Mr. Mark Hague 

Page Two 

4. 	 In accordance with 40 CFR 52.38(b )(3)(iii), the list submitted on March 27th was submitted 

electronically in the format specified by the Administrator. 

5. 	 In accordance with 40 CFR 52.38(b)(3)(iv), the list submitted on March 27th is a permanent 

allocation for the units on the list for 2016 and the SIP revision does not provide for any 

changes to the listed units or allocations after approval by the Administrator under subpart 

BBBBB of 40 CFR Part 97. 

The Missouri Air Conservation Commission adopted this SIP revision at the March 26, 2015 

commission meeting. A public hearing for the proposed plan was held on January 29,2015. A 30­

day public comment period opened by December 29,2015 and closed on February 5, 2015. During 

the public comment period for the proposed SIP revision, the Air Program did not receive any 

comments. A summary explaining that no comments were received is attached. 

In order to comply with Attachment A ofthe "Regional Consistency for the Administrative 

Requirements of State Implementation Plan Subnlittals and the Use of 'Letter Notices'" memo dated 

April 6, 2011, a searchable pdf version ofthe complete submittal package will be emailed to the EPA 

Regional Office. Within three business days, this complete package will be posted on our website at 

http://dnr.mo.gov/env/apcp/stateplans.htm. 

Thank you for your attention to this matter. If you have any questions regarding the March 27th 

submission, please contact Ms. Wendy Vit with the Missouri Department ofNatural Resources' Air 

Pollution Control Program at P.O. Box 176, Jefferson City, MO 65102 or by telephone at (573) 

751-4817. 

Sincerely, 

AIR POLLUTION CONTROL PROGRAM 

re;t kry Director 

KLM:mlc 

Enclosures: 

Copy of the email text for the March 27th submission 

Copy of supplemental document and appendix to the SIP revision 

Copy of commission signature page certifying Missouri Air Conservation Commission adoption 

Copy of public hearing notices 

Copy of public hearing transcript introductory statement 

Copy of recommendation for adoption 

Copy of the summary of comments and responses 

CD with electronic copy of the entire submittal package 

c: 	 Missouri Air Conservation Commission 

File# 2014-Transport Rule-NOx Ozone Season 
1

Bechtel, Cheri

From: Leath, Mark

Sent: Friday, March 27, 2015 8:36 AM

To: 'transport-rule@epa.gov'

Cc: 'branch.paula@epa.gov'; 'bhesania.amy@epa.gov'; 'jay.michael@epa.gov'; 

'kemp.lachala@epa.gov'; Moore, Kyra; Vit, Wendy; Wilbur, Emily; Graf, Wayne; Basham, 

Aaron; Leath, Mark; Bechtel, Cheri

Subject: Missouri TR NOx Ozone Season Allocations for Existing Units for Vintage Year 2016

Attachments: Submittal Missouri 2016 TR NOx Ozone Season Allocations.xls

Clean Air Market Division,

The attached Microsoft Excel document contains Missouri’s Transport Rule (TR) NOx Ozone Season Allocations for

Existing Units for Vintage Year 2016.  The Missouri Department of Natural Resources’ Air Pollution Control Program is

submitting this list to reallocate allowances to existing units under the federal Cross‐State Air Pollution Rule’s (CSAPR) TR

NOx Annual Trading Program for the 2016 control period in accordance with 40 CFR 52.38(b)(3).

The Missouri Department of Natural Resources’ Air Pollution Control Program is also submitting a letter to EPA Region

VII to request approval of the complete SIP revision to allow for the reallocation of allowances for the 2016 control

period.  If EPA approves the SIP revision, the attached list of unit level TR NOx Ozone Season allocations will replace the

provisions of 40 CFR 97.511(a) for the 2016 control period under the CSAPR.

If you have any questions regarding the submission of the attached list of Missouri’s unit level TR NOx Ozone Season

Allocations for existing units for vintage year 2016, please contact me via phone or email.

Thank you,

Mark Leath, P.E.

Environmental Engineer  

Air Pollution Control Program

Department of Natural Resources

Phone: (573) 526‐5503

Email: mark.leath@dnr.mo.gov

Promoting, Protecting and Enjoying our Natural Resources. Learn more at dnr.mo.gov. 
2014-Transport Rule-NOx Ozone Season 

Supplemental Document for 

Missouri State Implementation Plan Revision 

________________ 

Cross-State Air Pollution Rule (CSAPR) 

NOx Ozone Season Trading Program 

________________ 

Prepared for the 

Missouri Air Conservation Commission 

Adoption 

March 26th, 2012 

Missouri Department of Natural Resources 

Division of Environmental Quality 

Air Pollution Control Program 

Jefferson City, Missouri 
2014-Transport Rule-NOx Ozone Season 
i 

TABLE OF CONTENTS 

PURPOSE .................................................................................................................................................... 1

1. BACKGROUND ................................................................................................................................ 2

2. MISSOURI TR NOX OZONE SEASON TRADING PROGRAM SIP REVISION FOR 2016 .. 4

2.1 FEDERAL ALLOCATION METHOD TO EXISTING UNITS UNDER CSAPR ............................................................ 4

2.2 MISSOURI TR NOX OZONE SEASON TRADING PROGRAM ALLOCATION METHOD FOR 2016 UNDER THE SIP .. 4

2.3 AUTHORITY TO IMPLEMENT THIS SIP ............................................................................................................... 5

2.4 PUBLIC PARTICIPATION AND OUTREACH ......................................................................................................... 6

2.5 MISSOURI TR NOX OZONE SEASON TRADING PROGRAM ALLOCATIONS FOR 2016 ......................................... 6

Table 1. Missouri TR NOX Ozone Season Allocations for the 2016 Control Period ....................................... 7
i 
1 

Purpose 

The purpose of the State Implementation Plan (SIP) revision described in this document is for 

the Missouri Department of Natural Resources’ Air Pollution Control Program (Air Program) to 

assume allocation authority for the Missouri existing unit budget in the Transport Rule (TR) NOx

Ozone Season Trading Program for the 2016 control period under the U.S. Environmental 

Protection Agency’s (EPA) Cross-State Air Pollution Rule (CSAPR). The Air Program is 

submitting a SIP revision with adjusted individual unit level allocations that will replace the 

allocations from the existing unit budget established by the CSAPR Federal Implementation Plan 

(FIP) for the 2016 control period. 

This supplemental document outlines the purpose, background, and authority to submit as a SIP 

revision the unit level allowance allocations for existing TR NOx Ozone Season units in Missouri 

for the 2016 control period. This supplemental document will be submitted to EPA, but the Air 

Program is only requesting SIP approval of the allowance allocations being submitted. 

When the federal allocation method is applied to Missouri’s existing unit budget for the TR NOx

Ozone Season Trading Program for the 2016 control period, there are five (5) excess allowances 

in the existing unit budget due to rounding. The SIP revision described in this document will 

reallocate two (2) of these five (5) excess allowances as follows: one (1) allowance to the facility 

owned by the City of Chillicothe and one (1) allowance to the facility owned by the City of 

Higginsville. These two facilities were not allocated any allowances under the federal allocation 

method. All other existing unit budget allowances will be distributed identically to the federal 

allocation method. 

The SIP revision described in this document redistributes emission allowances for the 2016 

control period only. The Air Program is pursuing a separate rulemaking and SIP revision to 

reallocate allowances for the control periods in 2017 and beyond. 
2 

1. Background 

In 2005 the EPA finalized a federal emission trading program for the eastern half of the country. 

This trading program was known as the Clean Air Interstate Rule (CAIR). CAIR established 

three different federal emission trading programs that were designed to limit interstate transport 

of emissions that significantly contribute to nonattainment or interfere with maintenance in 

downwind states. States are required to address these emissions in accordance with Clean Air 

Act (CAA) Section 110(a)(2)(D)(i)(I). CAIR addressed these requirements for states that were 

included in the rule for two different NAAQS, the 1997 8-hour ozone NAAQS, and the 1997 fine 

particulate matter (PM2.5) NAAQS. However, in 2008, the District of Columbia Circuit Court of 

Appeals (D.C. Circuit Court) remanded CAIR to EPA due to deficiencies found in the rule. EPA 

was directed by the courts to write a rule to replace CAIR and address these deficiencies. In 

August 2011, CSAPR was finalized in response to this court decision and was intended to 

replace CAIR beginning January 1, 2012. 

However, in December 2011, prior to the implementation of CSAPR, the D.C. Circuit Court 

stayed the implementation of CSAPR pending the outcome of litigation that had been filed 

against the CSAPR. Then in August 2012, the D.C. Circuit Court issued a decision vacating 

CSAPR and directed EPA to continue to implement CAIR until they could implement a new 

replacement rule that addresses the Court’s concerns. However, EPA appealed the D.C. Circuit 

Court’s decision to the U.S. Supreme Court and in April 2014, the U.S. Supreme Court reversed 

the D.C. Circuit Court’s decision that vacated the CSAPR. Then in June 2014, EPA filed a 

motion to the D.C. Circuit Court to lift the stay of the CSAPR and delay all compliance dates in 

the rule by three (3) years, which would require that phase I of CSAPR would begin in January 

2015. In October 2014, the D.C. Circuit court granted EPA’s motion to lift the stay of the 

CSAPR, and on November 21, 2014 the EPA administrator signed an interim final rule that 

extends the compliance dates of the CSAPR by three (3) years and clarifies that the rule will go 

into effect in 2015. 

The CSAPR establishes four (4) separate federal emission trading programs for states located in 

the eastern half of the country. These four trading programs include the TR SO2 Group 1 

Trading Program, the TR SO2 Group 2 Trading Program, the TR NOx Annual Trading Program, 

and TR NOx Ozone Season Trading Program. States that were found to be significantly 

contributing to a 1997 and/or 2006 PM2.5 NAAQS nonattainment area or interfere with 

maintenance of these PM2.5 NAAQS in a downwind state are included in one of the TR SO2

Trading Programs, along with the TR Annual NOx Trading Program. States that were found to 

be significantly contributing to 1997 Ozone NAAQS nonattainment areas or interfere with 

maintenance of this ozone NAAQS in a downwind state are included in the TR NOx Ozone 

Season Trading Program. 

The final CSAPR, which was published in the federal register on August 8, 2011, includes 

Missouri in the TR SO2 Group 1 Trading Program and the TR NOx Annual Trading Program. 

Missouri was not included in the TR NOx Ozone Season trading program under the final rule. 

However, on December 27, 2011, EPA finalized a supplement to the final CSAPR (76 FR 

80760), which added Missouri and five (5) other states to the TR NOx Ozone Season Trading 

Program. Therefore, Missouri is included in the TR NOx Ozone Season Trading Program 

beginning in 2015. 
3 

EPA is implementing CSAPR through a FIP beginning January 1, 2015 (79 FR 71663). Through 

the CSAPR, every state included in the rule has a statewide emission budget for each trading 

program in which it is included. These statewide budgets consist of a certain amount of 

allowances that are distributed to the CSAPR-affected units in that state. Applicability under the 

TR NOx Ozone Season Trading Program is defined in 40 CFR 97.504. Each allowance permits a 

unit to emit one ton of the respective air pollutant for which the allowance is granted. 

Allowances may be used to cover emissions from a particular unit, they may be banked to be 

used in a future year, or they can be traded or sold to other affected units included in the 

respective trading program. There are several different compliance options for units subject to 

CSAPR. Some examples of compliance options include, but are not limited to, the installation of 

controls to lower emissions, purchasing allowances from units with excess allowances due to 

over-controlling emissions, transfer allowances from one unit to another, fuel-switching, 

improved unit operating procedures, unit efficiency improvements, and modifications to unit 

dispatch order. 

The following two paragraphs are intended to summarize the method used by EPA in setting 

statewide and unit level allowance budgets under the CSAPR. Complete details regarding these 

methods can be found in the preamble to the CSAPR (76 FR 48208 – 48352). 

EPA’s method of setting statewide emission budgets through the CSAPR included the use of the 

future year modeling. EPA took into account all known or planned controls that would be 

operational on all affected units included in the CSAPR by January 1, 2012. EPA also took into 

account all cost effective controls that could be installed to control emissions at CSAPR-affected 

units. The modeling was performed using these inputs, and the emissions computed by the 

model at each unit were summed for each state included in the rule to develop the statewide 

emission budget. These statewide budgets cannot be increased by states through a SIP. 

After calculating the statewide budgets, EPA allocated the allowances to individual units in each 

state. Under the FIP, the statewide budgets for each trading program are divided into two 

different budget pools, the existing unit budget and the new unit set-aside (NUSA). Existing 

units are defined as those in operation on or before January 1, 2010. The NUSA was established 

as a percent of the statewide budget, to cover emissions from units that commenced commercial 

operation after January 1, 2010. The allowances that remain in the statewide budget after the 

NUSA is subtracted make up the existing unit budget. Once these two budget pools were 

established, EPA allocated allowances to individual existing CSAPR-affected units (units that 

commenced operation prior to January 1, 2010) using a method that took into account both 

historical heat input and historical emissions at each unit. 

These individual existing unit level allocations established through the FIP cannot be changed by 

states through a SIP for the 2015 control periods. However, for the 2016 control period, states 

can submit SIPs to alter the individual unit level allocations under the FIP from the existing unit 

budget. The unit level allocations in the NUSA cannot be changed by states through a SIP for 

the 2016 control periods. For the 2017 and beyond control periods, states can submit SIPs to 

alter the individual unit level allocations under the FIP from both the existing unit budget and the 

NUSA. 
4 

2. Missouri TR NOx Ozone Season Trading Program SIP Revision for 2016 

2.1 Federal Allocation Method to Existing Units Under CSAPR 

The following two paragraphs are intended to summarize the method used by EPA to set unit 

level allowance budgets for existing units under the CSAPR. Complete details regarding the 

federal allocation method can be found in the preamble to the CSAPR (76 FR 48208 – 48352). 

Under the federal allocation method of the CSAPR, existing units are distributed allowances 

from the statewide existing unit budget based on their historical heat input and capped at their 

historical maximum emissions. Specifically, the highest (nonzero) three years of each unit’s heat 

input from the control periods in 2006 – 2010 are averaged together. This value is then summed 

with every other unit in the state in order to determine a percentage of historical statewide heat 

input for each unit. This percentage is then multiplied by the statewide existing unit budget to 

calculate the initial allocation for each unit. This value is compared to historical high emissions 

value at that unit from the control periods in 2003 – 2010. If the initial allocation for the unit is 

lower than the historical high emissions value, the unit receives the initial allocation amount. If 

the initial allocation for the unit is higher than the historical high emissions value, the unit 

receives their historical high emissions value as their allocation and the remaining allowances are 

rolled back to the statewide existing unit budget. This process is repeated until the number of 

allowances allocated to existing units equals the amount of allowances in the statewide existing 

unit budget. 

Once the number of allowances allocated to existing units equals the amount of allowances in the 

statewide existing unit budget, all allowances that have been allocated to existing units are 

rounded to the nearest whole number using conventional rounding. If more allowances are 

rounded down than rounded up, there will be excess allowances in the existing unit budget. If 

more allowances are rounded up than rounded down, there will not be enough allowances in the 

existing unit budget to cover the allowances that were allocated. In both cases, under the FIP, 

the difference would be made with the NUSA. In other words, under the FIP, any extra 

allowances in the existing unit budget due to rounding would be transferred to the NUSA, and 

allowances would be taken from the NUSA if needed to cover the existing unit budget as a result 

of rounding. 

2.2 Missouri TR NOx Ozone Season Trading Program Allocation Method for 2016 

Under the SIP 

When the federal allocation method is applied to Missouri’s existing unit budget for the TR NOx

Ozone Season Trading Program for the 2016 control period, there is are five (5) excess 

allowances due to rounding. The SIP revision described in this document will reallocate two (2) 

of these five (5) excess allowances as follows: one (1) allowance to the facility owned by the 

City of Chillicothe and one (1) allowance to the facility owned by the City of Higginsville. No 

other changes to the existing unit allowance allocations are being made. 

Missouri’s codified TR NOx Annual Trading Program NUSA for the 2016 control period is six 

percent (6%) of the statewide budget, or 1,367 allowances. Missouri’s SIP, as outlined in this 

document, is reallocating two (2) of these five (5) excess TR NOx Ozone Season allowances to 
5 

existing units. Therefore, if Missouri’s 2016 TR NOx Ozone Season SIP is approved by EPA, 

three (3) excess allowances from the existing unit budget will be placed in the NUSA for the 

2016 control period, in which case Missouri’s NUSA for the TR NOx Ozone Season Trading 

Program will contain 1,370 allowances for the 2016 control period. 

2.3 Authority to Implement this SIP 

Section 110(a)(2)(D)(i)(I) of the CAA requires States to develop SIPs to address their significant 

impact on downwind states’ nonattainment and maintenance areas. If a state fails to address 

their significant impact on downwind states, then EPA can implement a FIP. States have the 

authority to revise their SIP in order to replace all or portions of a FIP if the requirements of the 

CAA are met. 

Due to the timing of the requirements under the CSAPR FIP and the corresponding federal 

trading programs established under CSAPR, the EPA has issued regulations defining the states’ 

authority to revise their SIP to replace the individual allocation method portions of the CSAPR 

FIP. 40 CFR 52.38 (b)(3) grants states the right to adopt and submit a SIP revision that would 

replace the TR NOx Ozone Season allowance allocation provisions in 40 CFR 97.511(a) for the 

2016 control period provided that certain requirements are met. These requirements include that 

the State must provide a list of TR NOx Ozone Season Units and the allowances allocated to each 

of these units. All of the units on the list must be located in the state and must have commenced 

commercial operation before January 1, 2010. The total number of allowances must not exceed 

the total statewide budget listed in 40 CFR 97.510(a) for the 2016 control period minus the 

NUSA. The list must be submitted electronically in a format prescribed by EPA, and the SIP 

revisions must not provide for any change in the allocations on the list after approval of the SIP 

by EPA. The State must also have notified EPA of its intent to assume allocation authority for 

2016 electronically in a format prescribed by EPA and the SIP revision must be submitted by the 

appropriate deadline (76 FR 48354). The Supplement to the Final CSAPR (76 FR 80760) that 

added Missouri to the TR NOx Ozone Season Trading Program extended the submission 

deadlines for submitting SIPs for the six states that were been added to the TR NOx Ozone 

Season Trading Program as a result of the CSAPR Supplement. The deadline for these six states, 

including Missouri, to submit a SIP to allocate allowances to existing units under the TR NOx

Ozone Season Trading Program for the 2016 control period is October 1, 2015. 

As required by CSAPR, on October 17th, 2011, the Air Program notified EPA of its intent to 

assume the allocation authority for 2013 for the TR NOx Ozone Season Trading Program. As 

clarified in EPA’s CSAPR Interim Final rule that was promulgated on December 3, 2014 (79 FR 

71663), because implementation of the CSAPR was delayed through litigation for three (3) 

years, the letter of intent submitted back in 2011, still satisfies the requirement to submit such a 

letter in order for the state to assume allocation authority for existing units for the 2016 control 

period. 

The Missouri Air Conservation Commission has the legal authority to develop, implement, and 

enforce regulations regarding air pollution, including the requirements of the SIP submittal 

described in this document, under section 643.050 of the Revised Statues of Missouri, also 

known as the Missouri Air Conservation Law. 
6 

2.4 Public Participation and Outreach 

In accordance with Section 110(a)(2) of the CAA, Missouri is required to hold a public hearing 

prior to adoption of a SIP revision and the subsequent submittal to the EPA. The Department 

notified the public and other interested parties of the public hearing and comment period thirty 

(30) days prior to holding such hearing for the SIP revision described in this document as 

follows: 

 Notice of availability the SIP revision described in this document was posted on the 

Department of Natural Resources’ Air Pollution Control Program website by December 

29, 2014: http://www.dnr.mo.gov/env/apcp/stateplanrevisions.htm

 The public hearing on the SIP revision described in this document was held on January 

29, 2015, at 9:00 a.m. CST at the Bennett Springs Conference Room, 1730 E. Elm Street, 

Jefferson City, MO 65101. 

 The comment period for the SIP revision described in this document opened on 

December 29, 2014 and closed on February 5, 2015, at 5:00 p.m. CST, which was seven 

(7) days after the public hearing. 

The Air Program also held several stakeholder meetings and conference calls with CSAPRaffected facilities since the final CSAPR was promulgated on August 8, 2011. The goal of these 

meetings was to discuss the SIP revisions to assume allowance allocation authority under the 

CSAPR. 

2.5 Missouri TR NOx Ozone Season Trading Program Allocations for 2016 

Table 1, below, summarizes Missouri’s TR NOx Ozone Season Trading Program Allocations for 

the 2016 control period. Appendix A includes the same allocations as Table 1, but is presented 

in EPA’s prescribed format for submitting state allocations under the CSAPR. 

For clarity, the following list notes the differences between Table 1 and Appendix A: 

 Table 1 includes the facility plant names and ORIS codes for each facility; Appendix A 

includes the facility compliance account numbers that correspond to each plant as 

opposed to their names 

 Table 1 includes the state name in each row; Appendix A includes the state’s primary 

reserve account number from which the allocations will be transferred to each facility. 

 Table 1 does not have a specific column to indicate the vintage year of the allocations is 

2016. Appendix A has a column to specify that the vintage year of the all the allocations 

is 2016. 

 Appendix A will be submitted to EPA electronically as a Microsoft Excel document and 

will be titled Missouri 2016 Existing Unit Allocations – TR NOx Ozone Season Trading 

Program. 

By October 1, 2015, the Air Program will submit a SIP revision to EPA with Missouri’s TR NOx

Ozone Season Trading Program Allocations for the 2016 control period. The SIP revision will 

contain the table in Appendix A, and will be submitted electronically in the format prescribed by 

EPA. 
7 

Table 1. Missouri TR NOx Ozone Season Allocations for the 2016 Control Period 

Plant Name State ORIS ID Boiler ID 

2016 TR NOx Ozone 

Season Allocation 

Asbury Missouri 2076 1 444

Audrain Power Plant Missouri 55234 CT1 1

Audrain Power Plant Missouri 55234 CT2 1

Audrain Power Plant Missouri 55234 CT3 1

Audrain Power Plant Missouri 55234 CT4 1

Audrain Power Plant Missouri 55234 CT5 1

Audrain Power Plant Missouri 55234 CT6 1

Audrain Power Plant Missouri 55234 CT7 1

Audrain Power Plant Missouri 55234 CT8 1

Blue Valley Missouri 2132 3 73

Chamois Power Plant Missouri 2169 2 114

Chillicothe Missouri 2122 GT1A 1

Chillicothe Missouri 2122 GT1B 0

Chillicothe Missouri 2122 GT2A 0

Chillicothe Missouri 2122 GT2B 0

Columbia Missouri 2123 6 20

Columbia Missouri 2123 7 29

Columbia Missouri 2123 8 0

Columbia Energy Center (MO) Missouri 55447 CT01 1

Columbia Energy Center (MO) Missouri 55447 CT02 1

Columbia Energy Center (MO) Missouri 55447 CT03 1

Columbia Energy Center (MO) Missouri 55447 CT04 0

Dogwood Energy Facility Missouri 55178 CT-1 23

Dogwood Energy Facility Missouri 55178 CT-2 18

Empire District Elec Co Energy Ctr Missouri 6223 1 1

Empire District Elec Co Energy Ctr Missouri 6223 2 2

Empire District Elec Co Energy Ctr Missouri 6223 3A 6

Empire District Elec Co Energy Ctr Missouri 6223 3B 6

Empire District Elec Co Energy Ctr Missouri 6223 4A 6

Empire District Elec Co Energy Ctr Missouri 6223 4B 6

Essex Power Plant Missouri 7749 1 8

Fairgrounds Missouri 2082 CT01 0

Greenwood Energy Center Missouri 6074 1 3

Greenwood Energy Center Missouri 6074 2 2

Greenwood Energy Center Missouri 6074 3 3

Greenwood Energy Center Missouri 6074 4 3

Hawthorn Missouri 2079 5A 1,082

Hawthorn Missouri 2079 6 1

Hawthorn Missouri 2079 7 6

Hawthorn Missouri 2079 8 7

Hawthorn Missouri 2079 9 21

Higginsville Municipal Power Plant Missouri 2131 4A 1

Higginsville Municipal Power Plant Missouri 2131 4B 0

Holden Power Plant Missouri 7848 1 3

Holden Power Plant Missouri 7848 2 4
8 

Plant Name State ORIS ID Boiler ID 

2016 TR NOx Ozone 

Season Allocation 

Holden Power Plant Missouri 7848 3 3

Howard Bend Missouri 2102 CT1A 0

Howard Bend Missouri 2102 CT1B 0

Iatan Missouri 6065 1 1,550

James River Missouri 2161 **GT1 7

James River Missouri 2161 **GT2 13

James River Missouri 2161 3 99

James River Missouri 2161 4 115

James River Missouri 2161 5 210

John Twitty Energy Center Missouri 6195 1 396

John Twitty Energy Center Missouri 6195 CT1A 1

John Twitty Energy Center Missouri 6195 CT1B 1

John Twitty Energy Center Missouri 6195 CT2A 1

John Twitty Energy Center Missouri 6195 CT2B 1

Labadie Missouri 2103 1 986

Labadie Missouri 2103 2 1,038

Labadie Missouri 2103 3 1,121

Labadie Missouri 2103 4 1,100

Lake Road Missouri 2098 6 200

Lake Road Missouri 2098 GT5 1

McCartney Generating Station Missouri 7903 MGS1A 10

McCartney Generating Station Missouri 7903 MGS1B 10

McCartney Generating Station Missouri 7903 MGS2A 9

McCartney Generating Station Missouri 7903 MGS2B 9

Meramec Missouri 2104 1 287

Meramec Missouri 2104 2 281

Meramec Missouri 2104 3 545

Meramec Missouri 2104 4 713

Meramec Missouri 2104 CT01 0

Meramec Missouri 2104 CT2A 0

Meramec Missouri 2104 CT2B 0

Mexico Missouri 6650 CT01 0

Moberly Missouri 6651 CT01 1

Montrose Missouri 2080 1 351

Montrose Missouri 2080 2 333

Montrose Missouri 2080 3 346

Moreau Missouri 6652 CT01 0

New Madrid Power Plant Missouri 2167 1 1,115

New Madrid Power Plant Missouri 2167 2 1,121

Nodaway Power Plant Missouri 7754 1 4

Nodaway Power Plant Missouri 7754 2 5

Northeast Generating Station Missouri 2081 11 0

Northeast Generating Station Missouri 2081 12 0

Northeast Generating Station Missouri 2081 13 0

Northeast Generating Station Missouri 2081 14 0

Northeast Generating Station Missouri 2081 15 0
9 

Plant Name State ORIS ID Boiler ID 

2016 TR NOx Ozone 

Season Allocation 

Northeast Generating Station Missouri 2081 16 0

Northeast Generating Station Missouri 2081 17 0

Northeast Generating Station Missouri 2081 18 0

Peno Creek Energy Center Missouri 7964 CT1A 8

Peno Creek Energy Center Missouri 7964 CT1B 8

Peno Creek Energy Center Missouri 7964 CT2A 8

Peno Creek Energy Center Missouri 7964 CT2B 7

Peno Creek Energy Center Missouri 7964 CT3A 7

Peno Creek Energy Center Missouri 7964 CT3B 8

Peno Creek Energy Center Missouri 7964 CT4A 8

Peno Creek Energy Center Missouri 7964 CT4B 8

Ralph Green Station Missouri 2092 3 1

Rush Island Missouri 6155 1 885

Rush Island Missouri 6155 2 916

Sibley Missouri 2094 1 102

Sibley Missouri 2094 2 106

Sibley Missouri 2094 3 689

Sikeston Missouri 6768 1 618

Sioux Missouri 2107 1 872

Sioux Missouri 2107 2 778

South Harper Peaking Facility Missouri 56151 1 12

South Harper Peaking Facility Missouri 56151 2 16

South Harper Peaking Facility Missouri 56151 3 20

St. Francis Power Plant Missouri 7604 1 19

St. Francis Power Plant Missouri 7604 2 18

State Line (MO) Missouri 7296 1 5

State Line (MO) Missouri 7296 2-1 28

State Line (MO) Missouri 7296 2-2 29

Thomas Hill Energy Center Missouri 2168 MB1 412

Thomas Hill Energy Center Missouri 2168 MB2 628

Thomas Hill Energy Center Missouri 2168 MB3 1,315

Viaduct Missouri 2096 CT01 0
Appendix A 

Missouri 2016 NOx Ozone Season Allocations 

The table on the following pages includes the 2016 NOx Ozone Season Allocations under the 

Cross-State Air Pollution Rule that the Missouri Department of Natural Resources’ Air Pollution 

Control Program intends to submit to EPA by October 1st, 2015. The table is in the format 

prescribed by EPA; however, when the table is submitted to EPA, it will be submitted 

electronically as a Microsoft Excel Document and this cover page will not be included. 

 
STReserveAcct ReceiveAcct UnitId VintageYear Amount 

MO0000000100 002076FACLTY 1 2016 444

MO0000000100 055234FACLTY CT1 2016 1

MO0000000100 055234FACLTY CT2 2016 1

MO0000000100 055234FACLTY CT3 2016 1

MO0000000100 055234FACLTY CT4 2016 1

MO0000000100 055234FACLTY CT5 2016 1

MO0000000100 055234FACLTY CT6 2016 1

MO0000000100 055234FACLTY CT7 2016 1

MO0000000100 055234FACLTY CT8 2016 1

MO0000000100 002132FACLTY 3 2016 73

MO0000000100 002169FACLTY 2 2016 114

MO0000000100 002122FACLTY GT1A 2016 1

MO0000000100 002122FACLTY GT1B 2016 0

MO0000000100 002122FACLTY GT2A 2016 0

MO0000000100 002122FACLTY GT2B 2016 0

MO0000000100 002123FACLTY 6 2016 20

MO0000000100 002123FACLTY 7 2016 29

MO0000000100 002123FACLTY 8 2016 0

MO0000000100 055447FACLTY CT01 2016 1

MO0000000100 055447FACLTY CT02 2016 1

MO0000000100 055447FACLTY CT03 2016 1

MO0000000100 055447FACLTY CT04 2016 0

MO0000000100 055178FACLTY CT‐1 2016 23

MO0000000100 055178FACLTY CT‐2 2016 18

MO0000000100 006223FACLTY 1 2016 1

MO0000000100 006223FACLTY 2 2016 2

MO0000000100 006223FACLTY 3A 2016 6

MO0000000100 006223FACLTY 3B 2016 6

MO0000000100 006223FACLTY 4A 2016 6

MO0000000100 006223FACLTY 4B 2016 6

MO0000000100 007749FACLTY 1 2016 8

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----------------------------------

The Missouri Air Conservation Commission ADOPTS the following action 

on this 26th day of March, 2015: 

Missouri State Implementation Plan Revision - Cross-State Air Pollution 

Rule NOx Ozone Season Trading Program 

----,-<:,J. -f----} -f-''-=- ---- ----, Vice Chairman 

, Member 

__________________________________, Member 

, Member 

__________________________________,Member 

1

Vit, Wendy

From: Missouri DNR <MODNR@public.govdelivery.com>

Sent: Monday, December 29, 2014 8:57 AM

To: Bungart, Renee; Archer, Larry; Lovejoy, Victoria; Moore, Kyra; Vit, Wendy; Bechtel, Cheri; 

Terlizzi, Gena; Alexander, Jennifer

Subject: Courtesy Copy: Missouri Air Conservation Commission - January 29, 2015 Public Hearing

This is a courtesy copy of an email bulletin sent by Wendy Vit.

This bulletin was sent to the following groups of people:

Subscribers of Air Public Notices (691 recipients) 

Having trouble viewing this email? View it as a Web page.

MISSOURI AIR CONSERVATION COMMISSION 

WILL HOLD PUBLIC HEARING 

JEFFERSON CITY, MO -- The Missouri Air Conservation Commission will hold a public hearing on 

Thursday, January 29, 2015 beginning at 9 a.m. at the Elm Street Conference Center, 1730 East Elm Street, 

Lower Level, Bennett Springs Conference Room, Jefferson City, Missouri. The commission will hear 

testimony related to the following proposed action(s): 

 

* Missouri State Implementation Plan Revision – Cross-State Air Pollution Rule (CSAPR) NOx Annual 

Trading Program 

 

This proposed State Implementation Plan (SIP) revision will reallocate four oxides of nitrogen (NOx) 

annual allowances under the U.S. Environmental Protection Agency’s Cross-State Air Pollution Rule. 

Two NOx annual allowances each will be distributed to the City of Chillicothe and the City of 

Higginsville. These two municipalities would have received zero allowances under the federal allocation 

method. All other existing unit budget allowances will be distributed following the federal allocation

method. This SIP revision redistributes emission allowances for the 2016 control period only. The 

Missouri Department of Natural Resources’ Air Pollution Control Program is pursuing a separate 

rulemaking and SIP revision to reallocate allowances for the control period 2017 and beyond. 

 

* Missouri State Implementation Plan Revision – Cross-State Air Pollution Rule (CSAPR) NOx Ozone 

Season Trading Program 

 

This proposed State Implementation Plan (SIP) revision will reallocate two oxides of nitrogen (NOx) 

ozone season allowances under the U.S. Environmental Protection Agency’s Cross-State Air Pollution 

Rule. One NOx ozone season allowance each will be distributed to the City of Chillicothe and the City of 

Higginsville. These two municipalities would have received zero allowances under the federal allocation 
2

method. All other existing unit budget allowances will be distributed following the federal allocation

method. This SIP revision redistributes emission allowances for the 2016 control period only. The 

Missouri Department of Natural Resources’ Air Pollution Control Program is pursuing a separate 

rulemaking and SIP revision to reallocate allowances for the control period 2017 and beyond. 

 

If the Commission adopts these actions, it will be the Department’s intention to submit them to the U.S. 

Environmental Protection Agency to be included in Missouri’s State Implementation Plan. 

 

Documents for the above item(s) will be available for review at the Missouri Department of Natural 

Resources, Air Pollution Control Program, 1659 Elm Street, Jefferson City, (573) 751-4817 and in the Public 

Notices section of the program web site http://dnr.mo.gov/env/apcp/public-notices.htm. This information will 

be available at least 30 days prior to the public hearing date. 

The Department will accept written or email comments for the record until 5 p.m. on February 5, 2015. Please 

send written comments to Chief, Air Quality Planning Section, Air Pollution Control Program, P.O. Box 176, 

Jefferson City, MO 65102-0176. Email comments may be submitted via the program web site noted above. 

All written and email comments and public hearing testimony will be equally considered. 

 

Citizens wishing to speak at the public hearing should notify the secretary to the Missouri Air Conservation 

Commission, Missouri Department of Natural Resources, Air Pollution Control Program, P.O. Box 176, 

Jefferson City, Missouri 65102-0176, or telephone (573) 526-3420. The Department requests persons 

intending to give verbal presentations also provide a written copy of their testimony to the commission 

secretary at the time of the public hearing. 

 

Persons with disabilities requiring special services or accommodations to attend the meeting can make 

arrangements by calling the Program directly at (573) 751-4817, the Division of Environmental Quality's toll 

free number at (800) 361-4827, or by writing two weeks in advance of the meeting to: Missouri Department 

of Natural Resources, Air Conservation Commission Secretary, P.O. Box 176, Jefferson City, MO 65102. 

Hearing impaired persons may contact the program through Relay Missouri, (800) 735-2966. 

 

 

Celebrating 40 years of taking care of Missouri's natural resources. To learn more visit dnr.mo.gov.

 

 Questions? 

 Contact Us

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State Plan Actions on Public Notice - DNR

http://www.dnr.mo.gov/env/apcp/stateplanrevisions.htm[12/23/2014 9:14:52 AM]

Jay Nixon, Governor

Sara Parker Pauley,

 Director

Air Pollution Control Program

State Plan Action

On Public Notice | Proposed for Adoption

On Public Notice

Missouri State Implementation Plan Revision – Cross-State Air Pollution Rule (CSAPR) NOx Annual Trading

 Program

The Missouri Department of Natural Resources’ Air Pollution Control Program is proposing a State Implementation Plan

 (SIP) revision to reallocate four NOx annual allowances under the U.S. Environmental Protection Agency’s Cross-State

 Air Pollution Rule. Two NOx annual allowances each would be distributed to the City of Chillicothe and the City of

 Higginsville. These two municipalities would have received zero allowances under the federal allocation method. All

 other existing unit budget allowances will be distributed following the federal allocation method.

This SIP revision redistributes emission allowances for the 2016 control period only. The Air Program is pursuing a

 separate rulemaking and SIP revision to reallocate allowances for the control period 2017 and beyond.

CSAPR SIP-NOx Annual 

Appendix A

Submit Comments Now 

A public hearing is scheduled for this plan action on January 29, 2015. Comments about this plan action will be accepted

 through the close of business on February 5, 2015.

Missouri State Implementation Plan Revision – Cross-State Air Pollution Rule (CSAPR) NOx Ozone Season

 Trading Program

The Missouri Department of Natural Resources’ Air Pollution Control Program is proposing a State Implementation Plan

 (SIP) revision to reallocate two NOX Ozone Season allowances under the U.S. Environmental Protection Agency’s

 Cross-State Air Pollution Rule. One NOX ozone season allowance each will be distributed to the City of Chillicothe and

 the City of Higginsville. These two municipalities would have received zero allowances under the federal allocation

 method. All other existing unit budget allowances will be distributed following the federal allocation method.

This SIP revision redistributes emission allowances for the 2016 control period only. The Air Program is pursuing a

 separate rulemaking and SIP revision to reallocate allowances for the control period 2017 and beyond.

CSAPR SIP-NOx Ozone Season 

Appendix A 

Submit Comments Now

A public hearing is scheduled for this plan action on January 29, 2015. Comments about this plan action will be accepted

 through the close of business on February 5, 2015.

Proposed for Adoption

None at this time.

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Help
 PUBLIC HEARING 1/29/2015

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334

MIDWEST LITIGATION SERVICES

Page 1

1 BEFORE THE MISSOURI AIR CONSERVATION COMMISSION MEETING

2

3

4

5 PUBLIC HEARING

Missouri State Implementation Plan Revision - Cross-State Air

6 Pollution Rule NOx Annual Trading Program; Missouri State

 Implementation Plan Revision - Cross-State Air Pollution

7 Rule NOx Ozone Season Trading Program

8

9 January 29, 2015

 Elm Street Conference Center

10 1730 East Elm Street

 Lower Level

11 Jefferson City, MO 65101

12

13 Before:

14 Gary Pendergrass - Chair

Jack Baker - Member

15 Mark Garnett - Member

David Zimmermann - Member

16

17

18 THE COURT REPORTER:

19 Jenna Petree

MIDWEST LITIGATION SERVICES

20 401 Locust Street

Columbia, MO 65201

21 573-449-0561

22

23

24

25
 PUBLIC HEARING 1/29/2015

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334

MIDWEST LITIGATION SERVICES

Page 2

1 Proceedings

2 MR. BAKER: The hearing will come to order.

3 Let the record show the following Commissioners are

4 present: Jack Baker, David Zimmermann, Mark Garnett, and

5 Gary Pendergrass by phone. Air Commission -- the Air

6 Conservation Commission of the State of Missouri has called

7 this public hearing pursuant to Section 643.070 Revised

8 Statutes of Missouri; EPA promulgated rule 40 CFR 51.102,

9 for the purpose of hearing testimony relating to: Missouri

10 State Implementation Plan Revision - Cross-State Air

11 Pollution Rule NOx Annual Trading Program; Missouri State

12 Implementation Plan Revision - Cross-State Air Pollution

13 Rule NOx Ozone Season Trading Program.

14 The hearing will close at 5:00 p.m. on

15 February 5, 2015.

16 Anyone how has not been scheduled to appear,

17 but who wishes to be heard, should indicate that you wish

18 to speak on the sign-in sheet available at the door.

19 Section 643.100 of the Missouri Statutes

20 provides that all oral testimony be give under oath.

21 Accordingly, when you are called to testify, please present

22 yourself to the court reporter first to be sworn in.

23 When you testify, please state your name,

24 business address, and your occupation or affiliation.

25 If you have a prepared statement, it will be
 PUBLIC HEARING 1/29/2015

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334

MIDWEST LITIGATION SERVICES

Page 4

1 MR. BAKER: Okay. We are ready the sensitive

2 findings. I'm on the wrong page. I got ahead of my

3 myself.

4 MARK LEATH, having been first duly sworn, testifies as

5 follows:

6 MR. LEATH: Mr. Chairman, members of the

7 Commission. My name is Mark Leath. I am employed as an

8 environmental engineer with the Missouri Department of

9 Natural Resources' Air Pollution Control Program. I work

10 at 1659 East Elm Street, Jefferson City, Missouri.

11 I am here today to present testimony on two

12 proposed Missouri State Implementation Plan or the SIP

13 revisions entitled, "Cross-State Air Pollution Rule, or

14 CSAPR, NOx Annual Trading Program, and Cross-State Air

15 Pollution Rule NOx Ozone Season Trading Program." The

16 executive summaries for these two plans start in the

17 briefing document on pages 99 and 105, respectively.

18 If it pleases the Commission, I would like to

19 present both plans together.

20 The CSAPR is a federal rule designed to reduce

21 the interstate transport of power plant emissions through

22 an EPA-administered emission cap-and-trade program. CSAPR

23 is being implemented as a Federal Implementation Plan, or

24 FIP, effective without action by starting in 2015, but

25 states have the option to reallocate emission allowances
RECOMMENDATION FOR ADOPTION 

PROPOSED REVISION TO 

MISSOURI STATE IMPLEMENTATION PLAN – 

CROSS-STATE AIR POLLUTION RULE (CSAPR) 

NOx OZONE SEASON TRADING PROGRAM 

On January 29, 2014, the Missouri Air Conservation Commission held a public hearing for a 

revision to the Missouri State Implementation Plan (SIP) entitled – Cross-State Air Pollution 

Rule (CSAPR) NOx Ozone Season Trading Program. A summary of comments received and the 

Air Program’s corresponding responses is included on the following page. No revisions were 

made to the proposed plan as a result of comments received. 

The plan has not been reprinted in the briefing document due to its volume. The entire plan is 

available for review at the Missouri Department of Natural Resources’ Air Pollution Control 

Program, 1659 East Elm Street, Jefferson City, Missouri, 65101, (573)751-4817. It is also 

available online at http://dnr.mo.gov/env/apcp/stateplanrevisions.htm. 

The Air Program recommends the commission adopt the plan as proposed. If the commission 

adopts this plan, it will be the department’s intention to submit it to the U.S. Environmental 

Protection Agency for inclusion in the Missouri State Implementation Plan. 
COMMENTS AND RESPONSES ON 

PROPOSED REVISION TO 

MISSOURI STATE IMPLEMENTATION PLAN – 

CROSS-STATE AIR POLLUTION RULE (CSAPR) 

NOx OZONE SEASON TRADING PROGRAM 

The public comment period for the proposed revision to the Missouri State Implementation Plan 

(SIP) for the Cross-State Air Pollution Rule (CSAPR) NOx Ozone Season Trading Program

opened on December 29, 2014 and closed on February 5, 2015. No revisions to the proposed 

plan were made as a result of comments. However, minor clarifications and revisions were made 

to the supplemental document that will accompany the plan as a result of internal review. 

The following is a summary of comments received and the Missouri Department of Natural 

Resources’ Air Pollution Control Program’s (Air Program’s) corresponding responses. 

SUMMARY OF COMMENTS: During the public comment period for the proposed plan, the 

Air Program did not receive any comments. 

SUMMARY OF MINOR CHANGES: The SIP revision being proposed for adoption only consists 

of the list of existing units and their corresponding TR NOx Ozone Season Allocations for the 2016 

control period under CSAPR. The supplemental document that will accompany the SIP revision 

describes the background, purpose, and authority to submit this list as a SIP revision to the U.S. 

Environmental Protection Agency (EPA). Accordingly, the document describing the SIP revision 

has been renamed for clarity to show that it is a supplemental document that will accompany the 

SIP revision. The Air Program is only requesting SIP approval of the list that will be submitted 

and not the document itself. In addition to the title change of the supplemental document, other 

minor changes and clarifications were made to the supplemental document as follows: 

 Throughout the document, minor narrative changes were made to provide clarity that only 

the list of allocations will be submitted as a SIP revision and that the document only 

explains the background, purpose, and authority to do so. 

 A list was added to subsection 2.5 of the document to clearly explain the differences 

between the information displayed in Table 1 of the document and the information 

displayed in Appendix A. 

 References to EPA’s CSAPR Interim Final Rule, which was promulgated in December 

2014, were added to section 1 and subsection 2.3 of the document.