MEMORANDUM UNITED S T ATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON , D . C. 204 60 

## SEP 0 2 2015 OFFICE OF AIR AND RADIATION SUBJECT: Correction oflnadvertent Errors in the Prop osed Federal Plan Requirements for G reenhouse Gas Emiss ion s from Electric Ut ilit y Generating Units Constructed o n or Before January 8 , 20 14 ; Model Trad ing Rules; Amendments to Framework Regul at ions, and Associated Regu latory Imp act Analysis FROM: THRU:



### TO: Janet G. McCabe

### ~**~** 

## O . qc {..l ._ Acting Assistant Administrator (6101 A) 

# , / .. a-tJt/l/ v Lorie Schmidt, Associate General**Co unsel** **/~·iey_.....,** A ir and R adiation Law Office (2344A) Joe l Beauva is , Associate Administrator 

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# t ue t! Office of Polic y ( 1804A) 

# J (;} G ina McCarthy Adm inistrator (1 10 1A) Inadvertent e rrors were made in the process of preparing the signatu re package for the proposal titled , " F e deral Plan Requirements for Gree nhou se Ga s E missions from Electric Utili ty Generat in g U nit s Co nstructed on or Before January 8 , 2014; Model Trading Rules; Amendments to Framework Regulations ," s ig ned on August 3, 20 1 5. Corrections have been made to ensure th e accuracy and cons istency of the preamble and the regu latory text. Co rrection s to the s igned proposed ru le that merit ex planation are li sted be low. All of the correction s are s hown in the redline and strikeout version of the s igned propo se d rule , which is provided as Attachment l. The co rrections shown includ e those li s ted below, as we ll as g rammatic al, punctuation and fonnatt ing corrections , includin g edits needed to confonn to requirements for publication in the Fede r al Register. In add ition , inadvertent errors were made in th e process of preparing the Regulatory Impact Ana lysis (RIA). Corrections to the RlA that merit explanation are listed be low. Attachment 2 i s a redline and s trikeout vers i on of the RIA that s hows all corrections. Preamble • Passim - Re vised "e mi ss ion g u idelines" or "guidelines " to " EGs " for consistency. • Passim - Re placed "C PP " with "C lean Power Plan" for cons i stency. • Passim - Rev ised " IGCC unit s " to " IGCC " for consistency. • Passim - R evised " take comment ... " to " re qu es t comment. .. " for consistency. • Passim - Rev ise d "emission rate standard" to · ' rate-based emission standard" or " rate-based emission standa rds," as a terminological correction. l n l ernel Address (URL) • hllp://www epa.gov Recycled/Recyclab l e • Printed w11h Vegetable Oil Bilsed I nks on 100°0 Postconsumer. Process Chlorine Free Recyc l ed Paper2 • Pas s im - R ev ised "NGCC" to " NGCC unit " and " NGCCs " to " NGCC unit s," for consistency. • Passim - R ev i sed " EGU " to "affected EGU," " EGUs " to " affected EGUs" and "EGU's" to "affected EGU's ," for cons istency. • Pa ssim - Revised " ...the EPA is requesting co mme nt ... " to " .. . the E PA reques ts co mment .. . " for consistency and acti ve voice. • Passim - In serted "for th is propo s al " after " the RIA. " • Page 2 - Rev ised to spe ll out first u sage of acronym NGCC. • Pag es 3-7 - Re vised to refl ect dates and venues of public he a rings. • Page 12 - Revised t o c larify meaning of acronym IGCC . • Page 15 - Revised letterin g of sect ions within sectio n V. • Page 15 - Revised to add sec tion titled "E rro r Correc ti o ns " an d correct letterin g of subsequent sect ion s within se cti o n VII. • Page 16 - Added " and I CF R Part 5 1 " in th e sec tion titl e . • Page 27 - Rev ise d " In th e process of developing a final federal plan , the EPA will a l so take actions to addre ss th ose concern s as we ll. " to " In th e process of dev e lop in g a fina l f e deral plan , the EPA will take ac ti ons to address those co ncern s as we ll. " • Page 29 - Revi se d " ... and si mplify compliance o ption s for affected EGUs. " to " ... and simp lif y compliance planning for affec t e d EGUs. " to r e fl ec t that th e r e i s continued fl exib ili ty , eve n und er the scenario di sc ussed. • Page 29 - Revi se d "co mpli ance option s" to " compliance pl annin g" to reco g ni ze fl exibili ty of option s und e r e ither approach. • Page 30 - Rev ised to spe ll out fir st u sage of acronym ERC. • Pag e 3 1 - Revised to spe ll out first u sage of acronym RE . • Page 34 - R ev ised " integrat ed gasification combine d cycle unit (IGCC) " to " integ rated gasification combine d cycle ( IGCC) " for co n s istency . • Page 4 3 - De leted " a s a ' note"' to reflect that th at provi s i o n is now in the operative portion of the regulatory text and not a " no t e. " • P age 49-50 - Reword ed sentence to read , " Th e EPA will w ithdraw the federal plan for a state w hen that s tate s ubmits , and th e EPA approves , a final p lan ," to accurately reflect th e c ited EGs reg ul atory text. • Page 51 - Added "as propo se d to be ame nded , see section VII below," to make clear that aspects of the time li nes fo r federal ac ti o n are bein g prop ose d. • Page 52 - Rev ised to add tex t "U nde r the co mpl ete ness - criteria process prop osed to be added to 40 CFR 60 .27, se e section V ILE below , ... " and revised text , " T he EPA will have 6 months .. . " to " th e EPA wou ld hav e 6 month s ... " to clarify this is a propo sal. • Page 52 - Rev ised " In th e case of initia l s ubmittals und er 60.5765 , the E PA w ill have 60 day s from September 6 , 2016 to noti fy a s tate that it s initi a l s ubmitta l does not me et th e require ment s of 60.5760 (a)." to " In th e case of initial submitta ls under 40 CFR 60 .5765 , the EPA will have 60 day s from the date the EP A received the initial s ubmittal to notify a state that it s initial submitta l does not meet th e requirements of 40 CFR 60.576 5(a)." for consistency w ith 40 CFR 60 . 5765 . • Page 56 - Revi sed "e mi ss ion goal " to " emiss io n goals" to refl ec t interim and fi n al goals. • Page 92 - Rev ised " The BART Gu id elines provide: T he ' re maining us eful lif e' of a sourc e, if it represe nt s a relatively short time period , may affect the annua li ze d costs of retrofit controls .. . . If th e remainin g usefu l li fe will cle a rl y exceed th[e] time period [for amortization base d on the t ype of control] , th e remaining u se ful life ha s esse ntially no effect on control costs and on the BART determin at ion proce ss. Wh e r e the remainin g useful life i s less than the time period for amorti z in g cost s, yo u s hould u se thi s s horter time p eri od in yo ur cost calcu lation . 40 CFR part 51, app e ndix Y ,

### 3 section IV .D.4.k." to " In the context of the visibility program , we h ave interpreted this provi s ion to mean that th e remaining u se ful life should be considered wh e n calculatin g th e annuali z ed costs of retrofit contro l s. See 40 CFR part 51 , app e ndi x Y, section IV.D.4.k ." to conform to OFR publi cation g uid e lines agai n st quotin g r egu latory or s tatute text where unnecessary. • Page 100 - Revised "As a further example of fl ex ibility under title V , the title V regulations a ll ow the use of the minor permit mod ification procedures for permit modifications ' in vo lv ing th e use of eco nomi c incentives, marke ta bl e permits , e mi ss ions tradin g , and o ther similar approaches , to the extent th a t s uch minor permit modification procedures are ex pli c itly prov i de d for in an applicabl e implementat io n plan o r in app li cable req uire me nt s promul gat ed by EPA'. 40 CF R 70.7(e)(2)(i)(B) and 40 CFR 71.7(e)( l )( i)(B). T he refo re , the EPA is proposing ... " to " As a further exam pl e of flexibilit y under title V , and cons i stent wit h 40 CFR 70.7(e) (2 ) ( i)( B ) and 40 CFR 71.7(e)(l) ( i) (B ), the EPA is proposing .. . " to confo rm w ith OFR publication rules aga in st block quotes of reg ul ato ry text. • Page l 06 - Rev ised to list the correct date of promulgation and FR citation for th e final Coal Combustion Res iduals rul e. • Page l 07 - Reworded se nte nce to read , "The perso ns elig ible to fil e such app ea ls wo uld be de sig nated representatives as defined in this proposed rul e and o th e r ' inte rested persons' as defined in part 78. " T hi s is to conform to s tandard prac tice in part 78 and correct a false implication th at " designate d re presentativ es" are auto mati call y included in the d e finition of " interes t e d person " i n part 78 , which is not the ca se. • Page 131 - Revised "three" to " fo ur" to correctly reflect the numb er of ERC categories provid ed in the list. A l s o revised "fourt h " to " fifth " in s ub seq uent se nte nces to reflect an additional fifth categor y is being proposed. • Page 149 , 1 52 - R ev ised to re flect the s in g l e biomass treatment option off ered fo r co mment , r ather than multipl e treatment options as the se nte nce pre viously inferred . • Pag e 152 , foo tnote 59 - Re vi se d " ... bio ge ni c fee d stocks may include .... " to " ... bio g enic feedstocks include .... " • Page 153 , footnote 60 - Revised " ... ecosyste m serv ices protection as we ll as cl imate change mitigation . .. " t o ' · ... ecosy s tem service s protec ti o n and climate c han ge mitigation . ... " • Page 1 54 - Deleted the word " plan ," and rev i sed sentence to read, " ... which would a lso p o t enti a ll y app l y to e li g ible generation under the propo se d mass-base d model trading rul e allowance set-aside

.. . " to re fl ect that bioma ss set-as ides are not proposed in th e federal plan , but ar e potentially available in the model rul e. • P age 160 - R evi sed " WHP faci lities " to " WHP units" for co n s iste ncy within thi s di sc us s ion. • Page 162 - Rev ised " ...e mi ss io n s, and co mpliance inform ation. " to" ... e mi ss io n s data , and compliance information ." • Page 166 - R ev ised ''. ..r e ported to the Admini strator for reco rdation ... " to " ...reported to the Administrator, ... ." • Page 170 , footnote 71 - R ev i sed " Note th at these value s w ill be the s ubmitted va lu es from the affected EGUs to the EPA th at have gone throug h a transparent review pro cess. " to ' 'Note that affecte d EGUs will s ubmit these v alue s to the EPA and the va lu es w i ll go throu g h a transp a re nt re v iew process." • Page 171 - Rev i sed "S ub se qu e nt ly, th e EPA will finalize thi s NODA and iss ue ERCs accordin g ly with tracking a nd serial numb ers." to " Su b sequent ly , the E P A would finali ze this NO D A and issue ER Cs in accorda nce w ith the NO DA , w ith tracki ng and seri a l numbers. " • Page 1 73 - Revised " ... demand-side EE , C HP , biomas s ... " to " ... demand - side EE , C HP , WHP , biomass .... "4 • Page 174 - Co rrected sentence to reflect language in the final EGs that the determination of eligible RE is generatio n-ba sed and not measure-based by removing term , " measure must be implemented ," replaced it with , "generation was produced." Correc ted c itation to final gu idelines by adding "see sections V lll.K. l and," and deleting , " of the final EGs. " Clarified the context of a statement of geographic limitations on ERC issuance by adding , "s ubmitted fo r ERC issuance ," " rate-based " and " approac h ." • Page 176 - Corrected statement on EM& V requirements so that it applied to all proposed eligible providers by adding, " or nuclear. " Corrected citation to other section by add in g, "see above geographic elig ibility discussion and section III. A." Corrected terminology in ERC issuance process by replacing , "ERC I ssuance Application," with , " M&V Report. " Page 188 , footnote 77 - Revised " ... and other eligible measures and thereby ens ure that. .. " to " ... and o th er eligib le measures to ensure that. ... " • Page 190 - Revised " This federal plan proposes ... " t o " This act io n proposes .... " • Page 196 - Revised " ... and nuclear ... " to " ... and nucl ear energy .... " • Page 199 - Revised paragraph to read " An additional considerat ion regarding distributed RE units that directly serve on-site end -u se electricity load s is that avoided transmission and distribution (T&D) system losses can be quantified, as is commonly practiced with demand-side EE . If suc h T&D losses are quantified , the requirements for demand-side EE would be applicable ," to correctly characterize thi s topic as a "consideration" rather than a "cr iterion " and explain proposed treatment. • Pag e 199 - Revised " ... and other requirements included in this subsectio n ... " to " ... and other requireme nt s proposed in this subsectio n .... " • Page 199 - Deleted " in Clean Po wer Plan " fro m "for use in Clean Power Plan compliance" because CPP itse lf does not create the compliance obligation in this context. • Page 202 - R ev i sed "e ligible nuclear" to "eligible nuclear energy reso urces." • Page 227 - Revised " The two ERCs owed for each ERC needed for compliance is in addition to ... " to "The two ERCs owed for each ERC needed for compliance but not supp li ed is in addition to ... " for clarification. • Page 230 - Revised "The EPA also has reservations due to the fact. .. " to "The EPA also has reservations co nc ern in g this concept due to the fact ... " for cla rity. • P age 241-243 - Added asterisks to three states in Table 8 and a note to clarify that the values in the table exc lud e EGUs located in Indian country within those three states. • Pages 249,250 - Revised citations: "The EPA ha s adopted fac ility-leve l compliance in previous emissions b ud get-trad in g programs including the ARP (70 FR 25162), th e CA IR (70 FR 25162) , and the CSAPR (76 FR 48208)." to "The EPA ha s adopted facility- level compliance in previous emissions budget-trading programs including the ARP , see 70 FR 25 162, at 25296 - 98 (May 12 , 2005); the CA I R FIP , see 71 FR 25328, at 25365 (April 28, 2006); and the CSAPR , see 75 FR 45210, at 45323 (Aug. 2, 20 10) ." • Page 254 - Revised footnote 93 to be consistent with the preamble language that it references. • Page 273 - Deleted , " and model rule proposal " because the restriction on EPA regulating new sources under 11 l(d) does not apply to the model rule. • Page 275 - D e leted reference to text that was removed from preamble: " ... and in state-based GHG regulatory programs. " • Page 276, 277 - Deleted block quote of FR notice and replaced with paraphrase in conformance with OFR policy to avoid block quotes. • P age 285 - Correc ted " certificate of registration " to " certificate of representation." • Page 290 - Added "and other types of projects" to expand scope of the request for comment on what other projects sho uld be eligible under the renewable ene rgy set aside.

### 5 • Page 29 1 - Corrected TSO reference by replacing "A llowance Allocation Proposed Rule TSO" w ith "Renewab le Energy Set-as ide TSO." • Page 300 - Corrected preamble c itat ion by replacing, "EM&V section above , " with , "section IY.0.8 of this preamble (EM&V section for the rate-based approach). " • Page 300 - Corrected se ntence to delete 3 from " 3 years " because compl iance periods are not all 3 years. Changed "performan ce " to "compliance period" for accuracy. Clarified the context of comment request regardin g disqualifying set-as id e recipients from rece iving ER Cs if they are disqualified from receivin g set-as ide allowances by adding, "from states with rate-based plans." Deleted last clause of same sentence to correct for inac curacy. • Page 305 - Corrected sentence by replacing " ERCs" with "all owances." • Page 306 - Corrected sentence by replacing " ERCs" with " a ll owances. " • Page 308 - Deleted "to affected sources" to make the sentence consistent with the preamble sect ion that it references. • P age 333 - Added the fo ll ow in g as an introductory sentence: "The EPA proposes to establish the follow in g sched ule and procedures for recordation of allowance a llocation s and transfers." • Page 334 - Revised " A transfer would be subm itted providing ... " to "Allowances could be transferred by submitting a transfer form provid in g ... " for clarity. • Page 334 - Added the fo llowin g as an introductory sentence: " Th e EPA proposes to include the following provisions r ega rdin g compliance with emission limitations. Under the proposed provisions , once ... " • Page 340 - Deleted quote of CAA section 101 and replaced with paraphrase in conformance with OFR policy to avo id statutory quotes. • Page 34 I - Revised "Lega ll y , delegation of a s tandard or requirement means that obligations a source may have to the EPA under a fede rall y promulgated stand ard become ob li gatio n s to a state or tribe" to "De legation of a standard or requireme nt ge nerally means that obligat ions a so urc e may have to the EPA und er a federa ll y promulgated standard become obligat ions to a state or tribe in the first instance." • Page 342 - Revised " See generally "Good Prac ti ces Manual for Delegation of NSPS and NESHAP " (EP A , February 1983) " to " These criteria are explained generally in the "Good Practices Manual for Delegation ofNS PS and NESHAP" (EPA , Febmary 198 3). " • Page 343 - Revise d "(A copy of this ma nual has been placed in the docket for thi s action.)" to "(A copy of this delegation has been placed in the docket for this action.)" • Page 354 - Revised " The 1970 CAA only a ll owed th e EPA to approve or disapprove SIP subm ittals " to " The 1970 CAA o nl y allowed the EPA two c hoices - to approve or disapprove S IP submittals. " • Page 356 - Revised "This mec hanism are situations" to "Th is approac h would a lso address t h ose situations. " • Page 359 - Revised" 18 months after the date of the notice " to " I 8 months after the date of the action. " • Page 364 , 365 - Changed "s hall " to " must " in each occurrence in this paragraph for cons i stency with regulatory text. • Page 366 - Revised " ... i dentification of emi ss i on s tandard s for the d es ignated facilities ... " to " ident ifi cation of emission standards for each designated facility .... " Page 367 - Added sentences to clarify meaning of "comp lete by operation of law " as proposed to be added to the implementing regulations: " In cases where a state does not submit anything to the agency, however , the Admin istrator must make a finding offailure to sub mit no later than 6 m o nths after the date , 

### if any ,

### 6 by which a state is requ ired to submit the plan or revision. (In other words, 'co mpleteness by operation of law ' is only available where the state has actually submitted a plan to the agenc y.)" • Page 390 - Revised "as a compliance with the standards " to " as a compliance approach with the standards . " • Page 390 - Added "fo r this proposal" after " in th e RIA. " • Page 415, 416 - Changed "fi nal " to "propos ed," deleted " to assist states and stakeholders," spelled out EJ , and added "federa l" before " plan " to adjust language from final EGs prean1b le to proposed federal plan preamble. • Page 416- Revised " s t e p s that the EPA is going to be taking to assist communiti es" to "steps that the EPA will take to assist com munitie s. " • Page 432 - In serted " for this rulemaking" after " in the docket." • Page 433 - Deleted phrase " if implemented by s tates and affected EGUs in response to th e proposed rule " because inaccurate and unnecessary in context. • Page 456 - Revis ed " proposed guide lines" to "proposed federal plan" to correctly identify the reference to the federal plan being propo sed. • Page 457 - Added "and l CFR Part 51" to the NTT AA sect ion title. • Page 457 - Revised NIT AA section from: " This proposed action does not involve technical standards" to "Thi s proposed action involves technical stand ards . The EPA proposes to recogni ze ANSI accreditation under ISO 14065 for 

### GHG validation and verification bodies as a component of accreditation of indepe nd ent verifiers under both proposed federal plan approaches. The EPA also proposes that net energy output measurement s must be performed using 0.2 accuracy class electricity m etering instrumentation and calibration procedures as specified under ANSI Standards No. Cl2.20." • Page 464 - Included " Incorporation by Reference" in the List of Subjects. Regulatory text • Page 465 (60.27(b)) - Changed "will " to " s h all " for internal consistency and consistency with parallel s tatutory provision. • Page 465 (60.27(b)) - Added "co mplete " before "plan" and "p lan revi sion" for consistency with prior sentence. • Page 465 (60.27(c)) - C hanged " must " to "s hall " for internal consistency and consistency with parallel statutory provision. • Page 467 (60.27(g)) - Changed " must" to "s hall " for internal consistency and consistency with statute. • Page 470 (60.27(g)(4)(iv))- Corrected citation from " (g)(2)(E) through (I) " to "(g)(2)(v) through (ix)". • Pages 487-488 (62.16235)- Replaced Table 1 to Subpart MMM of Part 62 because some values in the table were inadvertently shifted to the wrong row s. • Page 5 1 1 (62. l 6250(c)) - Changed" ... savings in submitted M&Y report s, and any other requirements ... " to " ... sav ings in submitted M&V reports , or in any other submissions .. . " for clarification and g rammatical consistency. • Page 524 (62. 16260(c)(7)( iii)) - Corrected" ... EE program, EE project , or EE project. .. " to " EE program , EE project , or EE measure ... " • Page 525 (62. l 6260(c)(7)(iii)(B))- Clarified " ... part of a utility EE program direct install EE progran1 ... " by deleting " direct install EE pro gram " • Page 572 (62. 163 30(b)) - Changed "A C02 allowance transfer mu st be co rrect ly subm itted if : " to " A C02 allowance is correctly sub mitted if: " for clarification.

### 7 • Page 584-586 (62.16345(a)(6)(i)(A) and 

### (B))- Changed " ... relative to SATP conditions , as applicable) .. . " to " relative to SATP cond itions as defined in§ 62 . 16375 , as applicable) ... " for clarification. • Page 606 (62.16375, definition for Emissions)- Corrected "With regard to a period before the affected EGU or affected EGU is required to measure ... " to " With regard to a period before the affected EGU or facility is required to measure ... " • Page 601-602 (62.16375, definition for CEMS)-Corrected citation from "62.xx30 through 62.xx35" to "§ 62. 1 6345 " • Pages 614 (62. 1 6375, definition for Permanently retired) - Changed " Permanently retired means , with regard to an affected EGU, an affected EGU that is unava il able for serv ice and for which the affected EGU's owners and operators ... " to " Permanently retired means, with regard to an affected EGU , that an affected EGU is unavailab le for service and the affected EGU's owners and operators . .. " for clarification . • Page 618 (62. 1 6415(a)) - Added heading "Exemption" so that text reads "(a) Exemption . (1) Any affected EGU . .. " for clarification. • Page 642 (62 . 16440(c))- Changed " .. . savings in submitted M&V reports , and any other requirements .. . " to ''. .. savings in submitted M&V reports , or in any other submiss i ons ... " for clarification and grammatical consistency. • Page 643 (62.16445(a)(l))-Changed " ... account representative of the ERC resource ... " to " ... account representative of the e ligible resource .. . " for consistency. • Page 652 (62.16450(d)(3)) - Changed" ... general account of the ERC resource ... " to" ... general account of the eli g ible resource .. . " for clarification. • Page 662 (62.16455(c)(7)(iii))-Corrected " ...EE program , EE project , or EE project ... " to "EE progran1, EE project , or EE measure .. . " • Page 663 (62. l 6455(c)(7)(iii)(B)) - Corrected ''. .. part of a util ity EE program direct install EE program . . . " by deleting "direct install EE program. " • Page 674 (62. l 6465(b)(5)) - Changed ''. .. relating to the ERC resource .. . " to " ... re lating to the eligible resource . .. " for consistency. • Page 686 (62.16485(c))-Corrected " ... shall be construed to include the designated represe ntative or any a lternate designated represe n tative " by d eleting " or any alternate designated representative. " • Page 687 (62 . 16495)- Co rrected section heading from " What are the processes for changing designated representative, a lternate des i gnated representative , owners and operators?" to " What are the processes for chang ing designated representative , alternate designated representative , owners and operators, and affected EGUs? " • Page 707 (62.165 l 5(c)(5)(v))- Changed ''. .. submission by the designated representative or a lternate designated representative . .. " to " . .. subm i ss ion by the authorized account representative or alternate authorized account representative ... " for consistency. • Page 7 1 0 (62 . 16515(i)(2))-Changed " ... a list of all ERC resources .. . " to ''. .. a list of a ll eligible re so urces ... " for cons i stency. • Page 711 (62 . 16525(b)) - Changed "An ERC transfer must be correctly submitted if:" to "An ERC transfer is correctly submitted if:" for clarification. • Pages 722--724 (62 . l 6540(a)(5)(i)(A) and (B)) - Changed " ...relative to SATP cond itions , as applicable) ... " to " relative to SATP conditions as defined in § 

### 62.16570, as app licable) ... " for clarification. • Page 726 (62 . 16555) - Moved heading "(a)" from before sentence " You must prepare and submit reports according to paragraphs (a) through (g) of this section, as app li cab le." to after this sentence for clarification.8 • Pages 727 (62. l 6555(a)(l )(viii)) - Changed " . .. and all if an affected EGU is complying with an emission standard by using ERCs the designated representative must include in their report a list of all unique ERC serial numbers ... " to " and if an affected EGU is complying with an emission standard by using ERCs , then the designated representative must also include in the report a list of all unique ERC serial numbers ... " for clarification. • Page 741 (62.16570)-Revised "Demand-side energy efficiency or demand-side EE means energy efficiency activities , projects , programs or measures resulting in electricity savings " to " Demandside energy efficiency or demand-side EE means an installed piece of equipment or system , a modification of existing equipment or system , or a strategy intended to affect consumer electricityuse behavior, that resu lts in a reduction in electricity use (in MWh) at an end-use facility , premises , or equipment connected to the electricity grid. Demand - side EE is implemented through e nergy e fficiency activities , projects , programs or measures " for consistency with the definition in the final EG s . • Page 743 (62.16570 , definition for Emissions)- Corrected "With regard to a period before the aff e cted EGU or affected EGU is required to measure ... " to " With re gard to a p eriod before the aff e cted E GU or facility is required to measure ... " • Page 753 (62 . 16570, definition for Permanently retired) - Changed " Permane ntly retired means , with regard to an affected EGU , an affected E GU that is unavailable for service and for which the affecte d EGU ' s owners and operators .. . " to " Permanently retired means , with regard to an affected EGU , that an affected EGU is unavailable for service and the affected EGU ' s owners and op erators .. . " for clarification. • Pages 763-64 (78. l (b)) - Corrected " emission reduction credit" to " emission rate credit. " • Page 764 (78.1 (b )(19)(viii)) - Corrected citation from "62.1616535 " to "62.16535 " . Office of Federal Register COFR) edits provided by the Office of Po li cy • Passim - All 2"d level headings have been italicized. • Passim - The 3rd level heading has been revised to be i n p lain text , not bold or italic. • Passim - References to the term " notice " have been revised to " document " or " action . " • Page 1 - Revised to add FRL number. • Page 3 - Revised the instructions for " ADDRESSES " to be consistent with recently revised OFR guidance. Regulatory Impact Analysis (RIA) document • Page s 1-8 , 2-8 , and 2-13 - Changed the web address for Power Sector Modeling from www . epa.gov/ powersectormode ling/ to http: //www.epa.gov/ airmarkets/powersectormodeling.html. • Pages l -8 and 2-1 - Deleted "In other words , if one approach performs differently than the other on a giv e n metric during a given time period , this does not imply this will apply in all instances. " • Page 2-1 - R e vised " It is very important to note that the differences between the analytical results for the rate-based and mass-based federal plan approaches presented in this RIA may not be indicative of likely differences between the approaches if implemented by states and affected EGUs in response to the proposed rule. " to " It is very important to note that the differences betwee n the analytical results for the rate-based and mass - based federal plan approaches presented in thi s RIA may not be indicative of li ke l y differences between the approaches. " • As the RIA contains Executive Order text , edits made to the Executive Order text in the preamble were al so made to executive order text 

### in the RIA.

### 9 We recommend correct ion of these inadverte nt erro rs and approval of these changes 

### by signing and dating below.

A ll ac hments cc: Kristien Knapp/ QA ( 1 IOIA)