## Summary	of	Interagency	Working	Comments	on	Draft	Language	under EO12866 Interagency	Review.		Subject	to	Further	Policy	Review.

1 of 2 **Comments:**  Since b oth Puerto Rico and Guam have existing RPS targets, the commenter recommends that EPA set building block 3 goals for PR and Guam that acknowledge the efforts of these areas to deploy renewable energy. One option would be to use these RPS targets in developing this building block, similar to the methodology used to develop building block 3 goals for states in the June proposal.  With respect to the ability for tribes and territories without affected EGUs to participate in multi jurisdictional implementation plans, the commenter recommends that EPA propose a course of action for consideration, rather than seek comment genera lly on this issue. In addition, EPA should state and/or seek comment on whether such tribes need to have TAS status in order to participate in multi jurisdictional implementation plans. Finally, in providing guidance about such plans, EPA should state whether and how RECs traded to states from renewable energy generated by tribes or territories would count toward the purchasing state’s compliance. Similarly, since energy efficiency realized in territories or tribal areas without affected EGUs would likely reduce electr icity generation in a state, EPA should state whether and how states would be able to claim those savings. In developing this proposed guidance, EPA should seek consistency between the guidance provided in this action with relevant guidance to states in th e context of multi -state implementation plans in the June proposal .  With respect to high - utilization oil combustion turbines and oil -fired combined cycle units, the commenter requests clarification about the way in which sources not covered under 111(b) co uld become covered under this proposed action. **Technical comments:**  For clarity on the options/approaches (e.g., building block applications) provided for calculating the tribe/territory goals, the commenter suggests including a table to more clearly outli ne the characteristics and difference of each of the options offered.  The proposal summary indicates that it is for tribes and territories, but the majority of the rule text focuses on the three specific tribes and two territories. The commenter suggests including text regarding implications of the proposal on affected EGUs identified after the proposal is final.  It would be helpful to have a clearer explanation of the distinction between tribes with and without state -status for the purposes of t his rule and what the implications of the proposal are on the tribes based on which category they fall within. Some of this is scattered throughout various sections of the proposal, but a more concentrated discussion earlier in the preamble would more cle arly indicate how this distinction plays a role in the proposal, including (as noted below) with respect to participation in “multi -jurisdictional” plans. (Perhaps include in Preamble section II.C)  The use of the term “multi -jurisdictional” may create som e confusion when considered in conjunction with the June 2014 111(d) proposal’s terminology (e.g., “multi -state”). States themselves could also be considered “jurisdictions”; is the intent to have common terminology with the final 111(d) proposal for stat es? Suggest adding explanatory/clarifying text to address this potential confusion.

## Summary	of	Interagency	Working	Comments	on	Draft	Language	under EO12866 Interagency	Review.		Subject	to	Further	Policy	Review.

2 of 2  On page 30, the proposal states “The EPA is not aware of any affected EGUs that are owned or operated by tribal governments.” Suggest including additional text explaining the significance of this statement with respect to this proposal.  In preamble section V.A (impacts discussion), it is noted that EPA does not expect further emissions reductions from areas of Indian country with affected EGUs, in part based on previous or pending retirements that would be effective before the compliance window. This discussion appears limited to the EGUs and no additional reductions are expected of the EGUs; it would be helpful to have a clearer explanation of what the other applied build ing blocks/approaches would mean in terms of air impacts. Without this complement to the existing discussion, it seems awkward that a rule is being proposed that isn’t expected to have an effect on the air impacts with respect to Indian country.