turbines. As previously noted, new natural gas-fired combustion turbines in
the large, low-utilization subcategory that are higher efficiency [i.e., with a base load rated
heat input greater than 850 MMBtu/h, operating at a 12-calendar-month capacity factor
less than or equal to 45 percent, and with a design efficiency greater than or equal to 38
percent) are subject to a less stringent NOx emission limit than otherwise applicable under
the previous NSPS (subpart KKKK). These higher NOx emissions create disbenefits relative
to the baseline with lower efficiency turbines.

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5 ECONOMIC AND SMALL BUSINESS IMPACTS

5.1	Introduction

This chapter presents the economic and small business impact analyses performed
for this rulemaking. Section 5.2 describes the screening analysis that was performed to
determine the impacts to small entities impacted by this final rule. Section 5.3 discusses the
potential economic impacts of this final rule, while Section 5.4 concludes with a discussion
of potential employment impacts of the final rule.

5.2	Screening Analysis

This section investigates characteristics of businesses and government entities that
are likely to install new combustion turbines affected by this final rule and provides a
screening-level analysis to assist in determining whether this final rule is likely to impose a
significant impact on a substantial number of the small businesses within this industry. The
analysis compares compliance costs to revenues at the ultimate parent company level. This
is known as the cost-to-revenue or cost-to-sales test, or the "sales test." The sales test is an
impact methodology the EPA employs in analyzing entity impacts as opposed to a "profits
test," in which annualized compliance costs are calculated as a share of profits. The sales
test is frequently used because revenues or sales data are commonly available for entities
impacted by the EPA regulations, and profits data normally made available are often not
the true profit earned by firms because of accounting and tax considerations. Also, the use
of a sales test for estimating small business impacts for a rulemaking is consistent with
guidance offered by the EPA on compliance with the Regulatory Flexibility Act (U.S. EPA,
2017c).

In this analysis, a small entity is defined as: (1) a small business as defined by the
Small Business Administration's (SBA) regulations at 13 CFR § 121.201; (2) a small
governmental jurisdiction that is a government of a city, county, town, school district or
special district with a population of less than 50,000; and (3) a small organization that is
any not-for-profit enterprise that is independently owned and operated and is not

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dominant in its field. For the purposes of the RFA, States and tribal governments are not
considered small governments.

Section 5.2.1 describes the process for identification of small entities, and the small
business impacts analysis is presented and discussed in Section 5.2.2.

5.2.1 Identification of Small Entities

As described in Section 3.2, the EPA projects that approximately 44 new, modified,
or reconstructed combustion turbines will begin operation each year. Approximately 3
sources are expected to incur additional costs associated with running their controls more.
No existing combustion turbines will be affected by the regulation. Because it is not
possible to project specific companies or government organizations that will purchase
combustion turbines in the future, the small entity screening analysis for the combustion
turbine rule is based on the evaluation of owners of combustion turbines constructed
within the past five years. It is assumed that the existing size and ownership distribution of
combustion turbines in this dataset is representative of the future growth in new
combustion turbines.

Excluding turbines with an ultimate owner of a state, local, or foreign government,
the ultimate owners of combustion turbines constructed within the past five years fall into
one of the NAICS codes in Table 15, which also presents the associated SBA small entity
size threshold for each NAICS code.10 These NAICS differ from the broader groups shown in
Table 4 because the NAICS code of the ultimate owner is based on the primary activity of
the company as a whole, while the NAICS code reported in the NEI is for a particular
facility.

10 The table of SBA's Small Business Size Standards is available at https://www.sba.gov/document/support-
table-size-standards (U.S. SBA, 2023).

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Table 15 Affected NAICS Codes and SBA Small Entity Size Standards

NAICS
Code

NAICS Industry Description

Size
standards in
millions of
dollars

Size
standards in
number of
employees

211120

Crude Petroleum Extraction



1,250

221112

Fossil Fuel Electric Power Generation



950

221118

Other Electric Power Generation



650

221122

Electric Power Distribution



1,100

221210

Natural Gas Distribution



1,150

237990

Other Heavy and Civil Engineering Construction

$45.0



322120

Paper Mills



1,250

322291

Sanitary Paper Product Manufacturing



1,500

322299

All Other Converted Paper Product Manufacturing



500

325193

Ethyl Alcohol Manufacturing



1,000

325211

Plastics Material and Resin Manufacturing



1,250

325412

Pharmaceutical Preparation Manufacturing



1,300

325520

Adhesive Manufacturing



550

424690

Other Chemical and Allied Products Merchant Wholesalers



175

424720
523910

Petroleum and Petroleum Products Merchant Wholesalers
(except Bulk Stations and Terminals]

Miscellaneous Intermediation

$47.0

200

524126

Direct Property and Casualty Insurance Carriers



1,500

525910

Open-End Investment Funds

$40.0



532411
541330

Commercial Air, Rail, and Water Transportation Equipment
Rental and Leasing
Engineering Services

$45.5
$25.5



541715
551112

Research and Development in the Physical, Engineering, and
Life Sciences (except Nanotechnology and Biotechnology]
Offices of Other Holding Companies

$45.5

1,000

611310

Colleges, Universities and Professional Schools

$34.5



622110

General Medical and Surgical Hospitals

$47.0



813110

Religious Organizations

$13.0



Source: U.S. SBA Table of Size Standards (March 17,2023) (U.S. SBA, 2023).

5.2.2 Small Business Impacts Analysis

Based on SBA criteria, 12 of the ultimate parent companies, owning 16 turbines (8.9
percent of the turbines constructed within the past 5 years), are small entities. One of the
municipalities owning turbines constructed within the past five years is considered small.
As shown in Table 7, three new affected units each year are expected to incur additional
costs. If we assume that 8.9 percent of these units expected to incur increased costs will be
owned by small entities, this implies that at most one of the three new affected units each

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year that are expected to incur additional costs will be owned by a small entity. The 11
small entities have an average sales value of approximately $478 million and a median
sales value of approximately $123 million. We compared the average annual total
compliance cost per unit in 2027 from Table 9 ($1.01 million) with the average sales for a
typical small entity and estimate that the cost to sales ratio for the potentially affected
small entity is 0.21 percent. Comparing the average annual total compliance cost per unit in
2027 from Table 9 ($1.01 million) with the median sales for a typical small entity, we
estimate that the cost to sales ratio for the potentially affected small entity is 0.82 percent.
The average sales value and median sales value are used due to uncertainty in the
individual values. Many of the small entities that have constructed turbines within the past
five years are privately held, and there is considerable uncertainty surrounding the sales
estimates provided for them by D&B Hoovers. There is also uncertainty regarding the
implicit assumption that the same types of small entities will construct turbines in the
future. Because the final rule would affect new sources, any additional costs should factor
into the decision to proceed with a project and could lead to a different type of project
being undertaken. Based on our analysis, there are no significant economic impacts on a
substantial number of small entities (SISNOSE) from this final rule.

It is important to note that the cost-to-sales ratio estimated in this analysis may be
overstated or understated depending on the accuracy of the information in the underlying
data on parent company ownership and parent company revenues in addition to the
accuracy of the estimate of increased operating costs. The annual sales values for ultimate
parent companies were derived from multiple sources, including D&B Hoovers, company
reports, and Securities and Exchange Commission (SEC) filings. However, as previously
noted, many of the small entities in this industry are privately held and do not publicly
report their sales, so there is considerable uncertainty regarding the accuracy of this data.
Furthermore, the assumption that the average sales of any new affected small entity will be
equal to the average sales of the existing small entities is a source of uncertainty.

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5.3	Economic Impacts

Economic impact analyses focus on changes in market prices and output levels. If
changes in market prices and output levels in the primary markets are significant enough,
impacts on other markets may also be examined. Both the magnitude of costs needed to
comply with a rule and the distribution of these costs among affected facilities can have a
role in determining how the market will change in response to a rule.

This final rule requires new, modified, or reconstructed stationary combustion
turbines to meet emission standards for the release of NOx into the environment. While the
units impacted by these requirements are expected to already have installed any required
emissions control devices, some units are expected to incur increased operating costs of
their controls to meet the final requirements. These changes may result in higher costs of
production for affected producers and impact broader markets these entities serve. As
shown in section 2.5, the types of turbines affected by this rulemaking are primarily used in
the power sector and in oil and natural gas transmission but are located in smaller
numbers in many economic sectors.

5.4	Employment Impacts

This section discusses employment impacts related to the rule. Employment impacts
of environmental regulations are generally composed of a mix of potential declines and
gains in different areas of the economy over time. Regulatory employment impacts can
vary across occupations, regions, and industries; by labor and product demand and supply
elasticities; and in response to other labor market conditions. Isolating such impacts is a
challenge, as they are difficult to disentangle from employment impacts caused by a wide
variety of ongoing, concurrent economic changes.

Economic theory indicates that the effect of environmental regulation on labor
demand is difficult to predict ex-ante: plants that face increased costs to comply with a new
environmental regulation may reduce output, which means fewer inputs are required than
previously, including labor; may make changes to their production process in a way that
favors or disfavors labor compared to other inputs such as capital; and may need labor to
engage in new compliance activities. As a result, plants affected by environmental

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regulation may increase their demand for some types of labor, decrease demand for other
types, or may even absorb compliance costs in a way that minimizes effects on labor.
(Berman and Bui, 2001; Deschenes, 2018; Morgenstern et al., 2002). To study the impacts
of environmental regulation on firms' demand for labor empirically, a growing literature
has compared employment levels at facilities subject to an environmental regulation to
employment levels at similar facilities not subject to that environmental regulation; some
studies find no employment effects, and others find significant differences. Employment
effects have been found to manifest in different ways across affected plants, such as shifting
workers across plants owned by the same firm, wage changes, job loss, and reduced hiring
(e.g., Ferris et al., 2014; Curtis, 2018). A recent discussion of labor demand channels and a
review of empirical literature is presented in Gray et al. (2023).

Considered across the economy and over the long run, environmental regulation is
expected to cause a shift of workers among employers rather than affect the general
employment level (Arrow et al., 1996, Hafstead and Williams, 2020). Employers facing a
new environmental rule are more likely to see reduced employment due to cost pressure,
while a movement of labor can occur towards jobs associated with pollution control or
production techniques unimpacted by the regulation. Even if net impacts on employment
are small after long-run market adjustments to full employment across the economy,
regulatory actions move workers in and out of locations, jobs and industries, which has an
important distributional impact (U.S. OMB, 2015; Walker, 2013). Transitional job losses in
the near term may also have greater consequences for workers that operate in declining
industries or occupations, have limited capacity to migrate, or live in communities or
regions with high unemployment rates.

As indicated by the potential impacts on industries using combustion turbines
discussed in Section 5.3, this final rule is not projected to cause large changes in those
industries. As a result, the labor employed in those industries, their upstream suppliers,
and their downstream customers are not expected to experience significant impacts due to
this final rule.

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United States	Office of Clean Air Programs	Publication No. EPA-452/R-26-002

Environmental Protection	Impacts & Ambient Standards Division	January 2026

Agency	Research Triangle Park, NC


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