May 03, 2013 Abt Associates | List of Rulemaking Cost and Economic Impact Files | Page 1 

### Date May 3, 2013

To Record

From Isabelle Morin and Rob Chew

Subject List of Rulemaking Cost and Economic Im pact Files: Steam Electric Effluent Guidelines Rulemaking

This memorandum describes analytic files used for th e Regulatory Impact Analysis (RIA) of the proposed rulemaking of the Steam Electric Power Generating Effl uent Guidelines. The analytic files contain data classified by Industry as Confidential Business Informa tion. The list in Table 1 describes the content of the files to allow review and comment by the public w ithout potentially releasing proprietary information.

Table 1: List of Cost Files Developed fo r the Regulatory Impact Analysis (RIA)

File Name Description/Purpose 2010Pop.xlsx Contains 2010 "Race an d Hispanic or Latino: 2010 - State -- Place and (in selected states) County Subdivision" data (Table GCT- PL1). This information is used for entity size determination of municipalities and political subdivisions. Used in the RFA analysis. AEO_2011.xlsx Contains adjustment factors based on Annual Energy Outlook 2009 (AEO2009). AEO2010_sup_elec.xlsx Contains data used for the electricity rate impact analysis. CCI.xlsx Contains adjustment factors based on Construction Cost Index (CCI). CCI-based adjustment factors are used to brin g compliance costs to a given year. ComplYrs.xlsx Determines the first year when each analyzed plant would install a compliance technology based on its NPDES permit expiration year. CostControl.xlsx Contains the following: plant-level cost estimates for all cost options, facility sample weights, compliance-year sets, and plant-univ erse sets. This file specifies the specific option, sample weights, plant universe, and compliance-year set to be analyzed. ECI.xlsx Contains adjustment factors based on Employment Cost Index (ECI). EIA860_09.xlsx Data pull from the EIA-860 databases. These data are used for determination of total and steam capacity, NERC regions, and ownership type. EIA861_09.xlsx Utility-level data pull from the EI A-861 database. These data are used for revenue calculations, household impact analysis, and NERC region determination for utilities. EIA906_920_09.xlsx Data pull from the EIA-906/920 database. These data are used for determination of total and steam generation. ElPricesDisp.xlsx Contains cal culations of electricity prices and percent of total generated electricity sold
based on EIA data. These estimates are used to calculate revenue. ElRateImp.xlsx Estimates electricity price increases by consumer group due to regulatory requirements. EmplImp_MrgnstrnOnly _$1987.xlsx Contains employment impact analysis.

Facil_CTR.xlsx Contains calculations of facility-level cost-to-revenue ratios for analyzed plants. Final_FuelType_Classifi cation_11_09_11.xlsx Contains final fuel classi fications and sample weight s for Steam Electric plants.

Firm_CTR_RFA - OrigUniv_Ftr_RIA.xlsx Contains parent-level CTR and RFA analyses. This analysis is conducted for the future universe of plants. 

# Memorandum
Environment and ResourcesMay 03, 2013 Abt Associates | List of Rulemaking Cost and Economic Impact Files | Page 2 File Name Description/Purpose Firm_CTR_RFA - OrigUniv_RIA.xlsx Contains parent-level CTR and RFA analyses. This analysis is conducted for the current universe of plants. GDP_Deflator.xlsx Contains adjustment factors based on GDP Deflator (downloaded 6/25/2010). GDP_Deflator_2010.xls

x Contains adjustment factors based on GDP Deflator (downloaded 2/2/2012).

HHImp.xlsx Estimates an average impact of regulatory requirements on households. IndProf.xlsx Charts and tables developed for the electric power industry profile. Nameplate_Capacity_6.1
6.11.xlsx Contains plant capacity reported in the Steam Electric survey.

NERCRgns.xlsx Determines NERC regions for various analyses. PlantData.xlsx Contains plant-level information is used in the cost and economic impact analysis
model. PlantGen.xlsx Calculates total and steam electricity generation for each in-scope plant using EIA data. PlantOwn.xlsx Determines parent entities of Steam Electric plants and the size of these entities. PlantRev.xlsx Calculates facility-level revenue. PlantTypeCap.xlsx Determines facility type, total and steam capacity for in-scope facilities based on IPM
and EIA data. PrivateCosts.xlsx Calculates privat e discounted and annualized complian ce cost estimates used in various economic analyses. Original co sts are discounted to either promulgation year (2014), facility-specific compliance year, or analysis year (2014), annualized over appropriate number of years, and adjusted for taxes.
SocialCosts.xlsx Contains analysis of social costs. Calculates costs to use in the UMRA analysis. TaxRts.xlsx Contains total tax rate (total tax = stat e tax + federal tax - state tax * federal tax). Used for estimation of after-tax compliance costs. UMRA_OrigUniv.xlsx Contains UMRA analysis. CBI_Bio.xlsx Provides compliance costs for th e ORCR/OW Incremental Costs and Pollutant Reductions sensitivity analysis. These costs ar e associated with the treatment of FGD wastewater by a chemical precipitation an d biological treatment system (FGD_B). These costs are associated with Regulatory Option 3. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. These are exactly same costs as those included in the CBI_Bio_Costs_09052012_Exclude 50MW.xlsx file. CBI_Bio_Costs_08_06_
12.xlsx Provides plant-level complian ce costs associated with treatment of FGD wastewater by a chemical precipitation and biological treat ment system (FGD_B); these costs are for all units. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technolo gy/services to Steam Electric plants. CBI_Bio_Costs_08_06_ 12_50MW.xlsx Provides plant-level complian ce costs associated with the treatment of FGD wastewater by a chemical precipitation and biological treatment system (FGD_B); these costs are for units with capacity exceeding 50 MW only. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. CBI_BottomAsh.xlsx Provides compliance costs fo r the ORCR/OW Incremental Costs and Pollutant Reductions sensitivity analysis. These costs are associated with converting wet bottom ash handling systems to a dry bottom ash handling system (Bottom Ash). These costs are associated with Regulatory Option 4 for this analysis. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. These are the same costs as those included in the CBI_BottomAsh_Costs_09052012_Exclude 50MW.xlsx file. CBI_BottomAsh_Costs_ 08_06_12.xlsx Provides plant-level compliance costs associated with converting wet bottom ash handling systems to a dry bottom ash handling system (Bottom Ash); these costs are for all units. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technolo gy/services to Steam Electric plants.May 03, 2013 Abt Associates | List of Rulemaking Cost and Economic Impact Files | Page 3 File Name Description/Purpose CBI_BottomAsh_Costs_ 08_06_12_50 MW.xlsx Provides plant-level compliance costs associated with converting wet bottom ash handling systems to a dry bottom ash handling system (Bottom Ash); these costs are for units with capacity exceeding 50 MW only . Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. CBI_CP_Costs_08_06_1
2.xlsx Provides plant-level complian ce costs associated with the treatment of FGD wastewater by a chemical precipitation (FGD_C); these costs are for all units. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. CBI_CP_Costs_08_06_1 2_50MW.xlsx Provides plant-level complian ce costs associated with the treatment of FGD wastewater by a chemical precipitation (FGD_C); these costs are for units with capacity exceeding 50 MW only. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. CBI_FGD_MVC_&_Le achate_CP_Costs_08_06 _12.xlsx Provides plant-level comp liance costs associated w ith (1) leachate chemical precipitation alone (Leach_C) and (2) FGD chemical precipitation with mechanical vapor compression (not used); these costs are for all units. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. CBI_FGD_MVC_&_Le achate_CP_Costs_08_06 _12_50MW.xlsx Provides plant-level comp liance costs associated w ith (1) leachate chemical precipitation alone (Leach_C) and (2) FGD chemical precipitation with mechanical vapor compression (not used); these costs ar e for units with capacity exceeding 50 MW only. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/s ervices to Steam Electric plants. CBI_FlyAsh.xlsx Provides compliance costs for the ORCR/OW Incremental Costs and Pollutant Reductions sensitivity analysis. These costs ar e associated with converting wet fly ash handling systems to a dry fly ash handling syst em (Fly Ash). These costs are associated with both Regulatory Options 3 and 4 for this analysis. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. These are the same costs as those included in the CBI_FlyAsh_Costs_09052012_Exclude 50MW.xlsx file. CBI_FlyAsh_Costs_08_ 06_12.xlsx Provides plant-level compliance costs associated with converting wet fly ash handling systems to a dry fly ash handling system (Fly Ash); these costs are for all units. Groups plant-level costs by time of incurrence and du ration and by industry sector expected to provide technology/services to Steam Electric plants. CBI_FlyAsh_Costs_08_ 06_12_50MW.xlsx Provides plant-level compliance costs associated with converting wet fly ash handling systems to a dry fly ash handling system (F ly Ash); these costs are for units with capacity exceeding 50 MW only. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. CBI_Future_Profile_Bio _Costs_08_07_12.xlsx To account for upgrades some plants would make to their operations and treatment systems over the next few years, notably to comply with new air emission standards, EPA conducted a sensitivity analysis (i.e., denoted as the “future profile”) for the selected BAT and PSES options that inco rporates projected FGD installations in addition to FGD systems present in the base line. This file includes "raw" plant-level compliance costs associated with treatment of FGD wa stewater by a chemical precipitation and biological treatment system (FGD_B) for the future profile sensitivity analysis. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technolo gy/services to Steam Electric plants.May 03, 2013 Abt Associates | List of Rulemaking Cost and Economic Impact Files | Page 4 File Name Description/Purpose CBI_Future_Profile_CP _Costs_08_07_12.xlsx To account for upgrades some plants would make to their operations and treatment systems over the next few years, notably to comply with new air emission standards, EPA conducted a sensitivity analysis (i.e., denoted as the “future profile”) for the selected BAT and PSES options that inco rporates projected FGD installations in addition to FGD systems present in the base line. This file includes "raw" plant-level compliance costs associated w ith treating FGD wastewater with a chemical precipitation (FGD_C) for the future profile sensitivity analysis. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. CBI_Future_Profile_MV C_Costs_08_07_12.xlsx To account for upgrades some plants would make to their operations and treatment systems over the next few years, notably to comply with new air emission standards, EPA conducted a sensitivity analysis (i.e., denoted as the “future profile”) for the selected BAT and PSES options that inco rporates projected FGD installations in addition to FGD systems present in the base line. This file includes "raw" plant-level compliance costs associated with the treatment of FGD wastewater by a chemical precipitation and mechanical vapor compression (FGD_M) for the future profile sensitivity analysis. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. CBI_Leachate&FGD_08 _06_12_NoRET.xlsx Provides plant-level complian ce costs associated with FGD & Leachate (1) chemical precipitation (LeachFGD_C) and (2) chemical precipitation with biological treatment (LeachFGD_B): without retired la ndfills; these costs are for a ll units. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. CBI_Leachate&FGD_08 _06_12_NoRET_50MW
.xlsx Provides plant-level complian ce costs associated with FGD & Leachate (1) chemical precipitation (LeachFGD_C) and (2) chemical precipitation with biological treatment (LeachFGD_B): without retired landfills; these costs are for units with capacity exceeding 50 MW only. Groups plant-level co sts by time of incurrence and duration and by industry sector expected to provide t echnology/services to Steam Electric plants.CBI_LeachateCP_&_FGDBio_Alternate Cost Output_08_06_12.xlsx Provides plant-level complia nce costs associated withleachate & FGD chemical precipitation with biological treatment: w ithout retired landfills (FGD_LeachB_C); these costs are for all units. Groups plant-leve l costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants.CBI_LeachateCP_&_FGDBio_Alternate Cost Output_08_06_12_50.xl

sx Provides plant-level complia nce costs associated withleachate & FGD chemical precipitation with biological treatment: w ithout retired landfills (FGD_LeachB_C);
these costs are for units with capacity exceeding 50 MW only. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants.CBI_LeachateCP_FGD-Bio.xlsx Provides compliance costs for the ORCR/ OW Incremental Costs and Pollutant Reductions sensitivity analysis. These co sts are associated with treating FGD wastewater with a chemical precipitation an d biological treatment system and leachate using a chemical precipitation system (FGD_LeachB_C). For some plants, ERG
assumed that the FGD wastewater and leachatewould be combined into a single system
for treatment. These costs are associated wi th Regulatory Option 4 for this analysis. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. These are the costs included in the CBI_Leachate-CP_FGD-Bio_Alternate Cost Output_09052012_Excl.xlsx file. CBI_MVC_Costs_08_0 6_12.xlsx Provides plant-level complian ce costs associated with the treatment of FGD wastewater by a chemical precipitation and mechanical vapor compression (FGD_M); these costs are for all units. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants. CBI_MVC_Costs_08_0 6_12_50MW.xlsx Provides plant-level complian ce costs associated with the treatment of FGD wastewater by a chemical precipitation and mechanical vapor compression (FGD_M); these costs are for units with capacity exceeding 50 MW only. Groups plant-level costs by time of incurrence and duration and by industry sector expected to provide technology/services to Steam Electric plants.May 03, 2013 Abt Associates | List of Rulemaking Cost and Economic Impact Files | Page 5 File Name Description/Purpose Costs_08.14.12.xlsx Contains "raw" plant-level co sts for each waste stream/technology for all units. Costs_08.14.12_50MW.
xlsx Contains "raw" plant-level costs for each waste stream/technolo gy for units with capacity exceeding 50 MW. 410_Abt_SER_1 NERC Region Level Prices_04- 09-12 ToAbt.xls Contains NERC-level electricity prices for Option 3 based on IPM projections for the 2015, 2020, and 2030 run years. These runs use IPMv4.10_MATS platform.

CBI_IPM_Units_Incurri ng_Costs_02.06.12_v1.x
lsx Contains information on what generating units at Steam Electric plants get costs associated with a specific waste stream. This information is used for IPM analysis of Option 3. CBI_IPM_Units_Incurri ng_Costs_08.21.12_v1.x
lsx Contains information on what generating units at Steam Electric plants get costs associated with a specific waste stream. This information is used for IPM analysis of Option 4. CBI_Second Round
NSPS Costs_02_13_12.xlsx Contains new-unit compliance costs. It also calculates unit cost per MW and MWh to be used in the IPM analysis of Option 3.

CBI_Third Round NSPS Costs_08062012_CalcFi
le.xlsx Contains new-unit compliance costs for the NS PS options and compar ison of these costs to construction costs for new generation capac ity. It also calculates unit cost per MW and MWh to be used in the IPM analysis of Option 4. InScopeFacilityImpact_2 030_v3.xlsx Contains Market Model Analysis of individual in-scope plants and in-scope plants as a group for the 2030 IPM run y ear (steady-state analysis). IPM_03.05.12.xlsx Contains "raw" Option 3 cost estima tes for IPM analysis for each of the relevant waste

streams. IPM_08.17.12.xlsx Contains "raw" Option 4 cost estima tes for IPM analysis for each of the relevant waste

streams. IPM_Costs_OptionF_Cu rrent_3YrDelay_03.09.1
2.xlsx Contains IPM cost inputs for Option 3.

IPM_Costs_OptionICmb _Current_3YrDelay_08. 23.2012_v1.xlsx Contains IPM cost inputs for Option 4.

IPMCosts_OptionF_Det ails_v2.xlsx Contains generator-level cost estimates used for IPM analysis of Option 3. This file compares these costs to those used fo r the non-IPM analysis of Option 3. IPMCosts_OptionF_v2.x
lsx Contains generator-level cost estimates for IPM Option 3. These are IPM inputs.

IPMCosts_OptionICmb_ Details_v2.xlsx Contains generator-level cost estimates used for IPM analysis of Option 4. This file compares these costs to those used fo r the non-IPM analysis of Option 4. IPMCosts_OptionICmb_
v2.xlsx Contains generator-level cost estimates for IPM Option 4. These are IPM inputs.

MarketImpact_v3.xlsx Contains Market Model Analysis of the electric power market based on the pre-policy and policy (Options 3 and 4) IPM runs for 2030. MstrParsedFile_EPA410 FINAL_BC_244_2015_( To Abt)_02-08-12.xls Contains parsed (generator/boiler-level) base case (pre-policy) IPM projections for the 2015 run year. This run uses IPMv4.10_MATS platform. Indicates what units belong to in-scope plants. NEEDSv410_MATS_ad j.xlsx Contains NEEDS database underlying IPMv4.10_MATS. Indicates what units belong to in-scope plants. ParsedFile_410_ABT_B C_2015_2020_2030_(To Abt)_02-08-2012.xlsx Contains parsed (generator/boiler-level) base case (pre-policy) IPM projections for the 2015, 2020, and 2030 run years. These runs use the IPMv4.10_MATS platform. Indicates what units belong to in-scope plants. ParsedFile_410_ABT_S ER_1_2015_(To Abt)_04-09-2012.xlsx Contains parsed (generator/boiler-level) policy (Option 3) IPM projections for the 2015, 2020, and 2030 run years. These runs us e IPMv4.10_MATS platfo rm. Indicates what units belong to in-scope plants. ParsedFile_410_ABT_S ER_2_(To Abt)_10-01-
2012.xlsx Contains parsed (generator/boiler-level) policy (Option 4) IPM projections for the 2015, 2020, and 2030 run years. These runs us e IPMv4.10_MATS platfo rm. Indicates what units belong to in-scope plants.May 03, 2013 Abt Associates | List of Rulemaking Cost and Economic Impact Files | Page 6 File Name Description/Purpose ParsedFile_EPA410FIN AL_BC_244_2020_(To Abt)_02-08-12.xls Contains parsed (generator/boiler-level) base case (pre-policy) IPM projections for the 2020 run year. This run uses IPMv4.10_MATS platform. Indicates what units belong to in-scope plants. ParsedFile_EPA410FIN AL_BC_244_2030_(To Abt)_02-08-12.xlsx Contains parsed (generator/boiler-level) base case (pre-policy) IPM projections for the 2030 run year. This run uses IPMv4.10_MATS platform. Indicates what units belong to in-scope plants.
Plant-Level Bottom Ash Adjustment Factors_04102013.xlsx Contains plant-level adjustment factors to be applied to each plant's bottom ash costs to calculate the individual cost components for each plant for usin g in the cost and economic impact model. These factors repres ent the percent of plant's costs for units greater than 400 MW and 500 MW. Run 244 NERC Region Level Prices_02-11-11
ToAbt.xls Contains NERC-level electricity prices for th e base case (i.e., pre-policy) scenario based on IPM projections for the 2015, 2020, and 2030 run years. These runs use IPMv4.10_MATS platform. v410_Abt_SER_2 NERC Region Level Prices_10-02-12
ToAbt.xls Contains NERC-level electricity prices for Option 4 based on IPM projections for the 2015, 2020, and 2030 run years. These runs use IPMv4.10_MATS platform.

CBI_WA4- 17_T7_UnitswImpactsD etails_02102012.xlsx Contains information on the majority owners of each surveyed facility.

EJ_Analysis_8-27-
12.xlsx Contains the Environmental Justice analysis.