### Author: Abt Associates Inc.

Date Created: 7/11/2008 Date Modified: 3/30/2011 Purpose: This file contains calculations of enetity-level cost-to-revenue ratios for entities owning in-scope facilities using facility- and entity-level weights. Analysis assumed that parent entities assume 100% compliance costs. (CBI)

File Contents: Worksheet Contents Assumptions Lists assumed constants used throughout the cost and economic impacts analysis model as well as various adjustment indexes for dollar years adjustments.

FacilityInfo Contains facility-level information used for this analysis. Reads in parent-level information from the ParentSize.xls file. Reads in facility-level information that depends on the option selected from the Private_Costs.xls file. Reads in facility-level information that does not depend on the option selected from the PlantData.xls file. FirmWts Contains entity-level weights from the ParentSize.xls file. CTR_Calcs_Low Contains entity-level cost-to-revenue calculations using unweighted and weighted after-tax compliance costs. Reads facility-level information from the FacilityInfo worksheet and firm-level information from the ParentSize.xls file. AnalysisSummary (unwtd costs) Presents summary results of the entity-level impact analysis using unweighted costs for all entities. AnalysisSummary (wtd costs) Presents summary results of the entity-level impact analysis using weighted costs for all entities. Table Contains a summary table of analysis results.

Input Files: External data used in calculations/analysis: ParentSize.xls PlantData.xls Private_Costs.xls

The original version of this file contains, or is linked to a file that contains, confidential business information (CBI), or information that could be used to reveal CBI. As a result, the values for any variables determined by EPA to be CBI, or that could be used to reveal CBI, have been concealed.

FileInfo 1 of 53Discount Rate 7% 88%

Option EG_AllIM_NE11B_08-03-10 Weights P2RR - 29Sep10_NERC_125MGD Discounting Year Analysis Year (2015) 2 3 4 5 2 3

2 3 4 5 6 7 8 9 10 Entity-Level Cost-to-Revenue Meausre by Entity Type

Number of Entities with a Ratio of < 1% 1% - 3% > 3% Unknown Entity-level cost-to-revenue impact calculated using facility weights but not using entity weights Cooperative 25 11 10 0 1 0 0.00% 4.09% Federal 16 1 1 0 0 0 0.22% 0.22% Investor-Owned 306 39 39 0 0 0 0.00% 0.65% Municipality 25 13 9 4 0 0 0.00% 2.55% Nonutility 170 29 22 0 1 6 0.00% 47.84% Political Subdivision 0 0 0 0 0 0 0.00% 0.00% State 17 4 4 0 0 0 0.00% 0.67% Total 559 97 85 4 2 6 0.00% 47.84% Entity-level cost-to-revenue impact calculated using entity weights but not using facility weights Cooperative 13 20 18 2 0 0 0.00% 1.78% Federal 7 1 1 0 0 0 0.09% 0.09% Investor-Owned 138 43 43 0 0 0 0.00% 0.16% Municipality 13 35 35 0 0 0 0.00% 0.82% Nonutility 78 37 28 0 1 8 0.00% 22.74% Political Subdivision 0 0 0 0 0 0 0.00% 0.00% State 8 4 4 0 0 0 0.00% 0.29% Total 257 140 129 2 1 8 0.00% 22.74% UsingLowCost Estimates

Maximum Ratio Parent Entity Type Total Number of Entities Total Number of Facilities Minimun Ratio

Table 2 of 53

### Discount Rate 7%

Option EG_AllIM_NE11B_08-03-10 Weights P2RR - 29Sep10_NERC_125MGD Discounting Year Analysis Year (2015)

Summary of entity-level cost-to-revenue analysis using facility-level weights (i.e., using weighted costs).

1 2 3 4 5 

## Firm and Facility Counts by Ownership Type

Entity Type Minimum Ratio Maximum Ratio Cooperative 0.00% 4.09% Federal 0.22% 0.22% Investor-Owned 0.00% 0.65% Municipality 0.00% 2.55% Nonutility 0.00% 47.84% Political Subdivision 0.00% 0.00% State 0.00% 0.67% Total 0.00% 47.84%


## Final Parent Count by Type and Cost-Revenue Range

Ownership Type <1% 1-3% >=3% NA Without Firm-Level Weights Cooperative 10 0 1 0 Federal 1 0 0 0 Investor-owned 39 0 0 0 Municipality 9 4 0 0 Nonutility 22 0 1 6 Political Subdivision 0 0 0 0 State 4 0 0 0 Total 85 4 2 6 With Firm-Level Weights Cooperative 18 0 2 0 Federal 1 0 0 0 Investor-owned 43 0 0 0 Municipality 24 11 0 0 Nonutility 28 0 1 8 Political Subdivision 0 0 0 0 State 4 0 0 0 Total 118 11 3 8 CTR UsingLowCost Estimates UsingLowCost Estimates

Summary

(wtd costs) 3 of 53

### Discount Rate 7%

Option EG_AllIM_NE11B_08-03-10 Weights P2RR - 29Sep10_NERC_125MGD Discounting Year Analysis Year (2015)

Summary of entity-level cost-to-revenue analysis without facility-level weights (i.e., using non-weighted costs).

1 2 3 4 5 Firm-Level Cost-to-Revenue Measure by Entity Type for the Preferred Option

Entity Type MinimumMaximum Cooperative 0.00% 1.78% Federal 0.09% 0.09% Investor-Owned 0.00% 0.16% Municipality 0.00% 0.82% Nonutility 0.00% 22.74% Political Subdivision 0.00% 0.00% State 0.00% 0.29% Total 0.00% 22.74%

Final Parent Count by Type and Cost-Revenue Range

Ownership Type <1% 1-3% >=3% NA Without Firm-Level Weights Cooperative 10 1 0 0 Federal 1 0 0 0 Investor-owned 39 0 0 0 Municipality 13 0 0 0 Nonutility 22 0 1 6 Political Subdivision 0 0 0 0 State 4 0 0 0 Total 89 1 1 6 With Firm-Level Weights Cooperative 18 2 0 0 Federal 1 0 0 0 Investor-owned 43 0 0 0 Municipality 35 0 0 0 Nonutility 28 0 1 8 Political Subdivision 0 0 0 0 State 4 0 0 0 Total 129 2 1 8 UsingLowCost Estimates

CTR UsingLowCost Estimates

Summary (unwtd costs) 4 of 53Discount Rate 7%

Option EG_AllIM_NE11B_08-03-10 Weights P2RR - 29Sep10_NERC_125MGD Discounting Year Analysis Year (2015)

Entity-Level Cost-to-Revenue Ratios Using Unweighted and Weighted Costs

1 2 3 4 5 6 7

Final Parent Joint Parent Analyzed? Ownership Type Size Revenue Total Unweighted Annualized After-Tax Compliance Costs (as of 2015; discounted to 2015; $2008) - Excluding Baseline Closures

CTR_Calcs_Low 5 of 53Discount Rate

Option Weights Discounting Year

Entity-Level Cost-to-Revenue Ratios Using Unweighted and Weighted Costs

1

Final Parent 8 9 10 11 12 13

Cost as % of Revenue Impact Range Ownershipt Type_Impact Range Total Weighted Annualized

After-Tax Compliance Costs (as of 2015; discounted to 2015; $2008) - Excluding Baseline

Closures Cost as % of Revenue Impact Range CTR Using Unweighted Costs CTR Using Weighted Cost Estimates

CTR_Calcs_Low 6 of 53Discount Rate

Option Weights Discounting Year

Entity-Level Cost-to-Revenue Ratios Using Unweighted and Weighted Costs

1

Final Parent 14

Ownershipt Type_Impact

Range

CTR_Calcs_Low 7 of 53Final Parent Joint Parent Analyzed? Ownership Type Size Revenue Total Unweighted Annualized After-Tax Compliance Costs (as of 2015; discounted to 2015; $2008) - Excluding Baseline Closures

CTR_Calcs_Low 8 of 53Final Parent Cost as % of Revenue Impact Range Ownershipt Type_Impact Range Total Weighted Annualized

After-Tax Compliance Costs (as of 2015; discounted to 2015; $2008) - Excluding Baseline

Closures Cost as % of Revenue Impact Range CTR Using Unweighted Costs CTR Using Weighted Cost Estimates

CTR_Calcs_Low 9 of 53Final Parent Ownershipt Type_Impact Range

CTR_Calcs_Low 10 of 53Final Parent Joint Parent Analyzed? Ownership Type Size Revenue Total Unweighted Annualized After-Tax Compliance Costs (as of 2015; discounted to 2015; $2008) - Excluding Baseline Closures

CTR_Calcs_Low 11 of 53Final Parent Cost as % of Revenue Impact Range Ownershipt Type_Impact Range Total Weighted Annualized

After-Tax Compliance Costs (as of 2015; discounted to 2015; $2008) - Excluding Baseline

Closures Cost as % of Revenue Impact Range CTR Using Unweighted Costs CTR Using Weighted Cost Estimates

CTR_Calcs_Low 12 of 53Final Parent Ownershipt Type_Impact Range

CTR_Calcs_Low 13 of 53Final Parent Joint Parent Analyzed? Ownership Type Size Revenue Total Unweighted Annualized After-Tax Compliance Costs (as of 2015; discounted to 2015; $2008) - Excluding Baseline Closures

CTR_Calcs_Low 14 of 53Final Parent Cost as % of Revenue Impact Range Ownershipt Type_Impact Range Total Weighted Annualized

After-Tax Compliance Costs (as of 2015; discounted to 2015; $2008) - Excluding Baseline

Closures Cost as % of Revenue Impact Range CTR Using Unweighted Costs CTR Using Weighted Cost Estimates

CTR_Calcs_Low 15 of 53Final Parent Ownershipt Type_Impact Range

CTR_Calcs_Low 16 of 53Final Parent Joint Parent Analyzed? Ownership Type Size Revenue Total Unweighted Annualized After-Tax Compliance Costs (as of 2015; discounted to 2015; $2008) - Excluding Baseline Closures

CTR_Calcs_Low 17 of 53Final Parent Cost as % of Revenue Impact Range Ownershipt Type_Impact Range Total Weighted Annualized

After-Tax Compliance Costs (as of 2015; discounted to 2015; $2008) - Excluding Baseline

Closures Cost as % of Revenue Impact Range CTR Using Unweighted Costs CTR Using Weighted Cost Estimates

CTR_Calcs_Low 18 of 53Final Parent Ownershipt Type_Impact Range

CTR_Calcs_Low 19 of 53

## Calculation of Firm Weights

1 2 3 4 5 6 7 8 9 10 11 12 13

Number of Firms -ALL Number of Firms -DQ Firm Weights Ownershi p Type Small LargeUnknown Total Small Large NA Total Small LargeUnknown Total Cooperative 8 12 0 20 2 9 0 11 4.00 1.33 0 1.82 Federal 0 1 0 1 0 1 0 1 0 1.00 0 1.00 Investor-owned2 41 0 43 1 38 0 39 2.00 1.08 0 1.10 Municipality 17 18 0 35 6 7 0 13 2.83 2.57 0 2.69 Nonutility 5 32 0 37 3 26 0 29 1.67 1.23 0 1.28 Political Subdivision

1 2 0 3 0 0 0 0 1.00 2.00 0 3.00 State 0 4 0 4 0 4 0 4 0 1.00 0 1.00 Total 33 110 0 143 12 85 0 97 2.75 1.29 0 1.47

FirmWts 20 of 53Discount Rate 7%

Option EG_AllIM_NE11B_08-03-10 Weights P2RR - 29Sep10_NERC_125MGD Discounting YearAnalysis Year (2015)

1 2 3 4 5 6 7 8

Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 21 of 53Discount Rate

Option Weights Discounting Year

1

Facility ID 80 8 40 9 10 11 12 13 14 15

Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type Low Estimates

FacilityInfo 22 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 23 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 24 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 25 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 26 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 27 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 28 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 29 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 30 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 31 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 32 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 33 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 34 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 35 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 36 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 37 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 38 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 39 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 40 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 41 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 42 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 43 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 44 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 45 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 46 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 47 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 48 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 49 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 50 of 53Facility ID Facility Name Parent-Firm Joint Parent Facility CountBased WeightsParent Entity Size Parent Entity Revenue ( $2009)Facility (Based on Utility) Ownership Type

FacilityInfo 51 of 53Facility ID Unweighted Costs Weighted Costs Parent (Based on Most Utilities Owned) Total Facility Post-Tax Cost -

Annualized (as of 2015) Total Facility Post-Tax Cost - Annualized (as of 2015) Explicitly Analyzed? All DIF (MGD)DIF Group Ownership Type

FacilityInfo 52 of 53

### DollarYear 2009

AnalysisYear 2015 IPMDollarYear 2006 IPM_Yr1 2015 IPM_Yr2 2020 IPM_Yr3 2025 IPM_YrLast 2028 EIA_Yr1 2003 EIA_Yr2 2004 EIA_Yr3 2005 EIA_Yr4 2006 EIA_YrLast 2007

Assumptions 53 of 53