MEMORANDUM 

UNITED ST ATES ENVIRONMENT AL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

SEP 0 2 2015 OFFICE OF 

AIR AND RADIATION 

SUBJECT: Correction oflnadvertent Errors in the Proposed Federal Plan Requirements for 

Greenhouse Gas Emissions from Electric Utility Generating Units Constructed on or 

Before January 8, 20 14; Model Trading Rules; Amendments to Framework Regul ations, 

and Associated Regulatory Impact Analysis 

FROM: 

THRU: 

TO: 

Janet G. McCabe ~ ~ O .qc{..l ._ Acting Assistant Administrator (6101 A) 

,/ .. a-tJt/l/v 

Lorie Schmidt, Associate General Counsel /~·iey_....., 

Air and Radiation Law Office (2344A) 

Joel Beauvais, Associate Administrator 7 (? £eau l/ tuet! 

Office of Policy ( 1804A) J (;} 

Gina McCarthy 

Administrator (1 101A) 

Inadvertent errors were made in the process of preparing the signature package for the proposal titled, 

"Federal Plan Requirements for Greenhouse Gas Emissions from Electric Utility Generating Units 

Constructed on or Before January 8, 2014; Model Trading Rules; Amendments to Framework 

Regulations," signed on August 3, 2015. Corrections have been made to ensure the accuracy and 

consistency of the preamble and the regulatory text. Corrections to the signed proposed rule that merit 

explanation are listed below. All of the corrections are shown in the redline and strikeout version of the 

signed proposed rule, which is provided as Attachment l. The corrections shown include those listed 

below, as well as grammatical, punctuation and fonnatting corrections, including edits needed to 

confonn to requirements for publication in the Federal Register. 

In addition, inadvertent errors were made in the process of preparing the Regulatory Impact Analysis 

(RIA). Corrections to the RlA that merit explanation are listed below. Attachment 2 is a redline and 

strikeout version of the RIA that shows all corrections. 

Preamble 

• Passim - Revised "emission guidelines" or "guidelines" to "EGs" for consistency. 

• Passim - Replaced "CPP" with "Clean Power Plan" for consistency. 

• Passim - Revised " IGCC units" to " IGCC" for consistency. 

• Passim - Revised "take comment ... " to "request comment. .. " for consistency. 

• Passim - Revised "emission rate standard" to ·'rate-based emission standard" or "rate-based 

emission standards," as a terminological correction. 

lnlernel Address (URL) • hllp://www epa.gov 

Recycled/Recyclable • Printed w11h Vegetable Oil Bilsed Inks on 100°0 Postconsumer. Process Chlorine Free Recycled Paper 
2 

• Passim - Revised "NGCC" to "NGCC unit" and "NGCCs" to "NGCC units," for consistency. 

• Passim - Revised "EGU" to "affected EGU," "EGUs" to "affected EGUs" and "EGU's" to "affected 

EGU's," for consistency. 

• Passim - Revised " ... the EPA is requesting comment ... " to " .. . the EPA requests comment .. . " for 

consistency and active voice. 

• Passim - Inserted "for this proposal" after "the RIA." 

• Page 2 - Revised to spell out first usage of acronym NGCC. 

• Pages 3-7 - Revised to reflect dates and venues of public hearings. 

• Page 12 - Revised to clarify meaning of acronym IGCC. 

• Page 15 - Revised lettering of sections within section V. 

• Page 15 - Revised to add section titled "Error Corrections" and correct lettering of subsequent 

sections within section VII. 

• Page 16 - Added "and I CFR Part 51" in the section title. 

• Page 27 - Revised " In the process of developing a final federal plan, the EPA will also take actions 

to address those concerns as well." to " In the process of developing a final federal plan, the EPA will 

take actions to address those concerns as well." 

• Page 29 - Revised " ... and simplify compliance options for affected EGUs." to " ... and simplify 

compliance planning for affected EGUs." to reflect that there is continued flexibility, even under the 

scenario discussed. 

• Page 29 - Revised "compliance options" to "compliance planning" to recognize flexibility of 

options under either approach. 

• Page 30 - Revised to spell out first usage of acronym ERC. 

• Page 31 - Revised to spell out first usage of acronym RE. 

• Page 34 - Revised " integrated gasification combined cycle unit (IGCC)" to " integrated gasification 

combined cycle (IGCC)" for consistency. 

• Page 43 - Deleted "as a ' note"' to reflect that that provision is now in the operative portion of the 

regulatory text and not a "note." 

• Page 49-50 - Reworded sentence to read, "The EPA will withdraw the federal plan for a state when 

that state submits, and the EPA approves, a final plan," to accurately reflect the cited EGs regulatory 

text. 

• Page 51 - Added "as proposed to be amended, see section VII below," to make clear that aspects of 

the timelines for federal action are being proposed. 

• Page 52 - Revised to add text "Under the completeness-criteria process proposed to be added to 40 

CFR 60.27, see section VILE below, ... " and revised text, "The EPA will have 6 months .. . " to " the 

EPA would have 6 months ... " to clarify this is a proposal. 

• Page 52 - Revised " In the case of initial submittals under 60.5765, the EPA will have 60 days from 

September 6, 2016 to notify a state that its initial submittal does not meet the requirements of 

60.5760(a)." to " In the case of initial submittals under 40 CFR 60.5765, the EPA will have 60 days 

from the date the EPA received the initial submittal to notify a state that its initial submittal does not 

meet the requirements of 40 CFR 60.5765(a)." for consistency with 40 CFR 60.5765. 

• Page 56 - Revised "emission goal" to "emission goals" to reflect interim and final goals. 

• Page 92 - Revised "The BART Guidelines provide: The 'remaining useful life' of a source, if it 

represents a relatively short time period, may affect the annualized costs of retrofit controls .. .. If the 

remaining useful life will clearly exceed th[e] time period [for amortization based on the type of 

control], the remaining useful life has essentially no effect on control costs and on the BART 

determination process. Where the remaining useful life is less than the time period for amortizing 

costs, you should use this shorter time period in your cost calculation. 40 CFR part 51, appendix Y, 
3 

section IV.D.4.k." to " In the context of the visibility program, we have interpreted this provision to 

mean that the remaining useful life should be considered when calculating the annualized costs of 

retrofit controls. See 40 CFR part 51 , appendix Y, section IV.D.4.k." to conform to OFR publication 

guidelines against quoting regulatory or statute text where unnecessary. 

• Page 100 - Revised "As a further example of flexibility under title V, the title V regulations allow 

the use of the minor permit modification procedures for permit modifications ' involving the use of 

economic incentives, marketable permits, emissions trading, and other similar approaches, to the 

extent that such minor permit modification procedures are explicitly provided for in an applicable 

implementation plan or in applicable requirements promulgated by EPA'. 40 CFR 70.7(e)(2)(i)(B) 

and 40 CFR 71.7(e)(l)(i)(B). Therefore, the EPA is proposing ... " to "As a further example of 

flexibility under title V, and consistent with 40 CFR 70.7(e)(2)(i)(B) and 40 CFR 71.7(e)(l)(i)(B), 

the EPA is proposing .. . " to conform with OFR publication rules against block quotes of regulatory 

text. 

• Page l 06 - Revised to list the correct date of promulgation and FR citation for the final Coal 

Combustion Residuals rul e. 

• Page l 07 - Reworded sentence to read, "The persons eligible to file such appeals would be 

designated representatives as defined in this proposed rule and other 'interested persons' as defined 

in part 78." This is to conform to standard practice in part 78 and correct a false implication that 

"designated representatives" are automatically included in the definition of " interested person" in 

part 78, which is not the case. 

• Page 131 - Revised "three" to " four" to correctly reflect the number of ERC categories provided in 

the list. Also revised "fourth" to "fifth" in subsequent sentences to reflect an additional fifth category 

is being proposed. 

• Page 149, 152 - Revised to reflect the single biomass treatment option offered for comment, rather 

than multiple treatment options as the sentence previously inferred. 

• Page 152, footnote 59 - Revised " ... biogenic feedstocks may include .... " to " ... biogenic feedstocks 

include .... " 

• Page 153, footnote 60 - Revised " ... ecosystem services protection as well as climate change 

mitigation ... " to '· ... ecosystem services protection and climate change mitigation .... " 

• Page 154 - Deleted the word "plan," and revised sentence to read, " ... which would also potentially 

apply to eligible generation under the proposed mass-based model trading rule allowance set-aside 

.. . " to re flect that biomass set-asides are not proposed in the federal plan, but are potentially 

available in the model rule. 

• Page 160 - Revised "WHP facilities" to "WHP units" for consistency within this discussion. 

• Page 162 - Revised " ... emissions, and compliance information." to" ... emissions data, and 

compliance information." 

• Page 166 - Revised ''. .. reported to the Administrator for recordation ... " to " ... reported to the 

Administrator, ... . " 

• Page 170, footnote 71 - Revised "Note that these values will be the submitted values from the 

affected EGUs to the EPA that have gone through a transparent review process." to ''Note that 

affected EGUs will submit these values to the EPA and the values will go through a transparent 

review process." 

• Page 171 - Revised "Subsequently, the EPA will finalize this NODA and issue ERCs accordingly 

with tracking and serial numbers." to "Subsequently, the EPA would finalize this NODA and issue 

ERCs in accordance with the NODA, with tracking and serial numbers." 

• Page 173 - Revised " ... demand-side EE, CHP, biomass ... " to " ... demand-side EE, CHP, WHP, 

biomass .... " 
4 

• Page 174 - Corrected sentence to reflect language in the final EGs that the determination of eligible 

RE is generation-based and not measure-based by removing term, "measure must be implemented," 

replaced it with, "generation was produced." Corrected citation to final guidelines by adding "see 

sections Vlll.K. l and," and deleting, "of the final EGs." Clarified the context of a statement of 

geographic limitations on ERC issuance by adding, "submitted for ERC issuance," "rate-based" and 

"approach." 

• 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 adding, "see above 

geographic eligibility discussion and section III.A." Corrected terminology in ERC issuance process 

by replacing, "ERC Issuance Application," with, "M&V Report."Page 188, footnote 77 - Revised 

" ... and other eligible measures and thereby ensure that. .. " to " ... and other eligible measures to 

ensure that. ... " 

• Page 190 - Revised "This federal plan proposes ... " to "This action proposes .... " 

• Page 196 - Revised " ... and nuclear ... " to " ... and nuclear energy .... " 

• Page 199 - Revised paragraph to read "An additional consideration regarding distributed RE units 

that directly serve on-site end-use electricity loads is that avoided transmission and distribution 

(T&D) system losses can be quantified, as is commonly practiced with demand-side EE. If such 

T&D losses are quantified, the requirements for demand-side EE would be applicable," to correctly 

characterize this topic as a "consideration" rather than a "criterion" and explain proposed treatment. 

• Page 199 - Revised " ... and other requirements included in this subsection ... " to " ... and other 

requirements proposed in this subsection .... " 

• Page 199 - Deleted " in Clean Power Plan" from "for use in Clean Power Plan compliance" because 

CPP itself does not create the compliance obligation in this context. 

• Page 202 - Revised "eligible nuclear" to "eligible nuclear energy resources." 

• 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 supplied is in addition to ... " 

for clarification. 

• Page 230 - Revised "The EPA also has reservations due to the fact. .. " to "The EPA also has 

reservations concerning this concept due to the fact ... " for clarity. 

• Page 241-243 - Added asterisks to three states in Table 8 and a note to clarify that the values in the 

table exclude EGUs located in Indian country within those three states. 

• Pages 249,250 - Revised citations: "The EPA has adopted facility-level compliance in previous 

emissions budget-trading programs including the ARP (70 FR 25162), the CAIR (70 FR 25162), and 

the CSAPR (76 FR 48208)." to "The EPA has 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 CAIR FIP, see 71 FR 25328, at 25365 (April 28, 2006); and the CSAPR, see 75 FR 

45210, at 45323 (Aug. 2, 2010)." 

• 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 - Deleted 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. 

• Page 285 - Corrected "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 should be eligible under the renewable energy set aside. 
5 

• Page 291 - Corrected TSO reference by replacing "Allowance Allocation Proposed Rule TSO" with 

"Renewable Energy Set-aside TSO." 

• Page 300 - Corrected preamble citation 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 sentence to delete 3 from "3 years" because compliance periods are not all 3 

years. Changed "performance" to "compliance period" for accuracy. Clarified the context of 

comment request regarding disqualifying set-aside recipients from receiving ERCs if they are 

disqualified from receiving set-aside allowances by adding, "from states with rate-based plans." 

Deleted last clause of same sentence to correct for inaccuracy. 

• Page 305 - Corrected sentence by replacing "ERCs" with "allowances." 

• Page 306 - Corrected sentence by replacing "ERCs" with "allowances." 

• Page 308 - Deleted "to affected sources" to make the sentence consistent with the preamble section 

that it references. 

• Page 333 - Added the following as an introductory sentence: "The EPA proposes to establish the 

following schedule and procedures for recordation of allowance allocations and transfers." 

• Page 334 - Revised "A transfer would be submitted providing ... " to "Allowances could be 

transferred by submitting a transfer form providing ... " for clarity. 

• Page 334 - Added the following as an introductory sentence: "The EPA proposes to include the 

following provisions regarding 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 avoid statutory quotes. 

• Page 34 I - Revised "Legally, delegation of a standard or requirement means that obligations a 

source may have to the EPA under a federally promulgated standard become obligations to a state or 

tribe" to "Delegation of a standard or requirement generally means that obligations a source may 

have to the EPA under a federally promulgated standard become obligations to a state or tribe in the 

first instance." 

• Page 342 - Revised "See generally "Good Practices Manual for Delegation of NSPS and NESHAP" 

(EPA, February 1983)" to "These criteria are explained generally in the "Good Practices Manual for 

Delegation ofNSPS and NESHAP" (EPA, Febmary 1983)." 

• Page 343 - Revised "(A copy of this manual has been placed in the docket for this action.)" to "(A 

copy of this delegation has been placed in the docket for this action.)" 

• Page 354 - Revised "The 1970 CAA only allowed the EPA to approve or disapprove SIP 

submittals" to "The 1970 CAA only allowed the EPA two choices - to approve or disapprove SIP 

submittals." 

• Page 356 - Revised "This mechanism are situations" to "This approach would also address those 

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 "shall" to "must" in each occurrence in this paragraph for consistency with 

regulatory text. 

• Page 366 - Revised " ... identification of emission standards for the designated facilities ... " to 

"identification of emission standards for each designated facility .... " Page 367 - Added sentences to 

clarify meaning of "complete 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 

Administrator must make a finding of failure to submit no later than 6 months after the date, if any, 
6 

by which a state is required to submit the plan or revision. (In other words, 'completeness by 

operation of law' is only available where the state has actually submitted a plan to the agency.)" 

• Page 390 - Revised "as a compliance with the standards" to "as a compliance approach with the 

standards." 

• Page 390 - Added "for this proposal" after " in the RIA." 

• Page 415, 416 - Changed "final" to "proposed," deleted " to assist states and stakeholders," spelled 

out EJ, and added "federal" before "plan" to adjust language from final EGs prean1ble to proposed 

federal plan preamble. 

• Page 416- Revised "steps that the EPA is going to be taking to assist communities" to "steps that 

the EPA will take to assist communities." 

• Page 432 - Inserted "for this rulemaking" after " in the docket." 

• Page 433 - Deleted phrase " if implemented by states and affected EGUs in response to the proposed 

rule" because inaccurate and unnecessary in context. 

• Page 456 - Revised "proposed guidelines" to "proposed federal plan" to correctly identify the 

reference to the federal plan being proposed. 

• Page 457 - Added "and l CFR Part 51" to the NTT AA section title. 

• Page 457 - Revised NIT AA section from: "This proposed action does not involve technical 

standards" to "This proposed action involves technical standards. The EPA proposes to recognize 

ANSI accreditation under ISO 14065 for GHG validation and verification bodies as a component of 

accreditation of independent verifiers under both proposed federal plan approaches. The EPA also 

proposes that net energy output measurements must be performed using 0.2 accuracy class electricity 

metering 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 "shall" for internal consistency and consistency with 

parallel statutory provision. 

• Page 465 (60.27(b)) - Added "complete" before "plan" and "plan revision" for consistency with 

prior sentence. 

• Page 465 (60.27(c)) - Changed "must" to "shall" for internal consistency and consistency with 

parallel statutory provision. 

• Page 467 (60.27(g)) - Changed "must" to "shall" 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 rows. 

• Page 511 (62. l 6250(c)) - Changed" ... savings in submitted M&Y reports, and any other 

requirements ... " to " ... savings in submitted M&V reports, or in any other submissions .. . " for 

clarification and grammatical 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 program" 

• Page 572 (62. 16330(b)) - Changed "A C02 allowance transfer must be correctly submitted if:" to "A 

C02 allowance is correctly submitted 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 conditions 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 "§ 62.16345" 

• Pages 614 (62.16375, definition for Permanently retired) - Changed "Permanently retired means, 

with regard to an affected EGU, an affected EGU that is unavailable for service 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 unavailable for service and the affected EGU's owners and 

operators ... " for clarification. 

• Page 618 (62. 16415(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 submissions ... " for 

clarification and grammatical consistency. 

• Page 643 (62.16445(a)(l))-Changed " ... account representative of the ERC resource ... " to 

" ... account representative of the eligible resource .. . " for consistency. 

• Page 652 (62.16450(d)(3)) - Changed" ... general account of the ERC resource ... " to" ... general 

account of the eligible 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 utility 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 " ... relating to the 

eligible resource ... " for consistency. 

• Page 686 (62.16485(c))-Corrected " ... shall be construed to include the designated representative or 

any alternate designated representative" by deleting "or any alternate designated representative." 

• Page 687 (62.16495)- Corrected section heading from "What are the processes for changing 

designated representative, alternate designated representative, owners and operators?" to "What are 

the processes for changing 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 alternate 

designated representative ... " to " ... submission by the authorized account representative or alternate 

authorized account representative ... " for consistency. 

• Page 710 (62.16515(i)(2))-Changed " ... a list of all ERC resources .. . " to ''. .. a list of all eligible 

resources ... " for consistency. 

• 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 SA TP conditions, as 

applicable) ... " to " relative to SATP conditions as defined in § 62.16570, as applicable) ... " 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 applicable." 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 results 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 energy 

efficiency activities, projects, programs or measures" for consistency with the definition in the final 

EGs. 

• Page 743 (62.16570, 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 753 (62.16570, definition for Permanently retired) - Changed "Permanently retired means, 

with regard to an affected EGU, an affected EGU that is unavailable for service 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 unavailable for service and the affected EGU's owners and 

operators .. . " 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 Policy 

• Passim - All 2"d level headings have been italicized. 

• Passim - The 3rd level heading has been revised to be in plain 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 

• Pages 1-8, 2-8, and 2-13 - Changed the web address for Power Sector Modeling from 

www.epa.gov/powersectormodeling/ 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 given metric during a given time period, this does not imply this will apply in all instances." 

• Page 2-1 - Revised " 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 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." 

• As the RIA contains Executive Order text, edits made to the Executive Order text in the preamble 

were also made to executive order text in the RIA. 
9 

We recommend correction of these inadvertent errors and approval of these changes by signing and 

dating below. 

Allachments 

cc: Kristien Knapp/QA (1 IOIA)