Technical Support Docum ent (TSD) for the Transport Rule
Docket ID No. EPA-HQ-OAR-2009-0491



## State Budgets, Unit Allocation s, and Unit Emissions Rates

U.S. Environmental Protection Agency

Office of Air and Radiation July 2010

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### State Budgets, Unit Allocation s, and Unit Emissions Rates

This Technical Support Document (TSD) provides information that supports EPA’s determination of state emissions budgets, unit-level allocations, direct control rate limits, and new unit set-asides for the Trans port Rule proposal. Section IV.E in the Transport Rule preamble discusses state emi ssions budgets. Section V.D in the preamble discusses unit-level allocations, including the approach to allocate to new units from new unit set-asides in each state. Section V.D also discusses direct control rate limits. This TSD provides additional information in support of th e state budgets, unitlevel allocations, direct cont rol rate limits, and new unit set-asides. The TSD is organized as follows:

1. Overview 2. State Budgets 3. Unit-Level Allocations 4. Direct Control Rate Limits 5. New Unit Set-Asides



## 1. Overview State budgets, unit-level allocations, and direct control rate limits are key interrelated components of the proposed Tran sport Rule. As discussed in preamble sections III.A and IV.D, each state’s budget co mprises the emissions that EPA estimates remain after the state has ma de the reductions required to eliminate its significant contribution to nonattainment and interference with maintenance of the relevant National Ambient Air Quality Standards (NAAQS) in other states in an average year. 1 As such, the budget relates directly to the statutory authority upon which the Transport Rule is

1 As discussed in preamble section III.A, in the case of certain states for which EPA has only quantified a minimum amount of emissions reductions needed to make measurable progress towards eliminating their significant contribution and in terference with maintenance with respect to the 1997 8-hour ozone NAAQS, the emissions budget is the emissions that will remain after removal of those emissions.

2built. Under either the p roposed State Budgets/Limited Trading remedy or the State Budgets/Intrastate Trading alternative remedy, each state’s budget is allocated to sources within that state and determines how much each source can emit without trading allowances (allocations are discussed in preamble section V.D). Similarly, under the Direct Control alternative remedy, rate lim its specify the maximum emissions rate at which an electric generating unit (EGU) may operate without averag ing rates with other EGUs under the same ownership within the state (rate limits are discussed in preamble section V.D). Besides their importance to the Tran sport Rule, state budgets, unit-level allocations, and direct control rate limits sh are a common development process. Each is derived from a combination of recent emissions and heat input data and electric power sector projections from the Integrated Pla nning Model (IPM) affec ting an inventory of fossil-fuel-fired EGUs of more than 25 MW capacity. Specificall y, each state’s budget was constructed from a combination of data and IPM projections for the EGUs in that state, and each EGU’s contribution to the budget formed the basis of its allocation and direct control rate limit calculations. As discussed in preamble section V.D, EPA proposes to allocate emissions allowances to new units from small new unit se t-asides in each state. To create new unit set-asides, EPA would distribute to existing EGUs a quantity of allowances less than the entire state emissions budgets and would hold ba ck, for the new unit set-aside for a state, 3 percent of the state budget. This TSD details the how the state budgets were formed, how allocations were derived, and how direct control rate limits were set. The TSD also describes how EPA determined the size of the new unit set-asides . Following these descriptions, an appendix showing each affected EGU’s allocati on under the allocati on methodology in the proposed FIPs, as well as each EGU's allowabl e emissions rate under the direct control alternative, comprises most of the document. 

## 2. State Budgets

Inventory of Units The inventory of units on which state budgets are based is the union of units reporting emissions data to EPA (via vari ous emissions trading programs) and units included in IPM modeling (identified in N EEDS v302_EISA database). Generally, since IPM is a representation of all units which ar e capable of supplying electricity to the US

3electric grid and only units subje ct to EPA trading program s report emissions data, the units reporting data are a subset of the IPM/NEEDS inventory. However, both inventories must be considered due to poten tial inconsistencies. For example, it is possible that a new unit is captured in re ported data but not yet included in IPM modeling. Additionally, the breakdown of a pl ant into multiple generating units might be done differently in each data set, for exam ple, where there is not a 1:1 relationship between boiler and generator. Similarly, a co mbined cycle gas turbine and heat recovery steam generator may be treated as either a single unit or two separate units. Figure 1 provides a stylistic representati on of the unit inventory, aggregating the population into three sets (A, B, and C) by data source. The stylistic data sets in this figure are referred to throughout th e remainder of this document. 

### Figure 1. Stylistic Represe ntation of Unit Inventory

A B C Units Reporting Em issions Data to EPA IPM Projections (NEEDS Database)

The inventory of units on which budgets are based is lim ited to only fossil-fired units with greater than 25 MW electric gene rating capacity. For Set B and C, generating capacity and fuel type is defined in the NEED S database. Units in Set A are assumed to be fossil-fired EGUs greater th an 25 MW if they reported data to one of the following programs: CAIR NO X , CAIR SO 2 , ARP, and/or CAIROS in MA, CT, or AR. Where possible, EPA determined a cr osswalk between those units in the intersection of the two data s ources. This set is stylistically represented as Set B in Figure 1. This crosswalk is used to compare total state emissions from historic data to model projections. In cases where one unit with reported emissions matched to multiple units in the IPM/NEEDS inventory, emissions were divided equally.

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### Determining Reported Emissions For those units which report emissions da ta to EPA (Sets A and B), the reported annual data (SO 2 , NO X , and heat input) is assumed to be the most recent non-null first quarter, second quarter, third quarter, and fourth quarter emissions and heat input, between quarter 1 2007 and quarter 3 2009. The reported ozone season NO X emissions and heat input are assumed to be the most recent ozone season data reported to EPA between 2007 and 2009.


### Determining Projected Emissions For those units present in the NEEDS v302 EISA database and thus included in IPM modeling, (Sets B and C), projected data are assumed to be the annual (SO 2 , NO X , heat input) and ozone season (NO X , heat input) data projected by the IPM run that is designated “TR_Base_Case,” as apportioned to the unit level in the 2012 parsed file. The IPM runs and parsed files can be found in th e docket for this rule making (Docket ID No. EPA-HQ-OAR-2009-0491).


### Adjusting Emissions Both reported emissions and projected emi ssions require adjustment to reflect the fact that some sources installed advanced SO 2 and NO X control equipment to comply with CAIR but might not operate that equipmen t if they are not covered by the Transport Rule (because once the Transport Rule is fi nalized, the CAIR requirements will cease to exist). For both NO X and SO 2 , reported data is adjusted to account for retrofit controls that are expected to be built by 2012 but we re not in place during the time period for which the data was reported. Conversely, pr ojected data is adjusted to account for “dispatchable” controls that may not have ope rated fully in the ba se case projections. 2 Also, both reported and projec ted emissions for annual NO X are adjusted to account for the year-round operation of post-combusti on controls which may only have operated during the ozone season. Notably, all of thes e adjustments represent potential decreases, not increases, to the unadjusted reported or projected emissions; that is, only downward adjustments are made to a unit’s emissions to tal. The adjustments made are shown in summary in Tables 1 and 2 below and described in the following section.

2 Dispatchable controls are described in detail in the Transport Rule model documentation, “Updates to EPA Base Case v3.02 EISA Using the Integrated Planning Model.”

5For m any of the adjustments in Tables 1 and 2 below, the calculations use a “controlled model projection” of EGU emissi ons to prevent removal rates from being applied to units that are alrea dy controlling. For example, if a dispatchable scrubber with a 95% removal percentage were operating w ith a reduced removal percentage of 60%, simply applying 95% removal would yield an erroneous removal percentage of 98%. Instead, adjusting based on the greater of th at result and a controlled model projection yields the correct 95% rem oval corresponding to full operatio n of the scrubber. The controlled model projections used for this purpose are 2014 parsed results from three IPM runs: TR_SO2_1600 for SO 2 ; TR_NOX_500 for annual NO X ; and TR_NOX_OS_500 for ozone-season NO X . 3 Apart from the controlled model projectio ns described above, assumptions about controls follow those of EPA modeling using IPM 4 . Existing scrubbers have removal rates specified in NEEDS. 2012 retrofit scrubbers, for wh ich a NEEDS rate is not available, are assumed to achieve 95% removal. Post-combustion NO X controls are assumed to achieve the removal rates specifi ed in the IPM docume ntation, including 90% for SCR on coal-fired units, 35% for SNCR on conventional coal, and 50% for SNCR on fluidized bed coal units. As in IPM, NO X controls were assumed not to control beyond a floor of 0.06 lbs/mmBTU. Adjustments for scrubbers also account for the tendency to operate scrubbed units more than they operated as uns crubbed units. The rate determ ined with the criteria above was applied to the greater of reported heat i nput and heat input from the controlled model projection. For example, cons ider a hypothetical unit insta lling a scrubber in 2011 with a removal rate of 95%. As a relatively we ll-controlled unit in the controlled model projection, assume this unit operated 50% more in the controlled model projection than in the most recent reported data. Adjustment to this unit’s SO 2 emissions would account not only for the 95% reduction but also for th e 50% increase in ut ilization, accurately reflecting the combination of these two changes. Adjustments to reported data of units with controls installed in 2009 were treated on a case-by-case basis. Quarterly emissions rates were assessed to determine when the control might have been inst alled. If a clear drop comme nsurate with the new control

3 These model runs were originally used for analysis of significant contribution and are described in the TSD, “Analysis to Quantify Significant Contribution.”
4 Specifically, the discussion in this paragraph draws from Tables 5.5 and 5.2 from “Documentation for EPA Base Case 2006 (v3.0) Using the In tegrated Planning Model,” available at http://www.epa.gov/airmarkt/progsregs/epa-ipm/index.html.

6could be determ ined, the rate implied by the pos t-installation data was used. If the data did not clearly indicate when the control was installed, the control was treated as though it were a 2010 or 2011 control as specified in Table 1 below.



### Table 1. Adjustments to Reported Emissions to Account for Controls

Control

Type Online Year of Control Pollutant Procedure for Adjustment

Use the greater of the emissions that result from applying: SCR or SNCR 2010–2011 in NEEDS Annual NO X or Ozoneseason NO X Removal rate from IPM documentation* 0.06 lbs/mmBTU

SCR or SNCR 2009 in NEEDS Annual NO X or Ozoneseason NO X Reflect post-installation data if available. Otherwise, treat like 2010–2011 controls above.

Use the greater of the emissions that result from applying: SCR or SNCR 2012 retrofit in TR_Base_Case Annual NO X or Ozoneseason NO X Removal rate from IPM documentation* Emissions rate in controlled model projection SCR or SNCR Before 2009 in NEEDS Annual NO X Reflect emissions rate in reported ozone-season data. 1) Use the greater of the emissions rates that result from applying: FGD removal rate in NEEDS Emissions rate in controlled model projection 2) Apply the emissions rate to the greater of these heat inputs: FGD 2010–2011 in NEEDS SO 2

Reported heat input Heat input in controlled model projection FGD 2009 in NEEDS SO 2 Reflect post-installation data if available. Otherwise, treat like 2010–2011 controls above. 1) Use the greater of the emissions rates that result from applying: 95% removal rate Emissi ons rate in controlled model projection 2) Apply the emissions rate to the greater of these heat inputs: FGD 2012 retrofit in TR_Base_Case SO 2

Reported heat input Heat input in controlled model projection

7*As described above, removal rates are 90% for SCR and 35% (conventional) or 50% (FBC) for SNCR.



### Table 2. Adjustments to Projected Base Case Emissions to Account for Controls
Control Type Online Year of Control Pollutant Procedure for Adjustment

Use the greater of the emissions that result from applying: Dispatchable SCR Any year in NEEDS Annual NO X or Ozone-season NO X Removal rate from IPM documentation* Emissions rate in controlled model projection SNCR or nondispatchable SCR Any year in NEEDS or 2012 retrofit in TR_Base_Case Annual NO X Reflect emissions rate in TR_Base_Case 2012 ozone-season projection.

1) Use the greater of the emissions rates that result from applying: FGD removal rate in NEEDS Emissions rate in controlled model projection 2) Apply the emissions rate to the greater of these heat inputs: Dispatchable FGD Any year in NEEDS SO 2

Reported heat input Heat input in controlled model projection *As described above, IPM removal rates are 90% for SCR and 35% (conventional) or 50% (FBC) for SNCR. Prior to making the above adjustments for controls, a few units were adjusted on a case-by-case basis to correct for inaccurate or unrepresentative data. Brayton Point unit 3 is expected to have a dry scrubber rather than a wet scrubber by 2012. For Rodemacher unit 2, 2007 quarter 4 heat input is used instead of incomplete 2008 quarter 4 heat input. Seminole (Florida) units 1 and 2 are assumed to have had SCR installed prior to 2009. These adjustments are summarized below in Table 3, and the resulting allocations and direct control rate limits are show n in the Appendix of this document.

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### Table 3. Unit-specific Adjustments
NEEDS ID ORIS Code Plant Name Unit ID Adjustment to Data Affected Pollutant 1619_B_3 1619 Brayton Point 3 Scrubber achieves 90% rather than 95% removal SO 2

6190_B_2 6190 Rodemacher 2 Use 2007 Q4 for calculation of annual heat input data SO 2

136_B_1 136 Seminole 1 Has pre-2009 SCR Annual NO X 136_B_2 136 Seminole 2 Has pre-2009 SCR Annual NO X

Reported annual and ozone season NO X emissions are adjusted to account for unusually low utilization in 2009. For units repor ting emissions (Sets A and B), the annual emissions assumed in the budget calculati on are calculated by applying the 2008 heat input to the annual average emissions rate de termined from the most recent quarter 1, quarter 2, quarter 3, and quarter 4 (and potentially adjusted for controls, as described above). 2009 heat input is used for units which did not report 2008 heat input data. Ozone season emissions are assumed to be 2008 ozone season heat input multiplied by the most recent ozone season average emissions rate. Because 2009 was an unusually low year, rebasing emissions on 2008 heat input in this way typically re sults in larger annual NO X emissions.



### 2012 SO 2 

### Budgets
2012 SO 2 budgets are the lower of the recent actual emissions or projected base case emissions, at the state level. Th e unit-level data used in developing 2012 SO 2 state budgets is based on the inventory of units desc ribed in section 2 “Inventory of Units” and adjusted as summarized in Tables 1-3..
Each state’s 2012 SO 2 budget is the sum of (1) adjusted emissions from units with only reported data (Set A), plus (2) adjusted emissions from units with only projected data (Set C), plus (3) from units with both reported and projected data (Set B), the lesser of:

a. total emissions based on adjusted reported data, or

9b. total em issions based on adjusted projected data.


### 2014 and Beyond SO 2 

### Budgets For group 2 states 5 (Alabama, Connecticut, Delaware , Florida, Kansas, Louisiana, Maryland, Massachusetts, Minnesota, Nebraska , New Jersey, South Carolina) the 2014 and beyond budgets are equal to the 2012 budgets. 2014 and beyond SO 2 budgets for group 1 states (Georgia, Illi nois, Indiana, Iowa, Kentuc ky, Michigan, Missouri, New York, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virginia, Wisconsin) are based on 2014 IPM projected emi ssions from fossil units greater than 25 MW capacity. Group 1 state budgets are based on reductions projected to be cost-effective at $2000 per ton of SO 2 in the significant contribution an alysis. The TSD titled “Analysis to Quantify Significant Contribution” contai ns details about this analysis. More information on the IPM run (TR_SO2_2000) is available in the docket for this rulemaking (Docket ID No. EPA-HQ-OAR- 2009-0491). Each group 1 state’s budget, with the exception of Tennessee, is equal to the projected state emissions from covered units (fossil-fired, greater than 25 MW capacity) in this IPM run. For Tennessee, the 2012 SO 2 budget calculation methodology resulted in a slightly smaller budget than would have b een as calculated u nder the 2014 and beyond methodology for group 1 states. As a result, the budget for the state of Tennessee does not change in 2014.



### Annual NO X 

### Budgets 2012 and beyond annual NO X budgets are the lower of th e recent actual emissions or projected base case emissions at the state level. The unit- level data used in developing 2012 annual NO X state budgets is based on the inventor y of units described in section 2 “Inventory of Units” and adjusted as summarized in Tables 1-3.
Each state’s 2012 NO X budget is the sum of (1) adjusted emissions from units with only reported data (Set A), plus (2) adjusted emissions from units with only projected data (Set C), plus

5 As discussed in the preamble, the proposed Transport Rule divides the states required to make SO 2 reductions into two groups reflecting the differing stringency of SO 2 reductions required to address significant contribution and interference with maintenance for each state.

10(3) from units with both reported and projected data (Set B), the lesser of:

a. total emissions based on adjusted reported data, or
b. total emissions based on adjusted projected data.



### Ozone-season NO X 

### Budgets 2012 and beyond ozone season NO X budgets are the lower of the recent actual emissions or projected base case emissions at th e state level. The unit-level data used in developing 2012 ozone season NO X state budgets is based on the inventory of units described in section 2 “Inventory of Units” and adjusted as summarized in Tables 1-3.
Each state’s 2012 ozone season NO X budget is the sum of (1) adjusted emissions from units with only reported data (Set A), plus (2) adjusted emissions from units with only projected data (Set C), plus (3) from units with both reported and projected data (Set B), the lesser of:

a. total emissions based on adjusted reported data, or
b. total emissions based on adjusted projected data.



## 3. Unit-level Allocations The allocation methodology distributes the state budgets to indi vidual units. The proposed unit-level allocations are calculate d analogous with the way each state budget is calculated – each unit receives a proportional sh are of its state budget based on that unit’s share of state emissions assumed in deve loping the budget. The following sections describe in more detail the proposed a llocation methodology for each pollutant: SO 2 (2012-2013, 2014 and beyond), annual NO X , and ozone season NO X .


### SO 2 

### Allocations for 2012–2013
The basis for 2012-2013 SO 2 allocations is the unit-level emissions assumption (tons) used in determining the state budget. Consistent with state budget calculation, the allocations to units with only reported data (Set A) are based on th at reported data. Similarly, allocations to units w ith only projected data (Set C) are based on that projected data. For those units with both reported and pr ojected data (Set B), allocations are based on the data source used in the state budget (the source resulting in th e lowest total budget from Set B units at the state level).

11Units are allocated 97 % of the assume d unit-level emissions of each state’s budget. The remaining 3% of allowances ar e withheld for a new-unit set-aside. See section 5 for discussion of the new unit set- asides. Proposed allocations are rounded to the nearest ton.



### SO 2 

### Allocations for 2014 and Beyond For group 2 states (Alabama, Connecticut, Delaware, Florida, Kansas, Louisiana, Maryland, Massachusetts, Minnesota, Nebras ka, New Jersey, South Carolina), 2014 and beyond allocations are equal to 2012-2013 allocations. For group 1 states (Georgia, Illinois, Indiana, Iowa, Kentucky, Michigan, Missouri, New York, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West Virg inia, Wisconsin), unit-level allocations are a proportional share of the stat e’s budget based on projected SO 2 emissions from fossilfired greater than 25 MW capacity units in the TR_SB_Limited_Trading IPM run, as apportioned to the unit level in the 2014 parsed file. Units in group 1 states without an IPM projection do not receive SO 2 allocations in 2014 and beyond. The proposed unit-level allocations are 97% of each unit’s proportional share of emissions. The remaining 3% of allowances are withheld for a new unit set-aside. See section 5 for discussion of the new unit set-as ide. Proposed allocati ons are rounded to the
nearest ton.



### Annual NO X 

### Allocations for 2012 and Beyond The basis for 2012 and beyond annual NO X allocations is the unit-level emissions assumption (tons) used in determining the st ate budget. Consistent with state budget calculation, the allo cations to units with only reported data (Set A) are based on that reported data. Similarly, allocations to units with only projected da ta (Set C) are based on that projected data. For those units with both reported and proj ected data (Set B), allocations are based on the data source used in the state budget (the source resulting in the lowest total budget from Set B units at the state level). The proposed unit-level allocations are 97% of the unit-level emissions assumed in developing each state’s budget. The remain ing 3% of allowances are withheld for a new unit set-aside. See section 5 for disc ussion of the new unit set-aside. Proposed allocations are rounded to the nearest ton.

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### Ozone-season NO X 

### Allocations for 2012 and Beyond The basis for 2012 and beyond ozone season NO X allocations is the unit-level emissions assumption (tons) used in determini ng the state budget. Consistent with state budget calculation, the allocations to units with only reported data (Set A) are based on that reported data. Similarly, allocations to units with only projected data (Set C) are based on that projected data. For those units with both reported and projected data (Set B), allocations are based on the data source us ed in the state budget (the source resulting in the lowest total budget from Se t B units at the state level). The proposed unit-level allocations are 97% of the unit-level emissions assumed in developing each state’s budget. The remain ing 3% of allowances are withheld for a new unit set-aside. See section 5 for disc ussion of the new unit set-aside. Proposed allocations are rounded to the nearest ton.



## 4. Direct Control Rate Limits EPA is taking comment on a direct cont rol rate limit alternative remedy. The unit-level rates which sources must comply with under this approach are determined analogously to unit-level allocations – each unit’s proposed allocation is divided by the reported or projected heat inpu t associated with that tonnage. The heat input assumed in this approach is determined identically to em issions. For units in Set A, reported annual heat input is calculated from the most recent first, second, third, and fourth quarters for SO 2 , and 2008 heat input for annual and ozone season NO X . For units in Set C, the heat input is projected by IPM in TR_Base_Case, as apportioned to the unit-level in the 2012 parsed file (or, in the case of group 1 st ates in 2014 and beyond, projected by IPM in TR_SB_Limited_Trading, as apportioned to the unit level in the 2014 pa rsed file). The source of the heat input for un its in Set B (both projected an d reported data available) is identical to the source of the emissions data for that unit. Note that this data source could be different based on pollu tant, at the same unit.



## 5. New Unit Set-Asides

The new unit set-aside for SO 2 , annual NO X , and ozone season NO X for each state is determined based on the percentage of th e total emissions represented by the net new emissions calculated by IPM in TR_SB_Limite d_Trading, as parsed to the unit level in the 2020 run year. This method for calculati ng the new unit set aside ensures new units have sufficient allocations, while balancing the allocation needs of existing EGUs. The

13total em issions for each pollutant are the sum of emissions from all covered units (fossilfired, greater than 25 MW capacity) in th e 2020 run year of TR_SB_Limited_Trading. The net new emissions for each pollutant is equal to the projected 2020 emissions from newly built units in IPM, less th e sum of allocations to units projected to retire for more than 3 years by 2020 (after 6 years, allocations to retired units are returned to the new unit set-aside). The percentages of the tota l emissions represented by the projected net new emissions calculated by IPM in 2020 are:
SO 2 : 0.60%
Annual NO X : 3.06%
Ozone season NO X : 2.74% To allow for reasonable flexibility, EPA proposes new unit set-asides that are 3 percent of the state emissions budgets. The si ze of the new unit set-aside is 3 percent for the SO 2 group 1, SO 2 group 2, NO X annual, and NO X ozone season trading programs, as appropriate, for each state. See Tables 4 and 5. For each control period, any allowances remaining in a state’s new unit set-aside (after allocations are made to new units that requested allowances) are distributed to the existing units in that state in proportion to th e existing unit’s original allocations. This ensures that total alloca tions to units in the st ate equal the state budget. 

### Table 4. SO 2 

### and Annual NO X 

### State New Unit Set-Aside Budgets for Electric Generating Units (tons)

State SO 2 , 2012- 2013 SO 2 , 2014 and Later NO X , 2012 and Later Alabama 4,856 4,856 2,075 Connecticut 92 92 83 Delaware 234 234 186 District of Columbia 10 10 5 Florida 4,852 4,852 3,600 Georgia 6,998 2,572 2,214 Illinois 6,269 4,546 1,681 Indiana 12,011 6,042 3,471 Iowa 2,822 2,583 1,382 Kansas 1,718 1,718 1,540 Kentucky 6,586 3,415 2,224 Louisiana 2,714 2,714 1,318 Maryland 1,190 1,190 511

14Massachusetts 237 237 179 Michigan 7,540 4,670 1,948 Minnesota 1,413 1,413 1,240 Missouri 6,111 4,763 1,730 Nebraska 2,148 2,148 1,297 New Jersey 339 339 355 New York 1,996 1,261 700 North Carolina 3,345 2,456 1,554 Ohio 13,949 5,349 2,919 Pennsylvania 11,658 4,251 3,417 South Carolina 3,494 3,494 1,016 Tennessee 3,000 3,000 851 Virginia 2,178 1,224 887 West Virginia 6,163 3,570 1,560 Wisconsin 2,893 2,000 1,345 Total 116,816 75,000 41,288



### Table 5. Ozone Season NO X 

### State New Unit Set-Aside Budgets for Electric Generating Units (tons)

State NO X Ozone Season, 2012 and Later Alabama 892 Arkansas 500 Connecticut 39 Delaware 74 District of Columbia 3 Florida 1,708 Georgia 964 Illinois 707 Indiana 1,500 Kansas 643 Kentucky 927 Louisiana 637 Maryland 217 Michigan 848 Mississippi 496

1516 New Jersey 158 New York 333 North Carolina 706 Ohio 1,220 Oklahoma 1,113 Pennsylvania 1,448 South Carolina 457 Tennessee 347 Texas 2,267 Virginia 378 West Virginia 667 Total 19,249



## Appendix: Table of Unit-level Allocations and Rate Limits

See “TSD Allocation Table” available in the docket.