### www.AndoverTechnology.com 

# James E. Staudt, Ph.D. , CFA

Dr. Staudt is a nationally

- recognized expert in the field of control of air pollution em issions from
combustion sources

. Dr. Staudt has authored emissions control technology documents and
software that are used by air pollution control professionals in the United States, Europe, and Asia

. He has developed cost and performance algorithms that are used by the US Environmental Protection Agency for a ssessment of NOx, SO 2 

### and mercury control technologies. Since forming Andover Technology Partners in 1997 , Dr. Staudt has advised plant owners/operators, emission control technology suppliers, and government agencies on methods to comply with emissions

re gulat ions in a cost

- effective manner.

Recent activities by Dr. Staudt include :

• ongoing development of US EPA’s Gree nhouse Gas Technology database

• supporting EPA regions on BART analyses

• development of cost and performance data on emission control technologies, new facilities and energy efficiency measures for US EPA’s new Industrial Sector Integrated Solutions (ISIS) modeling too l used to model Portland Cement, Iron & Steel and Pulp & Paper
industrial sectors

,

• suppor t of state rulemaking measures,

• benchmarking of GHG emissions technologies for private sector clients, and

• development /deployment of mercury emission and NOx emission control technologies.

Dr. Staudt’s previous employers include suppliers of air pollution control or monitoring technolog y to the electric power industry and other industries.

• Vice President for Business Development at Spectrum Diagnostix (SDX) from 1995

- 1997, Dr.
Staudt directed the commercial activities for t his development

- stage company that offered advanced process gas analyzer s

- to the petrochemical, electric utility, and ch emical process
industries.

• Product Director of NOx Control at Research

- Cottrell from 1992

- 1995, Dr. Staudt started Research Cottrell’s NOx control product line

.

• Programs Manager at Fuel Tech, Inc. f rom 1988

- 1990, Dr. Staudt managed a chemical process engineering group in the United States and managed company field op erations in Germany and Japan.

Education and Professional Credentials

• B.S. in Mechanical Engineering from the U.S. Naval Academy (1979)

• M.S. (1986) in Engineering from the Massachusetts I nstitute of Technology (M.I.T.)

• Ph.D (1987) in Engineering from the Massachusetts I nstitute of Technology (M.I.T.)

• Chartered Financial Analyst (CFA) designation (2001)

Awards

2007 US Environmental Protection Agency Science and Technology Achievement Award Providing the Public with a Comprehensive Summary of Technologies for Control of Mercury Emissions from Electric Utility Boilers

### www.AndoverTechnology.com Business and Professional Associations

• Associate Member, Institute of Clean Air Companies

• Member, CFA Institute

• Member, Air and Waste Management Association

Military Service

From 1979 to 1984 Dr. Staudt served as a commissioned officer in the U.S. Navy in the Engineering Department of the nuclear

- power ed aircraft carrier USS ENTERPRISE (CVN

- 65), attaining the rank of Lieutenant (O

- 3) prior to leaving the service.

Expert Witness last four years

2011/2012 US Department of Justice

– expert witness for US Department of Justice in litigation relating to
SO 2 

### emissions from a Kraft pulp mill. Trial date is in December 2012 in US District Court, Baltimore, MD.

2009 Chase Power, LLC

– testimony at contested case hearing before the Texas State Office of Administrative Hearings conc e rning Las Brisas Energy Cente r LLC's application to the Texas Commission on Environmental Quality for an air permit authorizing the construction of the Las Brisas Energy Center . Testimony was specifically concerning the possible use of SCR technology
for NOx control at the proposed facility.

2008 Attorney General of North Carolina v. Tennessee Valley Authority

– testimony in US District Court, Asheville, NC, regarding methods for TVA to reduce emissions of NOx and SO 2 

### from its
fleet of coal generating plants and the associated costs

.

### www.AndoverTechnology.com PUBLICATIONS (2002

- 2012)

Staudt, J., “ Candidate SO 2 Control Measures for Industrial Sources in the LADCO Region ”, for Lake Michigan Air Director’s Consortium,, January 24, 2012. Staudt, J., “Engineering and Economic Factors Affecting the Installation of Control Technologies

– An Update”, for US EPA Clean Air Markets Division, December 15, 2011 Staudt, J., “ Air Pollution C ompliance Strategies for Coal Generation ”, EUCI, Arlington, VA, December 5

- 6, 2011
available at www.AndoverTechnology.com Staudt, J., ” Labor Availability for the Installation of Air Pollution Control Systems at Coal Fired Power Plants ”

, October 31, 2011, at www.AndoverTechnology.com Staudt. J. and M J Bradley & Associates, for the Northeast States for Coordinated Air Use Management, “Control Technologies to Reduce Conventional and Hazardous Air Pollutants from Coal

- Fired Power Plants”, March 31,
2011
Staud t, J., “Surviving the Power Sector Environmental Regulations”, The Bipartisan Policy Center's, National Commission on Energy Policy (NCEP), Workshop on Environmental Regulation and Electric System Reliability, Washington, DC October 22, 2010 Staudt, J, Hoover, B., Trautner, P., McCool, S., Frey, J., “Optimization of Constellation Energy’s SNCR System at Crane Units 1 and 2 Using Continuous Ammonia Measurement”, The MEGA Symposium, Baltimore, MD, August 31

- September 2, 2010 Staudt, J., “White Paper

– Availability of Resources for Clean Air Projects”, October 1, 2010, available at: www.AndoverTechnology.com Staudt, J., White , J., Heinlein, C., Hoover, B., Trautner, P., Airey

, R., McCool, S., Frey, J., and Afonso , R.,

“ Optimization of SNCR Systems with Continuous Measurement of Ammonia Slip at Constellation Energy’s Crane
Units 1 and 2 ”, International Power Generation Conference, Las Vegas, NV, December 8

- 10, 2009 Staudt, J., White , J., Heinlein, C., Hoover, B., Trautner, P., Airey, R., McCool, S., Frey, J., and Afonso, R., “Optimization of SNCR Systems with Continuous Measurement of Ammonia Slip at Constellation Energy’s Crane Units 1 and 2”, International Power Generation Conference, Las Vegas, NV, December 8

- 10, 2009 Staudt, J., “Commercializing technologies: The buyer’s perspect ive

- E xperience from the Clean Air Act”, 3 rd US Carbon Finance Forum, New York City, September 15

- 16, 2009 Yang, X., Tran, P., Shore, L., Mack, S., Staudt, J., “Pollutant emission control sorbents and methods of manufacture”,
US Patent No. 7,575,629, August 18, 2009. Staudt, J., Erickson, C., “Selective Catalytic Reduction System Performance and Reliability Review”, presented at the
International Power Generation Conference “ Power

- Gen ”

, Orlando, FL, December 2

- 4, 2008 Staudt, J., Khan, S., “Updating Performance and Cost of SO 2 Control Technologies in the Integrated Planning Model and the Coal Utility Environmental Cost Model”, EPA

- EPRI

- DOE Combined Utility Air Pollution Control Symposium

– The Mega Symposium, Baltimore, MD, August 28

- 31, 2006 Srivastava, R., Hutson, N. Princio tta, F., Martin, B., and Staudt, J., “ Control of Mercury Emissions from Coal

- Fired Electric Utility Boilers ”. Environmental Science & Technology , 41(5):1385

- 1393 (2006) Erickson, C., Staudt, J., “Selective Catalytic Reduction System Performance and Reliabi lity Review”, EPA

- EPRI

- DOE Combined Utility Air Pollution Control Symposium

– The Mega Symposium, Baltimore, MD, August 28

- 31, 2006 Mann, A., Sarkus, T., Staudt, J., “SCR Comes of Age”, Environmental Manager , published by the Air and Waste Management Asso ciation, November 2005, pp. 22

- 26. Srivastava, R., Neuffer, W., Grano, D., Khan, S., Staudt, J., and Jozewicz, W., “ Controlling NOx Emissions f rom Industrial Sources”, Environmental Progress , Wiley Interscience, Volume 24, No. 2, July 2005 , pp. 198

- 213.
Sr ivastava, R., Staudt, J., and Jozewicz , W., “ Preliminary Estimates of Per formance and Cost of Mercury Emission Control Technology Applications on Electric Utility Boilers: An Update ”, Environmental Progress , Wiley Interscience, Volume 24, No. 2, July 2005

, pp. 181

- 197. Staudt, J., Khan, S., Oliva, M., “Reliability of Selective Catalytic Reduction (SCR) and Flue Gas Desulfurization (FGD) Systems for High Pollutant Removal Efficiencies on Coal Fired Utility Boilers”, presented at the EPA

EPRI

- DOE Combined Uti lity Air Pollution Control Symposium

– The Mega Symposium, August 30

- September 2, 2004, Washington, DC, Paper # 04

- A

- 59

- AWMA Srivastava, R., Staudt, J., and Jozewicz, W ., “Preliminary Estimates of Per formance and Cost of Mercury Emission Control Technology Applications on Electric Utility Boilers: An Update”, presented at the EPA

- EPRI

- DOE Combined Utility Air Pollution Control Symposium

– The Mega Symposium, August 30

- September 2, 2004, Washington, DC, Paper # 04

- A

- 59

- AWMA Wicker, K., and Staudt, J., “SCR M aintenance Fundamentals” Power Magazine , June 2004

### www.AndoverTechnology.com Staudt, J., “Minimizing the Impact of SCR Catalyst on Total Generating Cost Through Effective Catalyst Management”

, Proceedings, ASME Power 2004, ASME Power Conference, Baltimore, Maryland, March 30

- Apr il 1, 2004 Staudt, J., “Optimizing Compliance Cost for Coal

- Fired Electric Generating Facilities in a Multipollutant Control
Environment”

, Proceedings ASME Power 2004, ASME Power Conference, Baltimore, Maryland, March 30

- April 1, 2004 Staudt, J.E., and Jozewicz, W., “Performance and Cost of Mercury and Multipollutant Emission Control Technology Applications on Electric Utility Boilers”, EPA

- 600/R

- 03

- 110, October 2003 Staudt, J.E., “Optimizing Compliance Cost for Coal

- Fired Electric Generating Facilit ies in a Multipollutant Control Environment” Presented at ICAC Forum 2003, Nashville, TN, October14

- 15, 2003 Staudt, J.E., Engelmeyer, A., “SCR Catalyst Management

– Modeling and Experience”, presented at Coal Gen, August 6

- 8, 2003, Columbus, OH Staudt, J.E., Engelmeyer, A., “SCR Catalyst Management

– Modeling and Experience”, presented at the EPA

- EPRI

DOE Combined Utility Air Pollution Control Symposium

– The Mega Symposium, May 20

- 25, 2003, Washington, DC, Paper # 03

- A

- 57

- AWMA Staudt, J.E., Jozewicz, W. , Srivastava, R., “Modeling Mercury Control with Powdered Activated Carbon” presented at
the EPA

- EPRI

- DOE Combined Utility Air Pollution Control Symposium

– The Mega Symposium, May 20

- 25, 2003, Washington, DC
, Paper # 03

- A

- 17

- AWMA Staudt, J.E., “ NOx Emiss ions Trading Markets

– An Approach for Using Them In Your Strategic Planning ”, DOE SCR/SNCR Conference, Pittsburgh, May 15

- 16, 2002 Staudt, J.E., Andover Technology Partners, “Analysis of the Stationary Point Source NOx Control Market in the
Houston Galveston Area”, made available under license from Andover Technology Partners, April 2002 Staudt, J.E., Engelmeyer, A., Weston, W.H., Sigling, R., “ Deactivation of SCR Catalyst from Arsenic

– Experience at OUC Stanton and Implications for Other Coal

- fired Boilers”, DOE SCR/SNCR Conference, Pittsburgh, May 15

- 16, 2002 Staudt, J.E., Andover Technology Partners, “Selective Catalytic Reduction

– Operating Principles, Operating Guidelines, Troubleshooting Guide”, made available under license from Andover Techn ology Partners, February
2002 Staudt, J.E., Engelmeyer, A., Weston, W.H., Sigling, R., “The Impact Of Arsenic On Coal Fired Power Plants Equipped With SCR”, ICAC Forum 2002, Houston, February 12

- 13, 2002

### www.AndoverTechnology.com 

# Related Projects by Andover Technology Partners

Title: Best Available Retrofit Technology (BART) analysis and BART related support

Client: EPA Regions 8 and 9

- through EC \ R and ICF International, respectively

Scope: Performed BART technology and cost analysis for industrial sources and electric gener ating units (visibility analysis performed by others). Also assisted regions respond to comments, as needed. Industrial sources included industrial boilers, cement kilns, lime kilns, combustion turbines, and reciprocating internal combustion engines.

Period of Performance: 2012

Title: Candidate Control Measures for SO 2 Control from Industrial Sources

Client: Lake Michigan Air Directors Consortium (LADCO)

Scope: Performed a study and published a report that evaluated candidate SO2 control measures fo r a wide range of industrial sources in the LADCO region, to include: Industrial Boilers, Cement Kilns, Lime Kilns, Iron and Steel Mills, Refineries, Chemical Plants, Glass furnaces, and others. A report was published
and is available on the 

### LADCO website :

Period of Performance: 2011/2012

Title: Control Technologies to Reduce Conventional and Hazardous Air Pollutants from Coal

- Fired
Power Plants

Client: MJ Bradley and Associates

Scope: Prepared a report in collaboration with MJ Bradley and Associates on the topic of control technologies for control of NOx, SO2, and Air Toxics (particle matter, acid gases, mercury, etc.) for coal fired power plants and the application of these technologies for compliance with US EPA rules. A report was published by the N ortheast States for Coordinated Air Use Management ( 

### NESCAUM ).

Period of Performance : 2011

Title: Greenhouse Gas Technology Database

Client: US EPA (through Eastern Research Group and RTI International)

Scope: Developing Greenhouse Gas Technology Database for US EPA for power plants and cement kilns. Effort includes collection and analysis of data on performance and cost of various greenhouse gas control technologies.

Period of Performance: Spring 2009

- present

Title: Emissions Control for Power Plants

Cl ient: US EPA (through ICF Consulting)

Scope: Comprehensive evaluation of NOx, SO 2 , and CO 2 emissions from power plants and development of capital cost, variable and fixed operating cost algorithms for control measures as well as impacts (energy use, water use, emissions reduction) for use in the Integrated Planning Model. Assisted EPA with analysis for Mercury and Air Toxic Standards, to include analysis of Information Collection Request (ICR) Data to
determine emission levels and controls needed for diffe rent sources. Also analyzed the availability of and demand for labor and other resources necessary for compliance with the MATS and Cross State Air Pollution Rule (CSAPR).

### www.AndoverTechnology.com Period of Performance: Fall 2009

- present

Title: Emissions Control for Cement Kiln s

Client: US EPA (through ICF Consulting and Eastern Research Group)

Scope: Comprehensive evaluation of NOx, SO 2 , and CO 2 emissions from cement kilns, and development of capital cost, variable and fixed operating cost algorithms for control measures as well as impacts (energy use, water use, emissions reduction) for use in the US EPA Industrial Source Integrated Solutions (ISIS)
Model.

Period of Performance: Fall 2008

- present

Title: Emissions Control for Iron and Steel Mills

Client: US EPA (through Eas tern Research Group)

Scope: Comprehensive evaluation of NOx, SO 2 , and CO 2 emissions from Iron and Steel Mills, and development of capital cost, variable and fixed operating cost algorithms for control measures as well as impacts (energy use, water use, emi ssions reduction) for use in the US EPA ISIS Multi

- Sector Model.

Period of Performance: Spring 2009

- present

Title: Emissions Control for Pulp and Paper Mills

Client: US EPA (through RTI International)

Scope: Comprehensive evaluation of NOx, SO 2 , and CO 2 emissions from Pulp and Paper Mills, and development of capital cost, variable and fixed operating cost algorithms for control measures as well as impacts (energy use, water use, emissions reduction) for use in the US EPA ISIS Multi

- Sector Model.

Period of Performance: Spring 2009

- present

Title: NOx Control

– NOx RACT

Client: State of Illinois, Bureau of Air (Contract with Lake Michigan Air Director’s Consortium)

Scope: Providing technical support to the Illinois Environmental Protection Agency’s Bureau of Air in developing rules for control of NOx at electric generating units, gas turbines and reciprocating engines and steel mills, cement plants, glass

- manufacturing plants, refineries, and other industrial facilities.

Period of Performance: 2007

- 2009

T itle: Best Available Retrofit Technology for EGU’s in Illinois

Client: State of Illinois, Bureau of Air (Contract with Lake Michigan Air Director’s Consortium)

Scope: Providing technical support to the Illinois Environmental Protection Agency’s Bureau of A ir in evaluating BART for specific IL EGUs.

Period of Performance: 2007

- 2008

Title: Air Pollution Reduction at Tennessee Valley Authority Plants

Client: Attorney General of North Carolina

Scope: Providing expert witness analysis of methods to reduce air pollution from TVA coal power plants.

Period of Performance: 2006

- 2008

### www.AndoverTechnology.com Title: NOx and SO 2 Cost of Control under the Clean Air Act Amendments

Client: US Environmental Protection Agency and ICF Consulting

Scope: Providing technical support to the US EPA Clean Air Markets Division and analyzing the cost of compliance with Title IV (NOx and SO 2 Acid Rain provisions) of the Clean Air Act Amendments (CAAA) and the NOx SIP Call and OTC NOx Budget Rule that were issued under Title I of the CAAA.

Period of Performance: 2006

Title: Mercury Emissions Control

Client: State of Illinois, Bureau of Air (Contract with Lake Michigan Air Director’s Consortium)

Scope: ATP provided technical support to the Illinois Environmental Protection Agency’s Bureau of Air in
d eveloping a rule to meet the Illinois Governor’s proposed reduction in Illinois power plant mercury
emissions.

Period of Performance: 2006

- completed

Title: Update of Coal Utility Environmental Cost (CUECost) Model

Client: US EPA and ARCADIS, P.O. Box 1 3109, Research Triangle Park, NC 27709

Scope: ATP developed cost and performance algorithms for mercury emissions control including cobenefits, powdered activated carbon and halogenated powdered activated carbon. Also developed SO 2 control cost and perform ance algorithms. These and other updates were incorporated into EPA’s CUECost model.

Period of Performance: 2005

- 2006

Title: SO 2 Control Cost and Performance

Client: US EPA and ICF Consulting, 9300 Lee Highway, Fairfax, VA 22031 (703) 934

- 3071

Scope: ATP supported ICF Consulting and US EPA in developing cost and performance models for limestone forced oxidation (LSFO) and Spray Drier Absorber technology that will be incorporated into the Integrated Planning Model. Reviews of installed installation data an d vendor quotes was used to develop algorithms.

Period of Performance: 2005

Title: NOx Control Technology

Client: US Environmental Protection Agency and ICF Consulting, 9300 Lee Highway, Fairfax, VA 22031 (703) 934

- 3071

Scope: ATP supports ICF and the US Environmental Protection Agency in an ongoing program to evaluating NOx, SO 2 and Mercury control technologies for electricity generating facilities and industrial plants.

Period of Performance: ongoing

Title: Reliability of Selective Catalytic Reduction (SCR) and Flue Gas Desulfurization (FGD) Systems for High Pollutant Removal Efficiencies on Coal Fired Utility Boilers

Client: US Environmental Protection Agency and ICF Consulting, 9300 Lee Highway, Fairfax, VA 22031 (703) 934

- 3071

### www.AndoverTechnology.com Scope: ATP evaluated th e reliability of recently installed SCR systems designed for very high removal efficiencies (over 90%) and also FGD technologies.

Period of Performance: 2004

Title: Performance and Cost of Mercury and Multipollutant Emission Control Technology Applications on Electric Utility Boilers, EPA

- 600/R

- 03/110 issued October 2003

Client: US EPA and ARCADIS, P.O. Box 13109, Research Triangle Park, NC 27709

Scope: ATP was the principal subcontractor to ARCADIS in evaluating the performance and cost of mercury and multipollutant control methods (NOx, SOx, PM, Hg) for the US EPA. ATP developed cost and performance models to assess the emission control strategies for control of mercury, NOx, SO 2 and PM and other pollutants for abou t 50 model plants. Results are documented in EPA report EPA

- 600/R

- 03/110 issued October 2003, which may be downloaded from EPA’s web site.

Period of Performance: 2002

- 2003

Title: Cost and Performance of NOx Controls

Client: US EPA and ICF Consulting, 930 0 Lee Highway, Fairfax, VA 22031 (703) 934

- 3071

Scope: As a subcontractor to ICF Consulting, ATP has evaluated the cost and performance of state

- of

- the

art combustion NOx controls and the cost and performance experienced with Selective Catalytic Reduction systems installed in response to the NOx SIP Call. Project entailed review of public information and interviews with industry contacts to collect cost and performance information, and reporting of the information to EPA and ICF.

Period of Performance: fall 2002

– fall 2003

Title: Engineering and Economic Factors Affecting the Installation of Control Technologies for Multipollutant Strategies, EPA

- 600/R

- 02/073, October 2002

Client: US EPA and ARCADIS, P.O. Box 13109, Research Triangle Park, NC 27709

Scope: As a subcontractor to ARCADIS, ATP analyzed the feasibility of complying with Multipollutant Control programs under evaluation by EPA. Report examined the feasibility of mercury, SO 2 , and NO X control technology implementation based upon forecasted technol ogy installation schedules for the Clear Skies Initiative.

Period of Performance: Fall 2001

- Spring 2002

Title: Status Report on NOx Controls for Gas Turbines, Cement Kilns, Industrial Boilers, Internal Combustion Engines

– Technologies and Cost Effectiveness

Client: Northeast States for Coordinated Air Use Management

Scope: Comprehensive report on technologies, performance and cost effectiveness of methods to control NOx from gas turbines, cement kilns, industrial boilers, and internal combustion engines.

Period of Performance: released December 2000

Title: Status Report on NOx Control Technologies and Cost Effectiveness for Utility Boilers

Client: Northeast States for Coordinated Air Use Management

Scope: Comprehensive report on technologies, p erformance and cost effectiveness of methods to control NOx from utility boilers.

Period of Performance : released December 2000