From: Frey, Nathan J. <Nathan_J._Frey@omb.eop.gov>

Sent: Friday, July 10, 2015 10:03 AM

To: Culligan, Kevin; Harvey, Reid; Vasu, Amy; Owens, Nicole

Cc: Szabo, Aaron; Grossman, Andrea Subject: Summary of interagency comments under EO 12866 and 13563 -- Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units

Attached please find a summary of interagency comments under EOs 12866 and 13563 on EPA’s Response to Summary of Interagency Working Comments and Revised Preamble for the EPA draft final rule Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units

.

Thanks and please let me know if you have any questions.

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### Summary	of	Interagency	Working	Com ments	on	Draft	Language	under EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Re view.

1 ENVIRONMENTAL PROTECTION AGENCY (EPA): Final Rule

Carbon Pollution Emission Guidelines for Exis ting Stationary Source s: Electric Utility Generating Units

RIN 2060-AR33

Comments on EPA’s Response to Summary of Interagency Working Comments and
Revised Preamble

General Comments

Trading

1) Reviewer recommends that the response to interagency comment number #17 (trading) include new and incremental nuclear genera tion in a mass-based state as a measure eligible for ERC issuance in a ra te-based state so long as this generation meets the criteria set out in EPA response #17.

a. Reviewer recommends removing the limitati on that only RE measures could be eligible. Reviewer recommends that any zero emissions generation or efficiency provider could meet the same requirement. 2) Reviewer recommends clarifying EPA’s appr oach in trading comment number #25 of restricting rate-based states from i ssuing ERCs for savings from EE programs implemented in a mass-based state. Reviewer suggests that this could take away an important compliance option a nd that it should be allowe d as long as states can demonstrate that leakage has been addressed. 3) Reviewer recommends that states choosing to apply the two subcategory rates to EGUs also be required to include a demonstration i ndicating that this will result in emissions reductions equivalent to either that statewide rate-based goal or a statewide mass-based goal. Pages 882 and 976 currently state that a state plan establishing emissions standards at or below the performance rates in the em issions guidelines does not have to submit any projection of CO2 emissions performance. 4) Reviewer recommends striking the following language from page 1229: “Under this adjustment, such allowances must be issu ed by a state with an emission budget trading program that only applies to affected E GUs”. This deletion would allow mass based states to count as net imports any allowances from states that have mass-based policies covering unaffected EGUs.

a. Reviewer notes that states that submit plans that include a mass-based policy to
cover affected and unaffected sources must demonstrate that their plan will result in compliance with the mass goals fo r affected sources, and after this demonstration is approved, allowances fr om such a program should be allowed to be traded and counted toward complian ce in any mass based state that uses approved allowance tracking systems. 5) Reviewer recommends additional clarification on pages 1375-79 about “equivalency with a rate-based approach” in the discussion on leakage.

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2 a. Reviewer suggests that this could mean the modelled emissions outcome from all sources if a statewide emissions rate targ et was applied, or a lternatively, if a mass target for all sources was applied. 6) Reviewer notes that the draft rule would allow ERCs to be awarded for any RE, EE, or incremental NGCC under the assumption that fossil steam will be displaced somewhere. This assumption may not hold where large nuclear units require.

a. Reviewer recommends requiring states in a trading arrangement to adjust the ERC supple in the event of a nuclear retiremen t and giving states the flexibility to design this adjustment process. Comment count be taken on these approaches in
the FIP. 7) Reviewer recommends removing the .09 value from the rule with relation to NGCC
ERCs. Reviewer recommends instead referri ng generically to a di scounted value that would reflect BSER at the actual or expected redispatch rate and refer the reader to the
FIP where EPA can take comment on this issue. 8) Reviewer recommends clarifying on page 899 th at when calculating allowances earned by entities that implement early action, the fo rmula be changed to eliminate any siting
distortions associated with di fferential state rate goals.

a. Reviewer recommends, consistent with BS ER and the interco nnected nature of the electricity grid, that i ssued early action allowances are equal to “a number of allowances equivalent to the quantified and verified MWhs realized during the period... divided by two and multiplied by the average rate of the interconnect”. 9) Reviewer recommends clarifying on pages 906-910 which of these flexibilities preclude the state from trading with ot her rate-based states (in line with the new language on pages 1361-62). 10) Reviewer recommends allowing NGCC ERCs to be used to satisfy NGCC compliance and steam compliance instead of just steam. Reviewer notes that having two types of ERCs makes the program more complicated with limited potential benefits, because BB2 ERCs are fungible with general ERCs for steam compliance. 11) Reviewer recommends clarifying on page 1310 th at there is no borrowing in the program from future compliance periods. Reviewer reco gnizes that averaging within a compliance period implicitly allows for borrowing within that period, but encour ages EPA to prohibit borrowing outside the compliance period due to potential reduction in benefits. 12) Reviewer recommends allowing performan ce upgrades at existing renewable energy facilities to qualify for ERC generation if the performance upgrades can be tied to a specific technology improvement and can be verified by proper EM&V methods. 13) Reviewer recommends that the text on page 1255 be edited to read as follows “For RE or NGCC measures to have some or all of its generation counted under a rate-based plan, it must be demonstrated that the generation was delivered to the grid to meet electricity
load in the same state or in another state with the same rate(s).

a. Em issions do not depend on the location of the measure but on the location of the
EGU that decreases the emissions. If a m easure in a blended rate state substitutes solely for generation in a uniform rate st ate, the generator should not be awarded ERCs (at least not at the same ratio) since the incremental CO2 emission
reductions would be less than credite d. EPA acknowledged this issue when it prohibited ERC trading between st ates with different rates.

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3 14) Reviewer recommends clarifying how access to sufficient credits will be assured for states choosing a 2 rate approach. 15) Reviewer recommends clarifying how investment s in natural gas or renewable generation would facilitate compliance for those sour ces in implementation outside of a credit trading context (pages 361, 639-646, 782) 16) Reviewer recommend adjusting the formula for BB2 ERC generati on to reflect actual NGCC capacity factor after BSER building bl ocks application (lower than 75% net summer due to NGCC displacement by RE)

Start Date/ Early Action/ Compliance Path/ Interim Goals

1) Reviewer recommends that in order to incr ease emissions reductions in 2020 and jump start efforts in incentivizing technology, the fi nal rule should include a structured early crediting program. Reviewer also recommends th at this be addresse d in the final rule rather than subsequent rule makings.

a. Reviewer recommends that projects starti ng in 2015-2020 can generate credits in
2020 and 2021 and that this should be incl usive of all zero and low emissions technologies.
b. Reviewer only recommends early action if additional BSER stringency options are incorporated. 2) Reviewer recommends clarifying whether time ex tensions are availabl e to all states and whether they are conditional. 3) Reviewer recommends providing an initial exte nsion of 12 months at which time states must fulfill the same requirements as at the 13 month initial plan to receive an additional
extension.
BSER

1) Reviewer recommends incorporating an interim review and update of what constitutes

BSER in 2023. Reviewer recommends th at, akin to GHG standards for light duty vehicles, EPA commit to performing an inte rim review to enable strengthening the targets based on new information on power ma rkets, technologies, energy policies and climate damages.

Treatment of new NGCC

1) Reviewer recommends clarifying why EPA is prohibiting certain non-BSER options from being made available for compliance based solely on the presumption of leakage (see NGCC EPA response #3). Reviewer recommends that a state should be allowed to rebut a presumption or leakage or demonstrate that it has been addressed. If this rebuttal or showing is made, reviewer recommends incl uding the use of new NGCC for generating

ERCs. 2) Reviewer recommends clarifying the treatment of natural gas in BSER in pages 350 to 354 of the preamble. Reviewer suggests that cost numbers for CO2 emission reductions from new NGCC are comparable with those from the other building blocks and notes that

new NGCC has been shown to be a cost -effective CO2 abatement opportunity. New

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4 NGCC is widely available across all major re gions and inclusion of new NGCC in BSER and compliance would improve economic efficiency an decrease complexity while lowing emission leakage. 3) Reviewer recommends EPA clarify the statemen t indicating that natural gas prices would

increase if new NGCC were included in the program. Reviewer suggests that any price increases would not be signifi cant and would be the same wh ether an increase in demand was met by new plants of increased utilizati on of existing plants. Reviewer recommends striking the language on page 352 on this topic. 4) Reviewer recommends removing the assertion that construction of new NGCC units is “inconsistent with the long-term need to continue reducing CO2 emissions”. Reviewer notes that burning natural gas is about half as carbon inte nsive as coal and that the

Climate Action Plan describes natura l gas as a critical bridge fuel. 5) Reviewer recommends removing the statement that there are “long term policy concerns about construction of additional CO2 emitting ge nerating capacity”. Reviewer notes thatfuture regulations are unlikely to strand new NGCC because they are less capitalintensive than other EGUs and CCS can be added to a new NGCC unit in the future if

necessary. 6) Reviewer recommends removing the statemen t that “including new NGCC capacity in

BSER would distort market in centives to build new NGCC units”. Reviewer notes that the opposite is likely to be true- excluding new NGCC could create market distortions. 7) Reviewer recommends removing the statement that including new NGCC creates “unfair disparities in the compliance opportunities afforded different states”. New NGCC are broadly available and this option is at least as broadly available as the other options. Similarly, reviewer notes that new NGCC build s are as easy to predict as any other new

builds.

Technical Comments 1) Reviewer recommends clarifying in the rule the definition of the term “leakage”. Reviewer suggests clarifying l eakage “from affected to non-affected sources” (see pages 878-881, 1283-4).

a. Reviewer notes that in other places, the rule appears to use the term “leakage” to
refer to a broader set of issues (pages 1358-1360, 1374). 2) Reviewer recommends requiring any state devi ating from the uniform rates provide an emissions projection (including mass and ra te states). Reviewer also recommends specifying that the provided mass caps and blended state rates are conditionally approvable, but that given poten tial leakage issues associated with state plan deviations, states must provide an emissi ons projection to demonstrate equivalence with the uniform rates approach.

a. Reviewer also recommends further requiring that such projections reflect
interactions with interconnected states and trading partners, using assumptions about other states’ plan types that reflect best available information at the time. 3) Reviewer recommends clarifying between pages 29, 1499, 82, and 1156-57 whether the reliability co nsultation in state plans is requi red or optional (some list it as a requirement, and some say that a state can consult with relevant ISOs/RTO s, or that such consultation is an “effective way” to demonstrate reliability.

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5 4) Reviewer recommends clarifying the preamble as to whether use of the RSV will count against the state goal and notes confli cting language between pages 1162, 1163-64, and 1108 (which still retains deleted la nguage from the other sections). 5) Reviewer recommends that the EM&V fram ework enable independent payment for verifiers, rather than payment by projects seeking credit verification. 6) Reviewer recommends clarifying how state plans will avoid forum shopping for EM&V. 7) Reviewer recommends that the link on page 1196 of the preamble between sustainable land management and carbon reductions has not been made, and that this inclusion appears to make biomass fuels subject to additional criteria, since there is no sustainability criteria for the derivation of natural gas or nuclear materials.

a. Reviewer notes that the language on page 1202 of the preamble about monitoring, reporting, and recordkeeping requirements for verifying feedstock type, origin, and associated benefits similarly appears to potentially restrict investment in biomass due to increased oversight and investment uncertainty. 8) Reviewer recommends expanding the response to general interagency comment #18 to include new and incremental nuclear to be elig ible as a compliance option. This would be consistent with language elsewhere in the preamble that allows the use of new and incremental nuclear for compliance. 9) Reviewer recommends editing the text on page 1313 and 1314 on EM&V to read “...M&V reports (and associated EM&V activities), emissions leakage, and state issuance of ERCs...including the qu ality of verifier reviews. The EM&V review must include a quantitative comparison of actual electricity consumption following EE projects with a valid control group and using a rigorous methodology such as randomized control trials. Where significant problems...”

a. This bolsters the review and demonstrates to rate states, as they prepare their SIPs, the need to accurately estimate savings ex ante. 10) Reviewer recommends adding the following lang uage after “all biogen ic feedstocks are “carbon neutral” on page 1199: “nor is it scientifically valid to equate full stack emissions from biomass combustion with fossil sources. The production and use of biogenic feedstocks and subsequent biogenic CO2 emi ssions from stationary sources will not inevitably result in an increased net flux of biogenic CO2 to the atmosphere within
relevant time scales”. This edit is taken from page 6 of the Framework. 11) Reviewer recommends that on page 1199, EPA recognize some of the benefits from biomass feedstocks from the Framework, such as greater levels of carbon sequestration
and other environmental benefits. 12) Reviewer recommends moving some of the discussion of responses to various reliability
studies from the preamble to the response to comments document. 13) Reviewer recommends that EPA clarify the d ecision not to include “under construction” nuclear in BSER due to delays and risks of non-completion of new plants. Reviewer notes that of the 5 units currently under construction, one is set to begin operation by the end of 2015 and 2 by 2019. Further, the V ogtle plants are fully financed.

a. Reviewer continues to recommend treating under construction nuc lear consistent
with renewables.
b. Reviewer notes that if you assume that costs incurred to date for “under construction” (capital and fi nancing costs) of these un its are “sunk”; then as of 2012, under construction expenditures (for total project capita l costs) were

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6 roughly 1/3 completed. For example, a new estimate for Levelized Cost of Energy (LCOE) of these units assuming the 1/3 project completion is $72 per MWh. If we assume the LCOE of new NGCC is $60 per MWh; this is a $12 per MWh difference compared to under cons truction which equals roughly a $33 per
metric ton of avoid CO 2

. 14) Reviewer recommends clarifying whether a state could use a fee-based approach in the state measures framework, per feedback from stakeholders that such an approach could ensure preservation of zero- carbon generation resources. 15) Reviewer recommends clarifying how to trea t lost generation from large “carbon free” energy sources. Reviewer suggests clarifying that the purpose for accounting for lost generation in the denominator is to incentiv ize the continued operation of existing largescale zero emissions generators. This would cr eated a compliance penalty for states that lost existing carbon-free power plants, thus encouraging continued operation. The lost generation should be subtracted from the de nominator of the compliance calculation for the state beginning in the year that the EGU goes offline. 16) Reviewer recommends clarifying section VIII of the preamble to include small modular
reactors. This would be consistent with th e listing of various renewable technologies already included. 17) Reviewer recommends using the maximum five year growth for the initial compliance years in determining BB3 target generation a nd using an accelerated growth case for the final years on page 803. 18) Reviewer recommends clarifying a response to stakeholder comments arguing that existing generation limits in permits will limit the feasibility of BB2. 19) Reviewer recommends using a RE growth ra te multiplier of 1.05 starting in 2024. This is a conservative growth rate given the growth in RE depl oyment seen over recent years. 20) Reviewer recommends removing the technol ogy specific limitation in the IPM model used to determine the regional allocation for BB3 (page 805). Several IPM subregions already exceed 20% wind today. 21) Reviewer recommends cross-referencing th e endangerment and contribution findings from the (b) standards. 22) Reviewer notes that while st ringency has decreased by approximately 20% for the interim years and 10% for 2030 relative to the NPRM, the aggregate cost estimates have changed significantly more from the NPRM. Review er recommends clarifying in the RIA how and why these estimates changed so much. 23) Reviewer recommends indicating whether stat e measures such as RPS and EERS, which are explicitly mentioned for a state-measur es based approach (section VIII.C.3) are acceptable to include as supporting meas ures in an emissions approach. 24) Reviewer notes that the updated costs for renewable energy used in IPM are noted on page 798 (under V.E.6 “Quantification of Renewable Energy Generation Potential for BSER and Major Comments”) but the IPM cost results are not reported here. Reviewer recommends noting on page 798 that future cost projections are not used in setting the BSER directly, only in determining the business as usual generation in 2021 and interconnect apportionment of the BB3 generation. 25) Reviewer recommends clarifying (in the RI A) how EPA arrived at the dem and-side energy efficiency employment impacts.

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7 26) Reviewer recommends clarifying that the secti on VIII.G.5.(f)(1) be amended to read “(1) EM&V requirements that apply to incremental hydroelectric power RE and nuclear

power ” with similar changes to the text to reflect that incremental RE and nuclear capacity upgrades are all compliance methods and use the same methodology as indicated

at the end of this section and at VIII.G.1.(b)(3) “RE and demand-side EE.”

27) Reviewer recommends editing the text in se ction VE3 to clarify that the new BB3 methodology relies primarily on historical de ployment of RE ra ther than economic potential.

28) Reviewer recommends editing the test on page 1367 to read: “To a ddress the risk of leakage to new units in a mass based approach and ensu re equivalency of the approaches, the EPA is requiring... that they have addressed the risk of leakage to new units (either

within the state or interconnect ed new units in other states) in their mass-based state plan...”

a. Reviewer also recommends further cl arifying that option 1 (including new nonaffected fossil EGUs under a state measures plan) may not fully address interstate leakage to new units. Accordingly, if ther e is a risk of interstate leakage, encourage or require states to use output based allocation to address interstate leakage.

b. For states choosing output based allocati on, reviewer recommends clarifying that

the state needs to demonstrate that the chosen allocation rules address both intra and interstate leakage.

29) Reviewer recommends adding the word “privately” to the below language on page 1326 of the preamble redline to allow a pathway for non-publicly funded or non-ratepayer funded projects or programs to submit thei r EM&V reporting every two or three years. This is important since industrial EE projec ts are often funded by the private companies themselves and can obtain energy savings verification over a multi-year period; these projects can then be aggregated by a third- party entity (not necessa rily just a publiclyfunded or rate-payer funded entity). 30) Reviewer recommends clarifying how stat ement on page 1163 regarding emissions during 90 day RSV period not being “counted against the state’ s over (sic) goal” corresponds to the revisions on page 1554 (par agraph (d)) which indicate that “During that period of time, the EGU or EGUS will n eed to comply with the modified emissions standards under the [RSV]...”. Reviewer fu rther recommends clarifying whether all or excess emissions during the RSV are not counted against the state’s overall goal. Reviewer also recomm ends clarifying when the short-term plan modification is required given that the “emergency” emissions are not counted against a state’s overall goal. 31) Reviewer recommends on page 1338, that footno te about the reference rate used for assigning ERCs to CHP be the state’s statewide rate target, even if the state has chosen a rate target that assigns different rates to different technologies or entities. This will

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8 represents the most accurate credit for emi ssions reductions by reducing grid demand in

the state. 32) Reviewer notes on page 798 (V.E.6) that the hydropower cost and performance data comes from NREL’s forthcoming Renewabl e Economic Potential study and not DOE’s Hydropower Vision.

33) Reviewer recommends removing summed capacity numbers given in Table 8. Capacity for utility-scale solar PV are shown in units of MW DC and not MW AC based on the SEIA source. It is not appropriate to sum the PV capacity with the othe r capacities shown. The capacity factor from NREL’ s Annual Technology Baseline ( http://www.nrel.gov/analysi s/data_tech_baseline.html ) includes a DC-to-AC conversion, so the resulting MWh are MWh AC and can be appropriately summed with the other technologies’ generation numbers. 34) Reviewer recommends adding text to the RE supply chain discussion to indicate that the materials at highest risk are not used in current solar technolog ies (Page 817). “For solar, the global supply chain has a capacity that ha s significantly expanded over the past few years from 1.4 GW/yr in 2004 to 22.5 GW/yr in 2011. Current capacity exceeds these levels and is expected to grow. For PV syst ems, raw materials like tellurium and indium are at highest risk of supply shortage, but these materials are not used in the PV technologies currently being deployed at large-scale.” 35) Reviewer recommends deleting the specific re ference to vehicle electrification on page 1285. It is our understanding that no CO 2 emission reductions that occur in the transportation sector would count toward CO 2 emission performance levels

36) Reviewer recommends that the RIA be clarified to show how the rule is likely to affect regulated entities and the economy at large. Reviewer recommends providing relevant estimates and supporting documents so that the adequacy of the RIA and it’s comportment with the requirements w ith circular A-4 can be assessed.

37) Reviewer recommends addressing the inte raction between ERCs and RECs to acknowledge in state REC requirements wh ere necessary. Reviewer recommends including the text below on page 1314 of revised draft: “However, as the requirements and definitions for RECs differ as established under individual state policies, indi vidual states may need to de termine how ERC certifications offered in a state plan interact with existi ng instruments authorized and defined in state law, particularly with respect to how the same MWh of RE genera tion or EE savings can be used for both state plan compliance and other state policies, such as RPSs.” 38) Reviewer recommends clarifying that CSP is now included as a building block 3 technology, and this should be indicated in section V.E.8 “Cost of CO2 Emission Reductions from Renewable Energy Genera tion” where it lists CSP as a non-BSER compliance option.

39) Reviewer recommends clarifying the meani ng of the sentence on page 719 beginning “with the exception of emissions cr editing (discussed further below).”

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9 Typographical Comments 1) Reviewer recommends removing the “some” be fore “biomass-derived fuels” on page 469 of the preamble. 2) Reviewer recommends removing the word “also ” before “anticipates that some states may consider the use of certain biomass” on page 1195 because it could be read to say
that what follows is in addition to what was in the previous sentence. 3) Reviewer recommends removing the word “policy” from “climate policy benefits” on page 1195 because the benefits are in stead direct climate benefits. 4) Reviewer recommends removing the “sustainab ly-derived” reference on page 1194 of the preamble, as the comments focused on the us e of any agricultural or forest biomass
feedstock. 5) Reviewer recommends replacing the langua ge on page 1195 reading “waste-derived biogenic feedstocks and certain forest a nd agriculture derive d industrial byproduct feedstocks” with “an array of biogenic feedstocks”. The revised Framework for Assessing Biogenic Carbon Dioxide for Stationa ry Sources determined significant carbon
benefits from all of the cas e studies they examined. 6) Reviewer recommends updating the language re garding nuclear in section V.A.3.c to avoid implying that government-s upported projects will fail. 7) Reviewer recommends harmonizing the la nguage surrounding EM&V for EE, RE, and other measures under a state-measures pl an. Under section VIII.C.1 “State Plan Approaches” it states that state-measures plan s must use the state’s mass based target, but in section VIII.G.3 “EM&V requirements for RE, demand-side EE, and other measures used to adjust a CO2 rate” it states “In stat es implementing state measures type plans, quantified and verified MWh of RE, EE, and other eligible measures may be used to adjust an emission rate...”implying that state measures plans can be included in rate goals. 8) Reviewer recommends clarification / recons ideration for using the word “inverter” on pages 1338-1339, as this limits the CHP pr ime mover technology and precludes CHP systems that are generators. 9) Reviewer requests clarification for the term “generator bus bar” on page 1339. Reviewer is concerned that by limiting the adjustment to the generator bus bar, credit would not be granted for electricity sold to the grid. 10) Reviewer requests clarification for why the a voided T&D losses is limited to small CHP systems only, by virtue of including in the seco nd paragraph that begins with “For small systems.” Reviewer recommends breaking that sentence out as a stand-alone statement so its applicability is not li mited to small systems. 11) Reviewer requests replacing the term “uni form conversion method” on page 1240 with “(standard conversion of 3412 Btu/kWh)”. 12) Reviewer recommends reiterating in this senten ce what these revised findings are so it’s clearer on page 23. Reviewer also recommends deleting the word “energy,” because this is an environmental and emissions strategy.

a. “Due to thes e revised findings, we expect the final guidelines will be more conducive to compliance, consistent with an energy strategy that allows for the cleanest generation and greater reducti ons in 2030 than the proposal.”

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10 13) Reviewer suggests retaining th e word “IGCC” on page 266 which had been struck from the following sentence: “For the emission guide lines, an affected EGU is any fossil fuelfired electric utility steam generating unit...” 14) Reviewer recommends that when the preamble re ferences the DOE analysis for RE that it refers instead to the DOE and NREL analysis (rather than just DOE analysis). On page 810, 816.

15) Reviewer recommends that pages 84 and 1165, on coordination among federal partners say that “staff” from the three agencies have coordinated, as descri bed in the referenced document on those pages.

16) Reviewer recommends adding language on page 68 where Plan Approaches are introduced describing that state measures pl ans may only be used to meet a state mass CO2 emissions goal. Reviewer also recommends making sure this reference is consistent across the text. See, for example, on page 984, says “Projections for a rate-based state measures plan.”

17) Reviewer recommends on page 1292, 1294, and 1295 that EPA clarifies that not only incremental NGCC generation can earn ERCs , but all NGCC generation can earn ERCs, as stated later on page 1295: “This factor [0.09 ERCs/MWh] can be applied to every MWh of generation by an affected NGCC unit...”

18) Reviewer recommends moving the sentence “ However, the overall technical potential for RE development significantly exceeds any analysis EPA has conducted to quantify potential building block three generation levels” as it does not pertain to the ability to accommodate high levels of variable RE (page 813). Instead this sentence could be used at the top of page 812, before the paragraph that begins “ Grid operators are reliably integrating large amounts... ”

19) Reviewer recommends clarifying the follo wing text regarding comparing BB3 wind deployment to Wind Vision: "11.5 GW/yr exceeds building block three deployment

levels for wind capacity over the compliance period ." (Page 814)

20) Reviewer recommends changing text on page 1151 to read “Sixth and finally we are committed to maintaining an ongoing relationshi p with FERC and DOE as this final rule is implemented to coordinate efforts to help ensure continued reliab le electric generation
and transmission

. 21) Reviewer recommends striking the la nguage “as a proposal” on page 17.

22) Reviewer recommends changing “existing ga s” to “existing NGC C.” On page 54.

23) Reviewer recommends editing language on page 163 to read “problems attaining the ozone NAAQS” rather th an “ozone problems”

24) Reviewer recommends editing language on page 272 to read “combining the listing of the
sources into one location” rather than “comb ining the sources into one location”. Similar edit on page 271.

25) Reviewer recommends clarifying on page 755 and elsewhere whether EPA is describing “electric” or “gas” transm ission.

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11 26) Reviewer recommends editing on page 1148 that the compliance average period is 2022 to 2029, not 2024.

27) Reviewer recommends changing the sentence on page 1244 to say (change underlined):

“ERCS or allowances distributed from the i nvestment pool may also be used by affected EGUs to demonstrate compliance with an emission standard, and may be banked from the interim to final periods.”

28) Reviewer requests clarification between tw o nearly duplicate para graphs on pages 1339- 1340 both beginning with “for small systems”.

29) Reviewer notes a sentence fragment on page 1362 including “states must all adopt as their goal the Cos emissi on performance rates...”

30) Reviewer recommends defining the term equiva lency in first reference in the preamble.