Carbon Pollution Standards for Modified and Reconstructed 

Stationary Sources: Electric Utility Generating Units 

Response to Comments on June 18, 2014 Proposed Rule

U.S. Environmental Protection Agency

August 3, 2015
ii

Foreword

Contents

Introduction....................................................................................................................................iii

Background.................................................................................................................................... iv

Stakeholder Engagement ............................................................................................................... iv

Public Comments............................................................................................................................ v

Organization of This Document.................................................................................................... xv
iii

INTRODUCTION

This document provides the Environmental Protection’s (EPA’s) responses to public comments 

on the Proposed Standards of Performance for Greenhouse Gas Emissions from Modified and 

Reconstructed Stationary Sources: Electric Utility Generating Units. The Notice of Proposed 

Rulemaking was published in the Federal Register on June 18, 2014, at 79 FR 34959. The EPA 

received comments on the proposed rule via mail, e-mail, facsimile, and at a public hearings held 

in Atlanta, Georgia; Denver, Colorado; and Washington, DC on July 29, 2014 and July 30, 2014; 

and in Pittsburgh, Pennsylvania on July 31, 2014 and August 1, 2014. Copies of all comments 

submitted and transcripts for the public hearings are available electronically through 

http://www.regulations.gov by searching Docket ID: EPA-HQ-OAR-2013-0603.

On January 8, 2014, the EPA proposed standards of performance to limit emissions of CO2 from 

new fossil fuel-fired electric utility steam generating units and natural gas-fired stationary 

combustion turbines (79 FR 1430). This document only contains responses to comments on the 

June 18, 2014 proposal. A separate RTC document has been developed for comments on the 

January 8, 2014 proposal. Further, many comments submitted on the June 18, 2014 proposal 

duplicate in substance comments submitted on the January 8, 2014 proposal, and EPA’s 

responses to some such duplicate comments are provided in the RTC for the January 8, 2014 

proposal and are not repeated here.

The EPA refers to the standards of performance for new, modified and reconstructed fossil fuelfired EGUs as the ‘Carbon Pollution Standards.’ The Response-to-Comments (RTC) Document, 

together with the preamble to the final Carbon Pollution Standards, presents the responses of the 

EPA to the more than two million public comments received on the proposals described above. 

The EPA has addressed all significant issues raised in the public comments.

As a result of changes made to the preamble and final rule prior to signature, and due to the 

volume of comments received, some responses in the RTC Documents may not reflect the 

language in the preamble and final rule in every respect. If there are any instances where the 

response in this document is in some way different from the preamble or the final rule, the 

language in the final preamble and rule controls and should be used for purposes of 

understanding the scope, requirements, and basis of the final rule. In addition, due to the large 

number of comments that addressed similar issues, as well as the volume of the comments 

received, the RTC Documents do not always cross-reference each response to the commenter(s) 

who raised the particular issue involved. The responses presented in this document are intended 

to augment the responses to comments that appear in the preamble to the final rule or to address 

comments not discussed in that preamble. Although portions of the preamble to the final rule are 

paraphrased in this document where useful to add clarity to responses, the preamble itself 

remains the definitive statement of the rationale for the revisions adopted in the final rule. In 

many instances, particular responses presented in the RTC Documents include cross references 

to responses on related issues that are located either in the preamble to the Carbon Pollution 

Standards, the Technical Support Documents, or elsewhere in the RTC Documents. All issues on 

which the EPA is taking final action in the Carbon Pollution Standards are addressed in the 

Carbon Pollution Standards rulemaking record.
iv

Accordingly, the RTC Documents, together with the preamble to the Carbon Pollution Standards 

and the information contained in the Technical Support Documents, and the rest of the 

administrative record should be considered collectively as the agency’s response to all of the 

significant comments submitted on the two proposals described above. The RTC Documents 

incorporate directly or by reference the significant public comments addressed in the preamble to 

the Carbon Pollution Standards as well as other significant public comments that were submitted 

on the proposed rule.

BACKGROUND

On June 18, 2014, the EPA proposed standards of performance to limit emissions of CO2 from 

modified and reconstructed fossil fuel-fired electric utility steam generating units and natural

gas-fired stationary combustion turbines (79 FR 34959; June 2014 proposal). Specifically, the 

EPA proposed standards of performance for: (1) modified fossil fuel-fired electric utility steam 

generating units, (2) modified natural gas-fired stationary combustion turbines, (3) reconstructed 

fossil fuel-fired electric utility steam generating units, and (4) reconstructed natural gas-fired 

stationary combustion turbines.

STAKEHOLDER ENGAGEMENT

The EPA engaged extensively with a broad range of stakeholders and the general public 

regarding climate change, carbon pollution from power plants, and carbon pollution reduction 

opportunities. These stakeholders included industry and electric utility representatives, state and 

local officials, tribal officials, labor unions, non-governmental organizations and many others.

In February and March 2011, early in the process of developing carbon pollution standards for 

new power plants, the EPA held five listening sessions to obtain information and input from key 

stakeholders and the public. Each of the five sessions had a particular target audience: the 

electric power industry, environmental and environmental justice organizations, states and tribes, 

coalition groups, and the petroleum refinery industry.

The EPA conducted subsequent outreach prior to the June 2014 proposals of standards for 

modified and reconstructed EGUs and emission guidelines for existing EGUs, as well as during 

the public comment periods for the proposals. Although this stakeholder outreach was primarily 

framed around the GHG emission guidelines for existing EGUs, the outreach encompassed 

issues relevant to this rulemaking and provided an opportunity for the EPA to better understand 

previous state and stakeholder experience with reducing CO2 emissions in the power sector. In 

addition to 11 public listening sessions, the EPA held hundreds of meetings with individual 

stakeholder groups, and meetings that brought together a variety of stakeholders to discuss a 

wide range of issues related to the electricity sector and regulation of GHGs under the CAA. The 

agency met with electric utility associations and electricity grid operators. Agency officials 

engaged with labor unions and with leaders representing large and small industries, many of 

which have been utilities and industry representatives directly related to the electricity sector. 

The agency also met with energy industries such as coal and natural gas interests, as well as with 

representatives of energy intensive industries, such as the iron and steel and aluminum industries, 

to help understand the potential concerns of large industrial purchasers of electricity. In addition, 

the agency met with companies that offer new technology to prevent or reduce carbon pollution. 
v

The agency provided and encouraged multiple opportunities for engagement with state, local, 

tribal, and regional environmental and energy agencies. The EPA also met with representatives 

of environmental justice organizations, environmental groups, and religious organizations.

PUBLIC COMMENTS

The EPA received approximately 230 public comments on the June 2014 proposed standards to 

limit CO2 emissions from modified and reconstructed fossil fuel-fired electric utilities (79 FR 

34959). Table 1 presents the list of public commenters.

Table 1. List of Commenters Cited in this Summary Document Submitting Comments to 

EPA Air and Radiation Docket Number EPA-HQ-OAR-2013-0603 Regarding the Carbon 

Pollution Standards for Modified and Reconstructed EGUs 

(Proposed June 18, 2014, 79 FR 34959)

EPA-HQ-OAR-2013-0603-

Document ID Commenter

0058 Anonymous public comment

0063 G. Holliday

0064 P. Adams

0065 Anonymous public comment

0066 Anonymous public comment

0067 G. Holliday

0068 G. Holliday

0069 G. Holliday

0070 G. Holliday

0071 G. Holliday

0073 G. Holliday

0074 G. Holliday

0075

Patrick O'Loughlin, Senior Vice President & Chief 

Operating Officer, Buckeye Power, Inc.

0076 G. Holliday

0077 Anonymous public comment

0078 P. O'Brien

0079

(Duplicate of 0175)

Patrick O'Loughlin, Senior Vice President &, Chief 

Operating Officer, Buckeye Power, Inc.

0080 Anonymous public comment

0081 Anonymous public comment

0082 C. Laieski

0083 L. M. Kaplan

0084 J. Breed

0085 Comment on G. Holliday

0086 Anonymous Public Comment

0087 G. Holiday

0088 Anonymous public comment

0089

James R. Frauen, Vice President of Technical Services and 

Development, Seminole Electric Cooperative
vi

0090 George Holliday, ASME

0091 R. Spencer

0092

Rob Klemmans, Chair, Florida Electric Power 

Coordinating Group, Inc. (FCG)

0093 Anonymous Public Comment

0094 G. Holliday

0095 Rich Batey, Siemens Energy, Inc.

0096 Anonymous public comment

0097 George Holliday, ASME Life Fellow

0098

Henry V. Nickel, Hunton & Williams LLP on behalf of 

Utility Air Regulatory Group (UARG)

0099 G. Holliday

0100 Anonymous public comment

0101 Anonymous public comment

0102 Anonymous public comment

0103 Anonymous public comment

0104 L. Hammel-Turk

0105 Anonymous public comment

0106 B. Auwaerter

0107 D. Fredrickson

0108 G. Holliday

0109 M. and B. Wisdom

0110 G. Holliday

0111 B. Rising

0112 Anonymous public comment

0113 Anonymous public comment

0114

John W. Mitchell, Director, Division of Environment, 

Kansas Department of Health and Environment (KDHE)

0115

John K. Powell, Environmental Regulatory Compliance 

Administrator, Environmental Policy and Energy 

Resources, City of Tallahassee

0116

Patrick Morrisey, West Virginia Attorney General, Office 

of Attorney General State of West Virginia, et al.

0117 M. Mortensen

0118 G. Holliday

0119 Mike DeWine, Ohio Attorney General et al.

0120 Anonymous public comment

0121 G. Holliday

0122 Anonymous public comment

0123 Anonymous public comment

0124 Anonymous public comment

0125 Anonymous public comment

0126 Anonymous public comment

0127 Anonymous Public Comment

0128 L. D. Martinez
vii

0129 C. Croce

0130 G. Holliday

0131

Robert G. Hilton, Vice President, Power Technologies for 

Government Affairs, Alstom Power, Inc.

0132 Joe Pandy, General Manager, Mountain Parks Electric,Inc.

0133 S. Bogdanovic

0134

Stuart A. Clark, Air Quality Program Manager, State of 

Washington Department of Ecology

0135

Donald E. Smith, P.E., General Manager, Wheatland Rural 

Electric Association (WREA)

0136

Allison D. Wood, Counsel, Hunton & Williams on behalf 

of Utility Air Regulatory Group (UARG)

0137 Laurie Kutina, Ecology and Environment

0138

Mike Dewine, Ohio Attorney General, Environmental 

Enforcement, et al.

0139 G. Holliday

0140 Anonymous public comment

0141

Donald E. Smith, General Manager, Wheatland Rural 

Electric Association

0142

Richard A. Hyde, P.E., Executive Director,Texas 

Commission on Environmental Quality (TCEQ)

0143

Jason McLaurin, Environmental Coordinator, Southern 

Illinois Power Cooperative

0144

Jolene M. Thompson, AMP Senior Vice President & 

OMEA Executive Director, American Municipal Power, 

Inc. (AMP) and the Ohio Municipal Electric Association 

(OMEA)

0145

Claire M. Olson, Senior Vice President & General 

Counsel, Basin Electric Power

0146

Barbara A. Walz, Senior Vice President, Policy and 

Compliance, Chief Compliance Officer, Tri-State 

Generation and Transmission Association

0147

The comment submitted on October 16, 2013 was 

incomplete

0148

(Duplicate of 0242)

Craig Butler, Director, Ohio Environmental Protection 

Agency (Ohio EPA)

0149

Quinlan J. Shea, III, Vice President, Environment, Edison 

Electric Institute (EEI)

0150

Theresa Pugh, Director, Environmental Services and Joe 

Nipper, Senior Vice President, Regulatory Affairs and 

Communications, American Public Power Association 

(APPA)

0151

Joseph A. Miakisz, Environmental Issues Manager, 

NextEra Energy, Inc.
viii

0152

Robert W. Klemans, Chair, Florida Electric Power 

Coordinating Group, Inc., Environmental Committee 

(FCG-EC)

0153

Robert Richhart, Vice President, Management Services, 

Hoosier Energy REC, Inc.

0154

(Duplicate of 0237)

Shannon L. Goessling, Esq., Executive Director and Chief 

Legal Counsel Southeastern Legal Foundation (SLF)

0155 Mark Farnsworth, Highline Electric Association (HEA)

0156

Bruce W. Ramme, Vice President Environmental, 

Wisconsin Electric Power Company (doing business as We 

Energies)

0157 Duke Energy

0158

Erik Bakken, Senior Director, Transmission Strategy and 

Environmental Services, Tucson Electric Power Company 

(TEP)

0159

Claire M. Olson, Senior Vice President & General 

Counsel, Basin Electric Power Association

0160

Dr. Laura Nelson, Director, Governor's Office of Energy 

Development, State of Utah

0161

Patrick O'Loughlin

Senior Vice President &. Chief Operating Officer, 

Buckeye Power, Inc.

0162

Rebecca Heffren, Environmental Coordinator, Empire 

District Electric Company

0163

Joseph A. Miakisz, Environmental Issues Manager, Next 

Era Energy

0164

Cory R. Borgeson, President & Chief Executive Officer 

(CEO), Golden Valley Electric Association (GVEA)

0165

Steven M. Pirner, Secretary, South Dakota Department of 

Environment and Natural Resources (DENR-SD)

0166

Leonard K. Peters, Secretary, Energy and Environment 

Cabinet of Kentucky, Office of the Secretary

0167

Arundhati Khanwalkar, Environmental Management 

Department, PPL Services Corporation (PPL)

0168

Colleen Smith, Senior Advisor, Regulatory & 

Environmental Policy, Capital Power Corporation

0169

James Andrew, Director, Environmental Services, Prarie 

State Generating Company, LLC

0170

Michael O. McKown, Senior Vice President, Law and 

Administration and Secretary and Gary M. Broadbent, 

Assistant General Counsel and Media Director, Murray 

Energy Corporation

0171

Paul Carpinone, Director, Environmental Health, and 

Safety, Tampa Electric Company (TEC)

0172 the Biogenic CO2 Coalition
ix

0173

Paul Bailey, Senior Vice President, Federal Affairs and 

Policy, American Coalition for Clean Coal Electricity 

(ACCCE)

0174

Frank Williams, Executive Director, Concentrating Solar 

Power Alliance (CSP Alliance)

0175 Dale Louda, Executive Director, CHP Association

0176

Mark W. Schwirtz, President and General Manager, 

Golden Spread Electric Cooperative, Inc.

0177

Matthew D. Hall, Senior Environmental Planner, 

Environmental Services Department, Policy and Strategy, 

Consumers Energy

0178

Comments submitted by Connie K. Lawniczak, Assistant 

Vice President, Shared Services and Environmental 

Services, Wisconsin Public Service Corporation (WPSC)

0179

Joseph G. Eutizi, Engineering Manager, San Miguel 

Electric Cooperative

0180

Lorraine Krupa Gershman, Director, Regulatory and 

Technical Affairs, American Chemistry Council

0181

Kathleen Robertson, Environmental and Fuels Policy 

Manager, Federal Regulatory Affairs, Exelon Corporation

0182 Jeff A. McNelly, Executive Director, ARIPPA

0183

Kim Mireles, Vice President, Environmental Services, 

Luminant

0185

Kara M. Montalvo, Director, Environmental Compliance 

and Permitting, Salt River Project Agricultural 

Improvement and Power District (SRP)

0186

Alexander C. Schoch, Executive Vice President, Peabody 

Energy Corporation

0187

Chas Spell, Director, Environmental Policy & Programs, 

Arizona Public Service Company (APS)

0188

Eric L. Hiser, Counsel, Jorden Bischoff & Hiser on behalf 

of Arizona Utilities Group (AUG)

0189

Abbie Krebsbach, Environmental Director, MontanaDakota Utilties Co.

0190

Cathy S. Woollums, Sr. Vice President, Environmental and 

Chief Environmental Counsel, Berkshire Hathaway Energy 

Company

0191

Michelle R. Freeark, Director of Safety and Environmental 

Services, Arizona Electric Power Cooperative, Inc. 

(AEPCO)

0192

Greg Bertelsen, National Association of 

Manufacturers(NAM)

0193 Larry A. Boggs, General Electric Company (GE)

0194

Patrick O'Loughlin, Senior Vice President & Chief

Operating Officer, Buckeye Power, Inc.
x

0195

Pamela J. Williams, Senior Vice President of Corporate 

Services, Santee Cooper

0196

Andrew T. O'Hare, Vice President, Public Policy, The 

Fertilizer Institute (TFI)

0197

Vincent J. Brisini, Deputy Secretary for Waste, Air, 

Radiation and Remediation, Pennsylvania Department of 

Environmental Protection

0198

Arundhati Khanwalkar, Environmental Management 

Department, PPL Services Corporation

0199

Jack F. Alvey, Senior Vice President, Generation, Indiana 

Municipal Power Agency (IMPA)

0201

Kara M. Montalvo, QEP, Director, Environmental 

Compliance & Permitting, Salt River Project Agricultural 

Improvement and Power District (SRP)

0202

Jason A. Schwartz, Legal Director, Institute for Policy 

Integrity et al.

0203

Douglas J. Fulle, Vice President, Environmental Affairs, 

Oglethorpe Power

0204

Bart Sponseller, Director, Air Management Program, 

Wisconsin Department of Natural Resources (WDNR)

0205 Anonymous public comment

0206

Sheila C. Holman, Director, Division of Air Quality, North 

Carolina Department of Environment and Natural 

Resources (NCDENR)

0207

William Day, Managing Director, Gas Turbine Association 

(GTA)

0208

Keith Stephens, Environmental Services Manager, 

PowerSouth Energy Cooperative

0209

Vicki Card, Environmental Section Supervisor, 

Environment, Health, & Safety Division, Colorado Springs 

Utilities

0210 New Hope Power Company (Incomplete)

0211

Frank J. Macchiarola, Executive Vice President, 

Government Affairs, America’s Natural Gas Alliance 

(ANGA)

0212 Richard Reisig, Siemens Corporation

0213

Sierra Club, Earthjustice, Clean Air Task Force, 

Environmental Defense Fund, Natural Resources Defense 

Council and National Wildlife Federation

0214

Larry S. Monroe, Chief Environmental Officer, Senior 

Vice President, Research & Environmental Affairs, South 

Company

0215

F. William Brownell, Counsel, Hunton & Williams LLP et 

al. on behalf of Utility Air Regulatory Group (UARG)

0216

David D. Doniger, Natural Resources Defense Council et 

al.
xi

0217

Barbara A. Walz, Senior Vice President, Policy and 

Compliance, Chief Compliance Officer, Tri-State 

Generation and Transmission Association, Inc.

0218

William F. Durham, Director, Division of Air Quality, 

West Virginia Department of Environmental Protection 

(WVDEP)

0219

(Duplicate of 0178)

Connie K. Lawniczak, Assistant Vice President, Shared 

Services & Environmental Services, Wisconsin Public 

Service Corporation (WPSC)

0220

Dr. Laura Nelson, Director, Governor’s Office of Energy, 

Development, State of Utah, Office of the Governor

0221 FirstEnergy Corp. (FE)

0222 Gulf Coast Lignite Coalition (GCLC)

0223

Commenr submitted by Matthew H. Mead, Governor, State 

of Wyoming

0224

Parthenia B. Evans, Brittany A. Barrientos and Dennis 

Lane, Stinson Leonard Street LLP on behald of Kansas 

City Board of Public Utilities

0225

Mary D. Nichols, Chairman, California Air Resources 

Board (CARB)

0226

Bill Matthews, 

Director Environmental Policy/Planning, Cleco 

Corporation

0227

John C. Hendricks, Director, Air Quality Services, 

Environmental Services Division, American Electric 

Power (AEP)

0228

Brian D. Heithoff, Chief Executive Officer (CEO), General 

Manager, High West Energy

0229

Paul Ling, Director Compliance, Kansas City Power & 

Light Company (KCP&L)

0230

John A. Garner, Executive Director, Alabama Public 

Service Commission (APSC)

0231 Bruce Watzman, National Mining Association (NMA)

0232

Tomas Carbonell, Senior Attorney, Climate and Air 

Program; and Megan Ceronsky; Environmental Defense 

Fund (EDF)

0233

(Duplicate of 0142)

Richard A. Hyde, Executive Director, Texas Commission 

on Environmental Quality (TCEQ)

0234

(Duplicate of 0206)

Sheila C. Holman, Director, Division of Air Quality, North 

Carolina Department of Environment and Natural 

Resources (NCDENR)

0235

Terry L. O'Clair, Director, Division of Air Quality, North 

Dakota Department of Health

0236

Kevin J. Craig, Executive Vice President, Natural 

Resource Partners L.P.
xii

0237

Shannon L. Goessling, Esq., Executive Director and Chief 

Legal Counsel, Southeastern Legal Foundation (SLF)

0238

C. Richard Neff, Vice President, Environment, Health & 

Safety, Cogentrix Energy Power Management, LLC

0239

Gregory L. Ryan, Senior Technological Specialist, 

Environmental Management & Resources, DTE Energy

0240

(Duplicate of 0203)

Douglas J. Fulle, Vice President, Environmental Affairs, 

Oglethorpe Power Corporation

0241

Tom Effinger, Director, Environmental Services et al., 

SCANA Corporation

0242

Craig Butler, Director, Ohio Environmental Protection 

Agency

0243

D. Richard Beam, Senior Vice President, Power Supply, 

Old Dominion Electric Cooperative (ODEC)

0244

Andres Restrepo, et al., Sierra Club and Jim Murphy, 

National Wildlife Federation

0245

Fred Carl, Director of Environmental Services, Black Hills 

Corporation (BHC)

0246 D. Cook

0247

Paul Noe, Vice President for Public Policy, American 

Forest & Paper Association and Robert Glowinski, 

President, American Wood Council

0248

Michael G. Cashin, Environmental Policy Manager, 

Minnesota Power (ALLETE)

0249

Jason Bohrer, President and CEO, Lignite Energy Council 

(LEC)

0250

Linda Barker, Director Environmental, Health and Safety, 

El Paso Electric Company

0251

Brian Brazil, Environmental Manager, TransAlta Centralia 

Generation LLC (TCG)

0252

Brent A. Ross, Manager, Carbon Programs, Associated 

Electric Cooperative, Inc. (AECI)

0253

Parthenia B. Evans and Dennis Lane, Stinson Leonard 

Street, LLP on behalf of Kansas City Board of Public 

Utilities, Unified Government of Wyandotte 

County/Kansas City, Kansas (BPU)

0254

Hopping Green & Sams, P.A. on behalf of James K. 

Frauen, Vice President, Technical Services and 

Development, Seminole Electric Cooperative, Inc.

0255

Mark Strohfus, Environmental Project Lead, Great River 

Energy

0256

Bob Holmes, Environmental Affairs Administrator, Omaha 

Public Power District

0257

Pamela F. Faggert, Chief Environmental Officer and Vice 

President, Corporate Compliance, Dominion Resources 

Services, Inc.
xiii

0258

Jasmine Mehta, Chief, Bureau of Air Quality Planning, 

Nevada Division of Environmental Protection (NDEP)

0259

Joe L. Citta, Jr., Corporate Environmental Manager, 

Nebraska Public Power District (NPPD)

0260

Debra J. Jezouit and Allison Watkins Mallick, Baker Botts 

L.L.P on behalf of The Class of 85 Regulatory Response 

Group

0261

Kevin G. Wailes, LES Administrator and Chief Executive 

Officer (CEO), Lincoln Electric System (LES)

0262

Joel Visser, Sidley Austin, LLP on behalf of David P. 

Tenny, President and CEO, National Alliance of Forest 

Owners (NAFO)

0263

Todd Parfitt, Director, Wyoming Department of 

Environmental Quality (WDEQ)

0264

Jack P. Broadbent, President, California Air Pollution 

Control Officers Association (CAPCOA)

0265

(Duplicate of 0248)

Michael G. Cashin, Environmental Policy Manager, 

Minnesota Power, ALLETE

0266

Barry R. Wallerstein, Executive Officer, South Coast Air 

Quality Management District (SCAQMD)

0267 Air Permitting Forum (APF)

0268

John T. Graves, Environmental Manager, Minnkota Power 

Cooperative, Inc.

0269

(Duplicate of 0232)

Tomás Carbonell and Megan Ceronsky, Environmental 

Defense Fund (EDF)

0270

Russell Frye, Counsel, Fryelaw PLLC on behalf of SSM 

Coalition

0271

Thomas W. Easterly, Commissioner, Indiana Department 

of Environmental Management (IDEM)

0272

(Duplicate of 0231)

Bruce Watzman, Senior Vice President, Regulatory 

Affairs, National Mining Association (NMA)

0273

Brian D. Heithoff, CEO/General Manager, High West 

Energy, Inc.

0274

Bruce A. Stevens, President, Indiana Coal Council, Inc., 

(ICC)

0275

S. Dear Schramm-Satayathum, Manager, Environmental 

Affairs, Wabash Valley Power Association (WVPA)

0276

Brian Hobbs, Vice President Legal and Corporate Services, 

Western Farmers Electric Cooperative (WFEC)

0277

Arundhati Khanwalkar, Environmental Management 

Department, PPl Services Corporation

0278

John M. Holloway, Sutherland, Asbill and Brennan LLP, 

on behalf of East Kentucky Power Cooperative (EKPC)

0279

(Duplicate of 0244)

Andres Restrepo, et al., Sierra Club and Jim Murphy, 

National Wildlife Federation
xiv

0280

James P. Duffy, Legal Fellow & Ann Brewster Weeks, 

Senior Counsel and Legal Director, Clean Air Task Force 

(CATF)

0281

Mark Latham, Deputy Vice Dean for Academic Affairs 

and Professor of Law

0282 Vera Pardess and Kevin P. Bundy, Senior Attorneys, 

Center for Biological Diversity (CBD) 

0283

Scott H. Segal, Director, Electric Reliability Coordinating 

Council, Bracewell & Giuliani L.L.P.

0284 National Rural Electric Cooperative Association (NRECA)

0285

(Duplicate of 0135)

Donald E. Smith, General Manager, Wheatland Rural 

Electric Association

0287 Municipal Electric Authority of Georgia (MEAG)

0288 Anonymous public comment

0289

Michael J. Nasi, Counsel, Jackson Walker LLP, on behalf 

of the Gulf Coast Lignite Coalition (GCLC)

0290 Don Huff, Director, Dairyland Power Cooperative

0291

Jason Bohrer, President and CEO, Lignite Energy Council 

(LEC)

0292

Megan Ceronsky & Tomas Carbonell, Senior Attorney, 

Environmental Defense Fund (EDF)

0293 Bruce Pendery, Wyoming Outdoor Council

0294

Robert E. Cleaves, President, Biomass Power Association 

(BPA)

0296

Craig S. Harrison and Andrew Knudsen, Counsel, Hunton 

& Williams LLP, on behalf of Utility Air Regulatory 

Group (UARG)

0297

Andrew Knudsen, Counsel, Hunton & Williams LLP et al. 

on behalf of Utility Air Regulatory Group (UARG)
xv

ORGANIZATION OF THIS DOCUMENT

This RTC document is organized into Chapters as follows:

Chapter 1: Applicability

Chapter 2: Legal Issues

Chapter 3: Impacts of Proposed Action

Chapter 4: Alternatives

Chapter 5: Reconstructed Fossil Fuel-fired Utility Boilers and IGCC Units

Chapter 6: Modified Fossil Fuel-fired Utility Boilers and IGCC Units 

Chapter 7: Reconstructed Natural Gas-fired Stationary Combustion Turbines

Chapter 8: Modified Natural Gas-fired Stationary Combustion Turbines

Chapter 9: Title V Permit Fees

Chapter 10: Monitoring, Recordkeeping, and Reporting and Other Issues

Chapter 11: Statutory and Executive Order Reviews

Chapter 12: Miscellaneous