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AQD | 2024 Revised Secondary (Welfare-Based) NAAQs for SO2

Air Quality Division

2024 Revised Secondary (Welfare-Based) National Ambient Air Quality Standard for SO2

Revised On: Feb. 14th, 2025 - 02:03 pm

On Dec. 10, 2024, the U.S. Environmental Protection Agency (EPA) strengthened the annual secondary (welfare-based) National Ambient Air Quality Standard (NAAQS) for sulfur dioxide (SO2), to be more protective of public welfare based on the latest available scientific evidence. Unlike primary NAAQS, which prioritize public health, secondary standards provide for protection of public welfare such as protection against decreased visibility and damage to animals, aquatic life, crops, vegetation, and buildings. Some sources of SO2 pollution include: fossil fuel fired power plants and industrial facilities; industrial processes such as extracting metal from ore; natural sources such as volcanoes; and locomotives, ships and other vehicles and heavy equipment that burn fuel with a high sulfur content. 

In this action, EPA revised the annual secondary (welfare-based) standard for SO2 from 0.5 parts per million (ppm) as a 3-hour average, not to be exceeded more than once in a year, to an annual standard with a level of 10 parts per billion (ppb), averaged over 3 years.

Read the full text of EPA’s final rule and learn more about the revised SO2 NAAQS | View >

When EPA releases a new or revised NAAQS, the Governor of each state is required to submit recommended boundary designations to EPA, identifying all areas of the state as:

  • Nonattainment (areas that do not meet the NAAQS, or areas that contribute to a nearby area not meeting the NAAQS), 
  • Attainment (areas that meet the NAAQS), or
  • Unclassifiable (areas that cannot be classified as attainment or nonattainment based on available information).  

The Arizona Governor’s recommendations for the 2024 revised annual secondary SO2 NAAQS are due to EPA by Dec. 10, 2025.

Pursuant to Arizona Revised Statutes (A.R.S.) § 49-405, ADEQ is the lead agency assisting the Arizona Governor in making the boundary recommendations. When developing the initial boundary recommendations, ADEQ will consider EPA’s five factors: air quality monitoring data, emissions and emissions-related data, meteorology, geography/topography, and jurisdictional boundaries. 

EPA will make the final decision regarding how areas are classified. If EPA decides that it is necessary to modify a state's recommendation, then EPA will notify the state at least 120 days prior to finalizing the area designations to allow the state an opportunity to comment on the potential modification. EPA has until Dec. 10, 2026, to finalize the initial area designations, unless there is insufficient information. In such circumstances, EPA may take up to one additional year to make the designation decisions (i.e., no later than three years after promulgation of the standard).

The timeline for developing the boundary recommendations is summarized in the following graphic for the 2024 revised annual SO2 secondary standard. 

image of a timeline

ADEQ welcomes interested parties to sign up to receive future updates and details on the boundary designations by subscribing to ADEQ’s Secondary SO2 Boundary Redesignation list. When selecting subscription topics, select Air Quality, proceed to the next page(s), select Other Air Quality Topics and then select "Secondary SO2 Boundary Redesignation" where listed | Subscribe >

Permitting and Other Impacts on Stationary Sources 

Stationary sources of SO2 emissions may be subject to additional control requirements as a result of the revised standard.

Existing Sources

  • Existing sources will not need to amend their current permits as a result of the new standard, unless they undertake a modification. 
  • However, if EPA designates nonattainment areas, and the nonattainment State Implementation Plan (SIP) development process is underway, air quality planning agencies will have to consider whether additional controls on existing stationary sources are necessary and should be included in the SIP.

New Sources and Modifications

  • A new source is a new industrial plant, such as a new factory or mine. 
  • A modification is a physical or operational change to an existing source, including installation of new equipment, which results in an increase in emissions. 
  • Anyone applying for a permit for a new source or modification may have to demonstrate through modeling that emissions of SO2 from the source or modification will not cause or contribute to a violation of the revised secondary SO2 NAAQS. 
    • This requirement will apply to any source subject to the Prevention of Significant Deterioration (PSD) permit program or to Minor New Source Review (NSR).
    • A source that has obtained a final permit under either of these programs before the effective date of the revised NAAQS (Dec. 31, 2024) will be grandfathered out of this requirement.
    • The NAAQS revision does not change which sources are subject to PSD or Minor NSR; rather, it requires sources and modifications already subject to those programs to model for compliance with the revised SO2 NAAQS.
  • If an area is designated nonattainment for the revised SO2 NAAQS, applicants for a permit or permit revision to construct a new source or modification in the area may be subject to nonattainment NSR. Among other requirements, an applicant subject to nonattainment NSR must obtain emission reductions from other sources in the area to completely offset the increase in emissions from the new source or modification.

Section Manager

Ph: 602-784-1603

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