Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 1 

# memorandum

Environment and Resources 55 Wheeler Street, Cambridge, MATel: 617 492-7100www.abtassociates.com



### Date April 4, 2011

To Erik Helm

From Tatiana Melnikova and Michael Fisher

Subject Cost and Economic Impact Analysis Using Alternative IPM Unit Closure Definition and

New Unit Cost Estimates

As described inChapter 6: Assessing the Impact of the Existing Facilities Regulatory Options in the Context of National Electricity MarketsofEconomic and Benefits Analysis for Proposed Section 316(b) Existing Facilities Rule(theEA report), EPA used ICF International’s Integrated Planning Model (IPM) to assess the economic impact of the existing facilities rule regulatory options within the context of regional and national electricity markets. The IPM analysis requires a baseline projection of operations by plant and generating unit, which is aggregated to the market level, over the relevant analysis period, independent of the effect of the existing facilities rule regulatory options (theIPM baseline). The information projected by IPM for this baseline includes operating statistics such as total electricity generated by individual plants and units, available capacity for electric generation, fuel consumption and electricity production cost, electricity price at the NERC regional market level, and the occurrence of capacity retirements and capacity additions1



### . The IPM baseline provides the foundation for assessing the effects of alternative regulatory options, most directly in the IPM-based analysis of market-level effects but also for the cost and economic impact analysis that is performed apart from the IPM market-level analysis. In particular, information from the IPM baseline that is used for the more general cost and economic impact analysis includes the projection of baseline operations for plants and generating units within the scope of the existing facilities rule, including a projection that some of these plants and units may cease operation during the period of analysisbefore considerationof the existing facilities rule compliance requirements. These plants and generating units that are projected to close independent of rule requirements are referred to as baseline closures, and are removed from the analysis of the cost and economic impact of the existing facilities rule regulatory options. Another part of the IPM baseline that is used in the general cost and economic impact analysis is the projection of capacity additions, which is used in estimating the potential cost of installing cooling tower technology at new generating units at existing facilities as specified in the existing facilities rule regulatory options. For these two items of information from the IPM baseline – projection of baseline closures and projection of new generating capacity – we received and processed information from the IPM baseline in accordance with certain interpretations of this information. However, we learned in the course of our analysis that the information on baseline closures and projection of new generating capacity could be interpreted differently. Implementing these alternative data interpretations within the cost and economic impact analysis would led to slightly different estimates of the total cost and economic impact of the regulatory options. This memorandum summarizes these differences of IPM baseline interpretation and the differences in cost and economic impact analysis findings. These alternative interpretations and the

1See Chapter 6 of the EA report for additional information on the data items for which IPM develops a baseline projection.Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 2



### general effect on the analysis are summarized in the following section. Following this overview, we provide summary results for the cost and economic impact analysis, using the same organization and table formats as documented in the EA report.



## 1 Differences in Interpretation IPM Baseline Information

1.1 Projection of Baseline Closures The IPM baseline includes projections of retired units (“early retirement” is the IPM baseline designation), which are generally taken to mean that the generating unit will be completely unavailable for electric power generation and thus would not be expected to incur compliance costs as a result of regulatory requirements. In the course of our work with the IPM baseline, we observed that a few generating units identified in the IPM baseline run as early retirements – and built into the rule analysis as baseline closures – in fact had some level of ongoing expenses suggesting that the units were not “truly closed.” In follow-up with ICF, we learned that these early retirement units are “partial closures,” meaning that their operation was limited to generation levels below their reported generating capacity but that, technically speaking, the units could remain available for electric power generation. In the primary analyses as documented in the EA report, we treated thesepartial closureunits as full unit closures. In some cases, thesepartial closureunits would lead to the interpretation that the entire steam generating capacity at a plant was closed in the baseline (and thus would constitute a baseline closure plant); in others, thepartial closureunits reflected only a part of the steam generating capacity otherwise operating at a plant and so were interpreted as a closure of specific generating units, but with the plant remaining subject to regulatory requirements. Accordingly, in the analysis presented in the EA report, these units and, in some instances, the total plant received no compliance costs. Including these generating units and plants in the analysis would have led to higher estimates of compliance cost and potentially higher estimates of plant-level impacts. As reported inTable 1-1, below, if the partial closure units had not been treated as full early retirements, the number of baseline closure units would have declined from 381 to 353.

Table 1-1: Summary of Different Baseline Closure Estimates Under Alternative Interpretations of IPM Baseline Closure Information

Number of Retired Units Unit Type (Steam Generating Only) Original Alternative Change Coal Steam 22 16 -6 Combined Cycle 60 52 -8 Nuclear 5 3 -2 O/G Steam 294 282 -12 Total 381 353 -28 Source: U.S. EPA analysis, 2011



### As reported in detail in the following sections, the effect on total costs and impacts is comparatively small given the small number of plants and/or units affected by the alternative analytic treatment. For example, total annualized cost to complying facilities for the proposed rule option, Option 1, increases from approximately $475.0 million to $479.1 million (pre-tax cost at 7 percent discount rate), or less than a one percent change (0.8%). For some cost metrics, the estimated cost declines slightly due to the use ofAbt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 3



### modestly different sample weights based on including additional facilities in the analysis.2

### Similarly, impact metrics record small changes. For example, for Option 1, the estimated number of facilities incurring costs between one and three percent of revenue increases by 2 facilities, and the number exceeding three percent of revenue is unchanged. For Option 2, the number of facilities incurring costs between one and three percent of revenue is unchanged, and the number exceeding three percent of revenue increases by 3 facilities. For Option 3, the number of facilities incurring costs between one and three percent of revenue declines by 1 facility, while the number exceeding three percent of revenue increases by 3 facilities. As another illustration of the small effect on analysis findings, in terms of small entity impacts, the number of small entities estimated to incur an adverse effect at either the 1 percent or 3 percent of revenue thresholds under the proposed Option 1 does not change.

1.2 Projection of New Capacity at Existing Facilities Subject to Regulatory Requirements The IPM analysis is based on run-years that generally represent additional years beyond the designated run-year, as described in Chapter 6 of the EA report. For example, the run-year 2020 represents the 5-year period, 2017-2022. In using the results from the IPM baseline analysis, we interpreted that each of the five run-years, 2012, 2015, 2020, 2025, and 2028, represented specific years as follows:

2012 – represents 2012 2015 – represents 2013-2017 2020 – represents 2018-2022 2025 – represents 2023-2027 2028 – represents 2028-2035. In developing the estimates of new generating capacity potentially subject to the new generating units at existing facilities requirement of the proposed rule, we summed the IPM-projected capacity additions in each of the specified run-year periods, over the entire IPM baseline analysis period and then divided this total by the number of years in the total baseline period. This calculation led to an estimated annual average capacity addition that would be subject to the requirement to install cooling towers at new generating units. Using the run-year specifications as outlined above, we divided the total estimatedcapacity addition by 24 years. We later learned that the new capacity addition reported for the 2028 runyear represented only one year in the IPM run and that the annual average of new capacity would have been better calculated by dividing by 17 years instead of 24 years. Based on this recalculation, the estimated annual addition of capacity in new generating units subject to the cooling tower requirement increases as reported inTable 1-1, below. These capacity values refer only to new units constructed at existing facilities and were developed following the same calculation methodology as described in Chapter 3, Section 3.3: Development of Costs for New Units of the EA report,

Table 1-2: Estimated Annual New Capacity Installation Subject to Cooling Tower Requirement (MW) Capacity Type Original Alternative Change Coal 482 681 199 Combined Cycle 34 47 13 Nuclear - - - Source: U.S. EPA analysis, 2011

2The weights used for calculation of results reported in this memorandum are slightly different from the weights used to generate the cost and economic results presented in the EA report because they were developed for a slightly different set of facilities; specifically, the in-scope facility universe includes facilities previously identified as baseline IPM closures and excluded from the development of weights applicable to facilities in the cost and economic impact analysis. See EA report Appendix 3A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses for additional information on development of sample weights for the cost and economic impact analysis.Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 4



### As a result of the increased rate of new capacity installation at existing facilities, the estimated annualized compliance cost increases proportionately to the increase in capacity, with pre-tax annualized cost increasing from $11.3 million to $16.4 million.

1.3 Overall Effect As highlighted in the preceding sections, the effect of reducing the number of baseline closures in the analysis is very small, with slight changes in costs and very little change, if any, in impact findings. As stated above, the estimated numbers of facilities incurring a given cost-to-revenue impact changes by very small amounts, and the number of small entities estimated to incur costs exceeding either the one or three percent of revenue threshold does not change at all. The effect of changing the calculation of new capacity at existing facilities subject to the cooling tower installation requirement is more substantial as a percentage effect – approximately a 45 percent increase in related costs – but the consequence of this increase in the overall rule analysis is small. For example, total social cost (including accounting for the new units compliance provision) would increase by $7 million (3 percent discount rate) or less than 2 percent of the current estimated total social cost, including accounting for the new units compliance provision.


## 2 EA Report Results Tables with Alternative Baseline Closures and New Units at Existing Facilities Calculations

The following pages contain the summary tables from the EA report using the alternative baseline closures and new units at existing facilities calculations, as outlined above. These tables have the same table numbering and format as those presented in the EA report. Because the alternative calculations do not apply to the Manufacturers in-scope industry segment, only tables and results for Electric Generators are presented below, except in those instances (e.g., UMRA and social cost analysis) where results are tabulated across the Electric Generators and Manufacturers segments in the EA report.Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 5



## Chapter 3: Development of Costs for Regulatory Options

Table 3-7: Annualized Compliance Costs by NERC Region (in millions, $2009, at 2012)a One-Time Costs Recurring Costs

NERC Region Capital

TechnologyConnection

OutageInitial Permit

Application O&M Monitoring, Record Keeping, and Reporting Energy

Penalty Permit

Renewal Total Option 1: IM Everywhere Pre-Tax Compliance Costs ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 ERCOT $12.11 $3.62 $0.11 $15.08 $1.79 $0.00 $0.10 $32.81 FRCC $15.35 $5.91 $0.06 $10.14 $1.00 $0.00 $0.06 $32.52 HICC $1.38 $0.00 $0.01 $1.91 $0.17 $0.00 $0.01 $3.48 MRO $7.01 $5.78 $0.12 $9.91 $2.14 $0.00 $0.11 $25.06 NPCC $14.31 $0.00 $0.16 $24.89 $2.66 $0.00 $0.15 $42.16 RFC $47.02 $6.15 $0.42 $56.03 $7.86 $0.00 $0.39 $117.88 SERC $36.80 $6.71 $0.40 $49.29 $6.92 $0.00 $0.38 $100.51 SPP $6.56 $31.17 $0.09 $12.62 $1.57 $0.00 $0.08 $52.09 WECC $1.05 $0.44 $0.06 $0.83 $0.85 $0.00 $0.06 $3.28 Total $141.58 $59.79 $1.42 $180.70 $24.96 $0.00 $1.34 $409.79 After-Tax Compliance Costs ASCC 

### $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 ERCOT 

### $8.46 $2.35 $0.08 $11.16 $1.33 $0.00 $0.07 $23.45 FRCC 

### $9.45 $3.63 $0.04 $6.25 $0.65 $0.00 $0.04 $20.06 HICC 

### $0.84 $0.00 $0.00 $1.16 $0.11 $0.00 $0.00 $2.12 MRO 

### $5.59 $5.71 $0.08 $7.23 $1.45 $0.00 $0.07 $20.13 NPCC 

### $8.54 $0.00 $0.10 $14.82 $1.61 $0.00 $0.09 $25.16 RFC 

### $28.25 $3.72 $0.26 $33.90 $4.97 $0.00 $0.25 $71.35 SERC 

### $26.09 $4.07 $0.28 $35.45 $4.83 $0.00 $0.27 $70.99 SPP 

### $4.22 $19.05 $0.06 $8.14 $1.03 $0.00 $0.05 $32.55 WECC 

### $0.72 $0.26 $0.04 $0.55 $0.56 $0.00 $0.04 $2.17 Total $92.15 $38.80 $0.94 $118.65 $16.54 $0.00 $0.89 $267.98 Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD Pre-Tax Compliance Costsb ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 ERCOT $303.99 $12.27 $0.08 $34.44 $0.19 $144.88 $0.07 $495.91 FRCC $137.06 $10.85 $0.05 $16.38 $0.18 $81.21 $0.04 $245.77 HICC $17.82 $1.44 $0.01 $2.02 $0.00 $4.90 $0.01 $26.19 MRO $120.89 $10.60 $0.10 $14.01 $0.89 $65.26 $0.09 $211.84 NPCC $332.23 $34.23 $0.12 $38.33 $0.55 $202.34 $0.12 $607.93 RFC $814.39 $61.58 $0.33 $93.86 $2.49 $451.55 $0.32 $1,424.53 SERC $852.02 $135.85 $0.32 $97.92 $2.05 $583.37 $0.30 $1,671.83 SPP $183.97 $14.59 $0.07 $21.30 $0.37 $65.54 $0.07 $285.90 WECC $2.98 $0.44 $0.06 $0.99 $0.74 $0.39 $0.05 $5.66 Total $2,765.35 $281.84 $1.13 $319.26 $7.46 $1,599.44 $1.07 $4,975.55 After-Tax Compliance Costs ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 ERCOT $214.74 $8.99 $0.06 $24.33 $0.12 $101.91 $0.05 $350.20 FRCC $86.06 $6.71 $0.03 $10.27 $0.11 $50.19 $0.03 $153.41 HICC $10.84 $0.88 $0.00 $1.23 $0.00 $2.98 $0.00 $15.93 MRO $89.19 $7.51 $0.06 $10.30 $0.53 $46.42 $0.06 $154.07 NPCC $197.67 $20.31 $0.08 $22.82 $0.36 $120.47 $0.07 $361.78 RFC $489.09 $37.09 $0.21 $56.49 $1.72 $271.26 $0.20 $856.06 SERC $624.12 $105.83 $0.22 $71.71 $1.48 $428.18 $0.21 $1,231.75 SPP $117.20 $9.07 $0.05 $13.66 $0.27 $41.07 $0.04 $181.36 WECC $1.92 $0.26 $0.04 $0.65 $0.50 $0.24 $0.04 $3.65 Total $1,830.82 $196.65 $0.75 $211.46 $5.10 $1,062.72 $0.71 $3,308.22Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 6



### Table 3-7: Annualized Compliance Costs by NERC Region (in millions, $2009, at 2012)a One-Time Costs Recurring Costs

NERC Region Capital

TechnologyConnection

OutageInitial Permit

Application O&M Monitoring, Record Keeping, and Reporting Energy

Penalty Permit

Renewal Total Option 3: I&E Mortality Everywhere Pre-Tax Compliance Costs ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 ERCOT $303.99 $12.27 $0.08 $34.44 $0.19 $144.88 $0.07 $495.91 FRCC $138.35 $11.69 $0.04 $16.49 $0.07 $84.44 $0.04 $251.13 HICC $17.82 $1.44 $0.01 $2.02 $0.00 $4.90 $0.01 $26.19 MRO $129.86 $11.60 $0.09 $14.84 $0.22 $70.70 $0.08 $227.40 NPCC $345.15 $37.42 $0.11 $39.12 $0.00 $223.94 $0.10 $645.86 RFC $826.49 $63.91 $0.32 $94.28 $1.46 $467.57 $0.30 $1,454.35 SERC $866.66 $144.67 $0.30 $98.94 $1.23 $616.39 $0.29 $1,728.48 SPP $183.97 $14.59 $0.07 $21.30 $0.37 $65.54 $0.07 $285.90 WECC $4.01 $0.54 $0.05 $0.93 $0.53 $0.93 $0.05 $7.05 Total $2,816.31 $298.13 $1.07 $322.37 $4.07 $1,679.31 $1.01 $5,122.27 After-Tax Compliance Costs ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 ERCOT $214.74 $8.99 $0.06 $24.33 $0.12 $101.91 $0.05 $350.20 FRCC $86.85 $7.23 $0.03 $10.34 $0.04 $52.18 $0.03 $156.70 HICC $10.84 $0.88 $0.00 $1.23 $0.00 $2.98 $0.00 $15.93 MRO $94.56 $8.15 $0.06 $10.79 $0.13 $49.77 $0.05 $163.51 NPCC $205.80 $22.25 $0.07 $23.33 $0.00 $133.69 $0.06 $385.20 RFC $498.13 $38.71 $0.20 $56.85 $0.93 $283.13 $0.19 $878.14 SERC $636.46 $113.41 $0.21 $72.58 $0.80 $455.56 $0.20 $1,279.22 SPP $117.20 $9.07 $0.05 $13.66 $0.27 $41.07 $0.04 $181.36 WECC $2.70 $0.32 $0.04 $0.60 $0.33 $0.60 $0.04 $4.62 Total $1,867.28 $209.00 $0.71 $213.71 $2.63 $1,120.89 $0.67 $3,414.89 Option 4: IM for Facilities with DIF>50MGDPre-Tax Compliance Costs ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 ERCOT $11.84 $3.62 $0.11 $15.07 $1.68 $0.00 $0.10 $32.43 FRCC $15.35 $5.91 $0.06 $10.14 $1.00 $0.00 $0.06 $32.52 HICC $1.38 $0.00 $0.01 $1.91 $0.17 $0.00 $0.01 $3.48 MRO $6.66 $5.78 $0.12 $9.60 $1.71 $0.00 $0.11 $23.98 NPCC $14.21 $0.00 $0.16 $24.84 $2.51 $0.00 $0.15 $41.87 RFC $46.15 $3.17 $0.42 $55.78 $7.23 $0.00 $0.39 $113.15 SERC $36.34 $6.39 $0.40 $49.13 $6.24 $0.00 $0.38 $98.88 SPP $5.96 $31.03 $0.09 $12.60 $1.44 $0.00 $0.08 $51.20 WECC $0.26 $0.00 $0.06 $0.16 $0.21 $0.00 $0.06 $0.75 Total $138.16 $55.89 $1.42 $179.24 $22.19 $0.00 $1.34 $398.24 After-Tax Compliance Costs ASCC $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 ERCOT $8.28 $2.35 $0.08 $11.15 $1.26 $0.00 $0.07 $23.20 FRCC $9.45 $3.63 $0.04 $6.25 $0.65 $0.00 $0.04 $20.06 HICC $0.84 $0.00 $0.00 $1.16 $0.11 $0.00 $0.00 $2.12 MRO $5.38 $5.71 $0.08 $7.05 $1.19 $0.00 $0.07 $19.49 NPCC $8.46 $0.00 $0.10 $14.78 $1.49 $0.00 $0.09 $24.92 RFC $27.69 $1.87 $0.26 $33.70 $4.50 $0.00 $0.25 $68.28 SERC $25.78 $3.87 $0.28 $35.33 $4.28 $0.00 $0.27 $69.82 SPP $3.86 $18.96 $0.06 $8.13 $0.95 $0.00 $0.05 $32.01 WECC $0.23 $0.00 $0.04 $0.14 $0.17 $0.00 $0.04 $0.61 Total $89.97 $36.40 $0.94 $117.69 $14.61 $0.00 $0.89 $260.50 a. EPA data indicate that no DQ in-scope facilities are located in the ASCC NERC region; an STQ facility in ASCC facility was grouped with STQ facilities in the WECC region (seeAppendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses). Source: U.S. EPA analysis, 2011Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 7



### Table 3-8: Annualized Compliance Costs For Manufacturers and Electric Generators (in millions, $2009, at 2012)a One-Time Costs Recurring Costs

Facility GroupCapital

TechnologyConnection

Outage Initial

Permit Application O&MMonitoring, Record Keeping, and Reporting Energy

Penalty Permit

Renewal Total Option 1: IM Everywhere Pre-Tax Compliance Costs Manufacturers $22.76 $1.34 $1.31 $21.91 $20.71 $0.00 $1.24 $69.26 Generators $141.58 $59.79 $1.42 $180.70 $24.96 $0.00 $1.34 $409.79 Total $164.34 $61.13 $2.73 $202.61 $45.67 $0.00 $2.58 $479.05 After-Tax Compliance Costs Manufacturers $13.79 $0.80 $0.79 $13.25 $12.53 $0.00 $0.75 $41.92 Generators $92.15 $38.80 $0.94 $118.65 $16.54 $0.00 $0.89 $267.98 Total $105.94 $39.60 $1.73 $131.90 $29.07 $0.00 $1.64 $309.90 Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD Pre-Tax Compliance Costs Manufacturers $97.69 $1.31 $1.24 $14.04 $18.97 $47.03 $1.17 $181.44 Generators $2,765.35 $281.84 $1.13 $319.26 $7.46 $1,599.44 $1.07 $4,975.55 Total $2,863.04 $283.15 $2.37 $333.30 $26.43 $1,646.47 $2.24 $5,156.99 After-Tax Compliance Costs Manufacturers $58.89 $0.78 $0.75 $8.50 $11.48 $29.14 $0.71 $110.24 Generators $1,830.82 $196.65 $0.75 $211.46 $5.10 $1,062.72 $0.71 $3,308.22 Total $1,889.71 $197.43 $1.50 $219.96 $16.58 $1,091.86 $1.42 $3,418.46 Option 3: I&E Mortality Everywhere Pre-Tax Compliance Costs Manufacturers $161.45 $0.72 $0.76 $10.91 $6.46 $65.86 $0.72 $246.88 Generators $2,816.31 $298.13 $1.07 $322.37 $4.07 $1,679.31 $1.01 $5,122.27 Total $2,977.76 $298.85 $1.83 $333.28 $10.53 $1,745.17 $1.73 $5,369.15 After-Tax Compliance Costs Manufacturers $97.57 $0.43 $0.46 $6.61 $3.90 $40.45 $0.44 $149.86 Generators $1,867.28 $209.00 $0.71 $213.71 $2.63 $1,120.89 $0.67 $3,414.89 Total $1,964.85 $209.43 $1.17 $220.32 $6.53 $1,161.34 $1.11 $3,564.75 Option 4: IM for Facilities with DIF>50MGDPre-Tax Compliance Costs Manufacturers $16.11 $0.23 $0.35 $16.62 $5.93 $0.00 $0.33 $39.58 Generators $138.16 $55.89 $1.42 $179.24 $22.19 $0.00 $1.34 $398.24 Total $154.27 $56.12 $1.77 $195.86 $28.12 $0.00 $1.67 $437.82 After-Tax Compliance Costs Manufacturers $9.78 $0.14 $0.21 $10.05 $3.60 $0.00 $0.20 $23.98 Generators $89.97 $36.40 $0.94 $117.69 $14.61 $0.00 $0.89 $260.50 Total $99.75 $36.54 $1.15 $127.74 $18.21 $0.00 $1.09 $284.48 Source: U.S. EPA analysis, 2011



### Table 3-10: Annual Capacity Installation Subject to New Units EM Technology Requirement in New Generating Units (MW)

Projected Annual Average New Capacity Subject to

Phase I New Facility RequirementsResidual

Subject to Existing Facilities Rule RequirementsInstall EM

Technology Independent of Rule RequirementsResidual

Incurring Cost due to Existing Facilities Rule RequirementsCapacity

Increase in Existing Units Capacity

Increase in New Units Coal 5,044 3,531 1,513 757 757 76 681 Combined Cycle 2,106 1,074 632 316 316 269 47 Nuclear 1,938 - 1,938 969 969 969 - Source: U.S. EPA analysis, 2011 

### The resulting annualized cost values for the new units EM technology requirement atnew generating unitsare $16.41 million pre-tax and $10.89 million after-tax ($2009, at 2012).Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 8



## Chapter 5: Cost and Economic Impact Analysis – Electric Generators

Cost-to-Revenue Analysis: Facility-Level Screening Analysis Table 5-1: Facility-Level Cost-to-Revenue Analysis Results by NERC Region and Regulatory Optiona,b

Number of Facilities with a Ratio of NERC Region Total Number of Facilitiesc No Revenued<1% 1-3% >3% Minimum Ratio Maximum

Ratio Option 1: IM Everywhere ASCC 0 0 0 0 0 0.00% 0.00% ERCOT 42 5 28 7 2 0.00% 3.28% FRCC 24 0 17 4 4 0.00% 3.49% HICC 3 0 2 2 0 0.34% 1.04% MRO 47 0 41 6 0 0.00% 1.80% NPCC 63 0 49 14 0 0.00% 2.64% RFC 165 0 149 13 3 0.00% 3.58% SERC 160 0 149 6 5 0.00% 3.61% SPP 34 0 28 6 0 0.00% 2.38% WECC 23 0 19 0 4 0.00% 3.38% Total 562 5 482 57 18 0.00% 3.61% Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD ASCC 0 0 0 0 0 0.00% 0.00% ERCOT 42 5 5 1 31 0.00% 43.40% FRCC 24 0 5 4 15 0.00% 35.37% HICC 3 0 0 0 3 3.88% 8.48% MRO 47 0 20 6 22 0.00% 25.35% NPCC 63 0 15 10 38 0.00% 37.53% RFC 165 0 47 15 103 0.00% 12.51% SERC 160 0 44 14 103 0.00% 24.24% SPP 34 0 11 6 17 0.00% 49.66% WECC 23 0 19 0 4 0.00% 40.10% Total 562 5 166 55 336 0.00% 49.66% Option 3: I&E Mortality Everywhere ASCC 0 0 0 0 0 0.00% 0.00% ERCOT 42 5 5 1 31 0.00% 43.40% FRCC 24 0 5 4 15 0.00% 35.37% HICC 3 0 0 0 3 3.88% 8.48% MRO 47 0 6 7 34 0.00% 25.35% NPCC 63 0 0 9 55 1.22% 37.53% RFC 165 0 38 8 119 0.00% 51.38% SERC 160 0 29 22 108 0.00% 28.48% SPP 34 0 11 6 17 0.00% 49.66% WECC 23 0 17 0 6 0.00% 40.10% Total 562 5 112 56 389 0.00% 51.38% Option 4: IM for Facilities with DIF>50MGD ASCC 0 0 0 0 0 0.00% 0.00% ERCOT 42 5 28 7 2 0.00% 3.28% FRCC 24 0 17 4 4 0.00% 3.49% HICC 3 0 2 2 0 0.34% 1.04% MRO 47 0 41 6 0 0.00% 1.80% NPCC 63 0 52 11 0 0.00% 2.64% RFC 165 0 151 12 2 0.00% 3.54% SERC 160 0 150 5 5 0.00% 3.61% SPP 34 0 28 6 0 0.00% 2.38% WECC 23 0 19 0 4 0.00% 3.38% Total 562 5 489 51 17 0.00% 3.61%Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 9

a. No explicitly analyzed facilities are located in the ASCC region. For more information on explicitly and implicitly analyzed facilities see Appendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses

. b. Facility counts may not add up due to rounding. c. Facility counts exclude baseline closures. d. IPM and EIA report no revenue for 2 facilities (5 on a weighted basis); consequently, the facility-level cost-to-revenue analysis is performed for 257 facilities (559 on a weighted basis). Source: U.S. EPA analysis, 2011 

### Cost-to-Revenue Screening Analysis: Parent Entity-Level Analysis Table 5-3: Entity-Level Cost-to-Revenue Analysis Results, Using Facility-Level Weights Number of Facilities with a Ratio of Entity Type Total Number of

Facilitiesa Total Number of

Entities <1% 1-3% >3%UnknownbMinimum Ratio Maximum

Ratio Option 1: IM Everywhere Cooperative 25 11 10 0 1 0 0.00% 3.88% Federal 17 1 1 0 0 0 0.22% 0.22% Investor-owned 305 39 39 0 0 0 0.00% 0.65% Municipality 25 13 9 4 0 0 0.00% 2.55% Nonutility 171 29 22 0 1 6 0.00% 47.84% Other Political Subdivision 2 1 1 0 0 0 0.45% 0.45%

State 17 4 4 0 0 0 0.00% 0.67% Total 562 98 86 4 2 6 0.00% 47.84% Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD Cooperative 25 11 7 1 3 0 0.00% 21.02% Federal 17 1 0 0 1 0 9.19% 9.19% Investor-owned 305 39 22 14 3 0 0.00% 10.97% Municipality 25 13 6 5 2 0 0.01% 17.08% Nonutility 171 29 17 2 4 6 0.00% 519.67% Other Political Subdivision 2 1 0 0 1 0 6.61% 6.61%

State 17 4 3 0 1 0 0.00% 13.40% Total 562 98 55 22 15 6 0.00% 519.67% Option 3: I&E Mortality Everywhere Cooperative 25 11 4 3 4 0 0.00% 21.02% Federal 17 1 0 0 1 0 9.19% 9.19% Investor-owned 305 39 21 15 3 0 0.00% 10.97% Municipality 25 13 2 5 6 0 0.57% 17.08% Nonutility 171 29 17 2 4 6 0.00% 519.67% Other Political Subdivision 2 1 0 0 1 0 6.61% 6.61%

State 17 4 2 1 1 0 0.00% 13.40% Total 562 98 46 26 20 6 0.00% 519.67% Option 4: IM for Facilities with DIF>125MGD Cooperative 25 11 10 0 1 0 0.00% 3.88% Federal 17 1 1 0 0 0 0.22% 0.22% Investor-owned 305 39 39 0 0 0 0.00% 0.65% Municipality 25 13 10 3 0 0 0.00% 1.46% Nonutility 171 29 22 0 1 6 0.00% 22.44% Other Political Subdivision 2 1 1 0 0 0 0.45% 0.45%

State 17 4 4 0 0 0 0.00% 0.67% Total 562 98 87 3 2 6 0.00% 22.44% a. Facility counts exclude baseline closures. b.EPA was unable to determine revenues for 6 parent entities (8 weighted). Source: U.S. EPA analysis, 2011Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 10



### Table 5-4: Entity-Level Cost-to-Revenue Analysis Results, Using Entity-Level Weights
Number of Facilities with a Ratio of Entity Type Total Number of

Facilitiesa Total Number of

Entitiesb <1% 1-3% >3%UnknowncMinimum Ratio Maximum

Ratio Option 1: IM Everywhere 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% Other Political Subdivision 1 3 3 0 0 0 0.20% 0.20%

State 8 4 4 0 0 0 0.00% 0.29% Total 258 143 132 2 1 8 0.00% 22.74% Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD Cooperative 13 20 13 5 2 0 0.00% 9.63% Federal 7 1 0 0 1 0 3.83% 3.83% Investor-owned 138 43 36 6 1 0 0.00% 5.28% Municipality 13 35 24 8 3 0 0.00% 8.22% Nonutility 78 37 24 4 1 8 0.00% 229.17% Other Political Subdivision 1 3 0 0 3 0 3.03% 3.03%

State 8 4 3 0 1 0 0.00% 5.86% Total 258 143 101 23 12 8 0.00% 229.17% Option 3: I&E Mortality Everywhere Cooperative 13 20 9 9 2 0 0.00% 9.63% Federal 7 1 0 0 1 0 3.83% 3.83% Investor-owned 138 43 36 6 1 0 0.00% 5.28% Municipality 13 35 13 11 11 0 0.26% 8.22% Nonutility 78 37 24 4 1 8 0.00% 229.17% Other Political Subdivision 1 3 0 0 3 0 3.03% 3.03%

State 8 4 3 0 1 0 0.00% 5.86% Total 258 143 86 29 20 8 0.00% 229.17% Option 4: IM for Facilities with DIF>50MGD 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% 0.76% Nonutility 78 37 28 0 1 8 0.00% 10.04% Other Political Subdivision 1 3 3 0 0 0 0.20% 0.20%

State 8 4 4 0 0 0 0.00% 0.29% Total 258 143 132 2 1 8 0.00% 10.04% a. Facility counts exclude baseline closures. c. EPA was unable to determine revenue for 6 parent entities (8 weighted). b. There are a total of 143 parent entities on an unweighted basis, 3 of which are other political subdivision entities. These entities own only implicitly analyzed facilities; consequently, there is no explicitly analyzed other political subdivision parent entity to represent these implicitly analyzed parent entities and total weighted entity counts do not include 3 other political subdivision entities. Source: U.S. EPA analysis, 2011Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 11



### Impact of Compliance Costs on Household Electricity Costs Table 5-5: Average Annual Cost per Household in 2015 by NERC Region and Regulatory Option ($2009)a

NERC RegionbTotal Annual

Compliance Cost (at 2015; Million; $2009) Total

Electricity Sales (at 2015; MWh) Compliance

Cost per Unit of Sales ($2009/MWh)Residential

Electricity Sales (at 2015; MWh)Number of

Households (at 2015)Residential Sales

per Residential Consumer (MWh) Compliance

Cost per Household ($2009) Option 1: IM Everywhere ASCC $0 6,326,610 $0.00 2,114,456 265,449 7.97 $0.00 ECAR $60,951,195 569,849,487 $0.11 190,477,670 16,899,104 11.27 $1.21 ERCOT $40,192,064 313,395,966 $0.13 91,064,812 6,603,322 13.79 $1.77 FRCC $39,839,838 242,320,908 $0.16 110,173,004 7,923,249 13.91 $2.29 HICC $4,259,468 10,585,038 $0.40 3,200,675 407,140 7.86 $3.16 MAAC $61,918,789 294,365,234 $0.21 104,073,139 10,285,013 10.12 $2.13 MAIN $42,651,542 275,415,009 $0.15 86,988,500 8,939,201 9.73 $1.51 MAPP $29,804,875 165,189,056 $0.18 55,172,815 5,146,199 10.72 $1.93 NPCC $51,647,619 284,990,412 $0.18 95,584,731 12,557,410 7.61 $1.38 SERC $102,914,657 887,073,303 $0.12 332,332,257 22,705,585 14.64 $1.70 SPP $63,811,175 204,172,272 $0.31 68,368,566 5,439,270 12.57 $3.93 WECC $4,015,273 701,826,043 $0.01 240,757,548 26,073,156 9.23 $0.05 U.S. $502,006,4953,960,424,805 $0.13 1,380,308,173123,244,098 11.20 $1.42 Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD ASCC $0 6,326,610 $0.00 2,114,456 265,449 7.97 $0.00 ECAR $994,314,819 569,849,487 $1.74 190,477,67016,899,104 11.27 $19.67 ERCOT $607,506,688 313,395,966 $1.94 91,064,812 6,603,322 13.79 $26.73 FRCC $301,083,642242,320,908 $1.24 110,173,004 7,923,249 13.91 $17.28 HICC $32,085,172 10,585,038 $3.03 3,200,675 407,140 7.86 $23.83 MAAC $555,717,454294,365,234 $1.89 104,073,139 10,285,013 10.12 $19.10 MAIN $555,136,480275,415,009 $2.02 86,988,500 8,939,201 9.73 $19.61 MAPP $258,612,305 165,189,056 $1.57 55,172,815 5,146,199 10.72 $16.78 NPCC $744,738,535 284,990,412 $2.61 95,584,731 12,557,410 7.61 $19.89 SERC $1,688,899,692 887,073,303 $1.90 332,332,25722,705,585 14.64 $27.87 SPP $350,239,021 204,172,272 $1.72 68,368,566 5,439,270 12.57 $21.56 WECC $6,930,361 701,826,043 $0.01 240,757,54826,073,156 9.23 $0.09 U.S. $6,095,264,1683,960,424,805 $1.54 1,380,308,173123,244,098 11.20 $17.24 Option 3: I&E Mortality Everywhere ASCC $0 6,326,610 $0.00 2,114,456 265,449 7.97 $0.00 ECAR$1,018,436,899 569,849,487 $1.79 190,477,67016,899,104 11.27 $20.14 ERCOT $607,506,688 313,395,966 $1.94 91,064,812 6,603,322 13.79 $26.73 FRCC $307,648,969 242,320,908 $1.27 110,173,004 7,923,249 13.91 $17.65 HICC $32,085,172 10,585,038 $3.03 3,200,675 407,140 7.86 $23.83 MAAC $565,635,134294,365,234 $1.92 104,073,139 10,285,013 10.12 $19.44 MAIN $583,584,581 275,415,009 $2.12 86,988,500 8,939,201 9.73 $20.62 MAPP $274,653,131 165,189,056 $1.66 55,172,815 5,146,199 10.72 $17.83 NPCC $791,203,354284,990,412 $2.78 95,584,731 12,557,410 7.61 $21.13 SERC $1,735,362,189 887,073,303 $1.96 332,332,25722,705,585 14.64 $28.63 SPP $350,239,021 204,172,272 $1.72 68,368,566 5,439,270 12.57 $21.56 WECC $8,641,891 701,826,043 $0.01 240,757,54826,073,156 9.23 $0.11 U.S. $6,274,997,0283,960,424,805 $1.58 1,380,308,173123,244,098 11.20 $17.75 Option 4: IM for Facilities with DIF>50MGD ASCC $0 6,326,610 $0.00 2,114,456 265,449 7.97 $0.00 ECAR $60,212,067 569,849,487 $0.11 190,477,67016,899,104 11.27 $1.19 ERCOT $39,723,901 313,395,966 $0.13 91,064,812 6,603,322 13.79 $1.75 FRCC $39,839,838 242,320,908 $0.16 110,173,004 7,923,249 13.91 $2.29 HICC $4,259,468 10,585,038 $0.40 3,200,675 407,140 7.86 $3.16 MAAC $57,199,454294,365,234 $0.19 104,073,139 10,285,013 10.12 $1.97 MAIN $41,377,323 275,415,009 $0.15 86,988,500 8,939,201 9.73 $1.46 MAPP $28,983,847 165,189,056 $0.18 55,172,815 5,146,199 10.72 $1.88 NPCC $51,290,663 284,990,412 $0.18 95,584,731 12,557,410 7.61 $1.37 SERC $101,339,678 887,073,303 $0.11 332,332,25722,705,585 14.64 $1.67 SPP $62,721,433 204,172,272 $0.31 68,368,566 5,439,270 12.57 $3.86 WECC $913,556701,826,043 $0.00 240,757,54826,073,156 9.23 $0.01Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 12

U.S. $487,861,2283,960,424,805 $0.12 1,380,308,173123,244,098 11.20 $1.38 a. The rate impact analysis assumes full pass-through of all compliance costs to electricity consumers. b. No explicitly analyzed facilities are located in the ASCC region. For more information on explicitly and implicitly analyzed facilities see Appendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses Source: U.S. EPA analysis, 2011; U.S. DOE, 2009b; U.S. DOE, 2007cAbt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 13



### Impact of Compliance Costs on Electricity Prices Table 5-6: Compliance Cost per KWh of Sales by NERC Region and Regulatory Option in 2015 ($2009)a

NERC Regionb Annualized Pre-Tax Compliance Costs (at 2015; $2009; million) Total Electricity Sales (at 2015; KWh) Costs per Unit of Sales (2009¢/KWh Sales) Option 1: IM Everywhere ASCC $0 6,326,610,000 0.000 ECAR $60,951,195 569,849,487,305 0.011 ERCOT $40,192,064 313,395,965,576 0.013 FRCC $39,839,838 242,320,907,593 0.016 HICC $4,259,468 10,585,038,000 0.040 MAAC $61,918,789 294,365,234,375 0.021 MAIN $42,651,542 275,415,008,545 0.015 MAPP $29,804,875 165,189,056,396 0.018 NPCC $51,647,619 284,990,412,176 0.018 SERC $102,914,657 887,073,303,223 0.012 SPP $63,811,175 204,172,271,729 0.031 WECC $4,015,273 701,826,043,025 0.001 U.S.c $502,006,495 3,960,424,804,688 0.013 Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD ASCC $0 6,326,610,000 0.000 ECAR $994,314,819 569,849,487,305 0.174 ERCOT $607,506,688 313,395,965,576 0.194 FRCC $301,083,642 242,320,907,593 0.124 HICC $32,085,172 10,585,038,000 0.303 MAAC $555,717,454 294,365,234,375 0.189 MAIN $555,136,480 275,415,008,545 0.202 MAPP $258,612,305 165,189,056,396 0.157 NPCC $744,738,535 284,990,412,176 0.261 SERC $1,688,899,692 887,073,303,223 0.190 SPP $350,239,021 204,172,271,729 0.172 WECC $6,930,361 701,826,043,025 0.001 U.S. $6,095,264,168 3,960,424,804,688 0.154 Option 3: I&E Mortality Everywhere ASCC $0 6,326,610,000 0.000 ECAR $1,018,436,899 569,849,487,305 0.179 ERCOT $607,506,688 313,395,965,576 0.194 FRCC $307,648,969 242,320,907,593 0.127 HICC $32,085,172 10,585,038,000 0.303 MAAC $565,635,134 294,365,234,375 0.192 MAIN $583,584,581 275,415,008,545 0.212 MAPP $274,653,131 165,189,056,396 0.166 NPCC $791,203,354 284,990,412,176 0.278 SERC $1,735,362,189 887,073,303,223 0.196 SPP $350,239,021 204,172,271,729 0.172 WECC $8,641,891 701,826,043,025 0.001 U.S. $6,274,997,028 3,960,424,804,688 0.158 Option 4: IM for Facilities with DIF>50MGD ASCC $0 6,326,610,000 0.000 ECAR $60,212,067 569,849,487,305 0.011 ERCOT $39,723,901 313,395,965,576 0.013 FRCC $39,839,838 242,320,907,593 0.016 HICC $4,259,468 10,585,038,000 0.040 MAAC $57,199,454 294,365,234,375 0.019 MAIN $41,377,323 275,415,008,545 0.015 MAPP $28,983,847 165,189,056,396 0.018 NPCC $51,290,663 284,990,412,176 0.018 SERC $101,339,678 887,073,303,223 0.011 SPP $62,721,433 204,172,271,729 0.031 WECC $913,556 701,826,043,025 0.000 U.S. $487,861,228 3,960,424,804,688 0.012Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 14

a. The rate impact analysis assumes full pass-through of all compliance costs to electricity consumers. b. No explicitly analyzed facilities are located in the ASCC region. For more information on explicitly and implicitly analyzed facilities see Appendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses

. Source: U.S. EPA analysis, 2011; U.S. DOE 2009b; U.S. DOE 2007cAbt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 15



### Table 5-7: Projected 2015 Price (Cents per KWh of Sales) and Potential Price Increase Due to Compliance Costs by NERC Region and Regulatory Option ($2009)a Residential Commercial Industrial Transportation All Sector Average NERC RegionbCompliance

Cost (¢/KWh)Baseline

Price % ChangeBaseline

Price % ChangeBaseline

Price % ChangeBaseline

Price % ChangeBaseline

Price % Change Option 1: IM Everywhere ASCC 0.000 15.69 0.00% 12.59 0.00% 13.06 0.00% NA NA 13.73 0.00% ECAR 0.011 9.83 0.11% 8.97 0.12% 6.15 0.17% 7.90 0.14% 8.21 0.13% ERCOT 0.013 13.28 0.10% 9.37 0.14% 7.47 0.17% 10.59 0.12% 10.39 0.12% FRCC 0.016 13.38 0.12% 11.28 0.15% 9.16 0.18% 8.94 0.18% 12.19 0.13% HICC 0.040 24.93 0.16% 22.64 0.18% 18.99 0.21% NA NA 22.00 0.18% MAAC 0.021 13.09 0.16% 11.35 0.19% 8.14 0.26% 11.06 0.19% 11.32 0.19% MAIN 0.015 10.15 0.15% 8.24 0.19% 5.64 0.27% 7.52 0.21% 7.99 0.19% MAPP 0.018 8.02 0.23% 7.45 0.24% 5.68 0.32% 6.84 0.26% 7.04 0.26% NPCC 0.018 18.23 0.10% 14.42 0.13% 9.69 0.19% 15.84 0.11% 14.92 0.12% SERC 0.012 9.04 0.13% 7.67 0.15% 5.56 0.21% 5.97 0.19% 7.60 0.15% SPP 0.031 9.71 0.32% 8.25 0.38% 6.15 0.51% 7.56 0.41% 8.23 0.38% WECC 0.001 11.37 0.01% 9.63 0.01% 7.00 0.01% 8.87 0.01% 9.64 0.01% U.S. 0.013 11.200.11% 9.57 0.13% 6.46 0.20%10.640.12% 9.35 0.14% Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD ASCC 0.000 15.690.00% 12.590.00% 13.060.00% NA NA 13.730.00% ECAR 0.174 9.83 1.77% 8.97 1.95% 6.15 2.84% 7.90 2.21% 8.21 2.13% ERCOT 0.194 13.28 1.46% 9.37 2.07% 7.47 2.59% 10.59 1.83% 10.39 1.87% FRCC 0.124 13.380.93% 11.28 1.10% 9.16 1.36% 8.94 1.39% 12.19 1.02% HICC 0.303 24.93 1.22% 22.64 1.34% 18.99 1.60% NA NA 22.00 1.38% MAAC 0.189 13.09 1.44% 11.35 1.66% 8.14 2.32% 11.06 1.71% 11.32 1.67% MAIN 0.202 10.15 1.99% 8.24 2.45% 5.64 3.57% 7.52 2.68% 7.99 2.52% MAPP 0.157 8.02 1.95% 7.45 2.10% 5.68 2.76% 6.84 2.29% 7.04 2.22% NPCC 0.261 18.23 1.43% 14.42 1.81% 9.69 2.70% 15.84 1.65% 14.92 1.75% SERC 0.190 9.04 2.11% 7.67 2.48% 5.56 3.42% 5.97 3.19% 7.60 2.50% SPP 0.172 9.71 1.77% 8.25 2.08% 6.15 2.79% 7.56 2.27% 8.23 2.08% WECC 0.001 11.370.01% 9.63 0.01% 7.00 0.01% 8.87 0.01% 9.64 0.01% U.S. 0.154 11.201.37% 9.57 1.61% 6.46 2.38%10.641.45% 9.35 1.65% Option 3: I&E Mortality Everywhere ASCC 0.000 15.690.00% 12.590.00% 13.060.00% NA NA 13.730.00% ECAR 0.179 9.83 1.82% 8.97 1.99% 6.15 2.91% 7.90 2.26% 8.21 2.18% ERCOT 0.194 13.28 1.46% 9.37 2.07% 7.47 2.59% 10.59 1.83% 10.39 1.87% FRCC 0.127 13.380.95% 11.28 1.13% 9.16 1.39% 8.94 1.42% 12.19 1.04% HICC 0.303 24.93 1.22% 22.64 1.34% 18.99 1.60% NA NA 22.00 1.38% MAAC 0.192 13.09 1.47% 11.35 1.69% 8.14 2.36% 11.06 1.74% 11.32 1.70% MAIN 0.212 10.152.09% 8.24 2.57% 5.64 3.75% 7.52 2.82% 7.99 2.65% MAPP 0.166 8.02 2.07% 7.45 2.23% 5.68 2.93% 6.84 2.43% 7.04 2.36% NPCC 0.278 18.23 1.52% 14.42 1.92% 9.69 2.87% 15.84 1.75% 14.92 1.86% SERC 0.196 9.04 2.16% 7.67 2.55% 5.56 3.52% 5.97 3.28% 7.60 2.57% SPP 0.172 9.71 1.77% 8.25 2.08% 6.15 2.79% 7.56 2.27% 8.23 2.08% WECC 0.001 11.370.01% 9.63 0.01% 7.00 0.02% 8.87 0.01% 9.64 0.01% U.S. 0.158 11.201.41% 9.57 1.66% 6.46 2.45%10.641.49% 9.35 1.69% Option 4: IM for Facilities with DIF>50MGD ASCC 0.000 15.690.00% 12.590.00% 13.060.00% NA NA 13.730.00% ECAR 0.011 9.83 0.11% 8.97 0.12% 6.15 0.17% 7.90 0.13% 8.21 0.13% ERCOT 0.013 13.280.10% 9.37 0.14% 7.47 0.17% 10.590.12% 10.390.12% FRCC 0.016 13.380.12% 11.280.15% 9.16 0.18% 8.94 0.18% 12.190.13% HICC 0.040 24.930.16% 22.640.18% 18.990.21% NA NA 22.000.18% MAAC 0.019 13.090.15% 11.350.17% 8.14 0.24% 11.060.18% 11.320.17% MAIN 0.015 10.150.15% 8.24 0.18% 5.64 0.27% 7.52 0.20% 7.99 0.19% MAPP 0.018 8.02 0.22% 7.45 0.24% 5.68 0.31% 6.84 0.26% 7.04 0.25% NPCC 0.018 18.230.10% 14.420.12% 9.69 0.19% 15.840.11% 14.920.12% SERC 0.011 9.04 0.13% 7.67 0.15% 5.56 0.21% 5.97 0.19% 7.60 0.15% SPP 0.031 9.71 0.32% 8.25 0.37% 6.15 0.50% 7.56 0.41% 8.23 0.37% WECC 0.000 11.370.00% 9.63 0.00% 7.00 0.00% 8.87 0.00% 9.64 0.00% U.S. 0.012 11.200.11% 9.57 0.13% 6.46 0.19%10.640.12% 9.35 0.13%Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 16

a. The rate impact analysis assumes full pass-through of all compliance costs to electricity consumers. b. No explicitly analyzed facilities are located in the ASCC region. For more information on explicitly and implicitly analyzed facilities see Appendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses

. Source: U.S. EPA analysis, 2011; U.S. DOE, 2009b; U.S. DOE, 2007c



## Chapter 7: Assessing the Potential Impact of the Proposed Existing Facilities Rule on Small Entities – Regulatory Flexibility Act (RFA) Analysis – Electric Generators

Table 7-6: Unique Parent Entities and Facilities for Electric Generators (by Entity Type and Size)
Number of Parent Entitiesa,b Number of Facilities Parent Entity Type Small Entity Size Standard Large Small Total Large Small Total Parent Entities Owning at Least One Explicitly Analyzed Facility Rural Electric Cooperative4,000 MWh output 9 2 11 11 2 13 Federal assumed large 1 0 1 7 0 7 Investor-Owned Utilities 4,000 MWh output 38 1 39 137 1 138 Municipality 50,000 population served 7 6 13 7 6 13 Nonutility 4,000 MWh output 26 3 29 73 5 82 Other Political Subdivision 50,000 population served 1 0 1 1 0 1

State assumed large 4 0 4 8 0 8 Total 86 12 98 244 14 262 Parent Entities Owning Only Implicitly Analyzed Facilities or Owning at Least One Explicitly Analyzed Facilityc,d Rural Electric Cooperative4,000 MWh output 12 8 20 23 8 31 Federal assumed large 1 0 1 14 0 14 Investor-Owned Utilities4,000 MWh output 41 2 43 282 3 285 Municipality 50,000 population served 18 17 35 26 17 43 Nonutility 4,000 MWh output 32 5 37 153 8 161 Other Political Subdivision 50,000 population served 2 1 3 7 1 8

State assumed large 4 0 4 9 0 9 Total 110 33 143 514 37 551 a. For 8 entities, EPA was unable to find entity revenue necessary to determine the size of these entities; consequently, EPA used the total revenue for all facilities owned by these entities to determine entity size. b. In three instances, a facility is owned by a joint venture of two entities. c. 548 facilities include (1) explicitly analyzed facilities and (2) implicitly analyzed facilities that responded to the 316(b) 2000 Surveys. For a discussion of explicitly and implicitly analyzed facilities refer toAppendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses

. d. These counts are unweighted and reflect the known universe of facilities and their parent entities expected to be in scope of Proposed Existing Facilities Rule. Source: U.S. EPA analysis, 2011Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 17



### Table 7-7: Number of Small Electric Generators Parent Entities (Industry Total and Entities with In-Scope Facilities) Small Entities Owning In-Scope Facilities

Parent Entity Type Total Small Entitiesa Numberb Percentage of Total Small Entities Rural Electric Cooperative 848 8 0.94% Federal 0 0 0.00% Investor-Owned Utilities 18 2 10.87% Municipality 968 17 1.76% Nonutility 131 5 3.81% Other Political Subdivision 113 1 0.88% State 0 0 0.00% All Entity Types 2,078 33 1.59% a. Form EIA-861 does not provide data on nonutilities. The reported number oftotalsmall nonutilities is the total of non-regulated operators from the 2007 EIA-860 database; the number of small parent entities owning 316(b) facilities for non-regulated operators was determined using the 2007 EIA-906/920/923 database. State and federal entities are considered large. b. Entity counts include entities owning explicitly and implicitly analyzed facilities and are not weighted estimates. For a discussion on explicitly and implicitly owned facilities seeAppendix 3.A: Use of Sample Weights in the Proposed Existing Facilities Rule Analyses

. c. Industry non-regulated operators with no electricity sales/generation data were excluded from this analysis. Source: U.S. EPA analysis, 2011; U.S. DOE, 2007b; U.S. DOE, 2007c; U.S. DOE, 2007d



### Table 7-8: Estimated Cost-to-Revenue Impact on Small Electric Generators Entities, by Entity Type – Using Facility-Level Weightsa Cost Impact Category Cost > 1% of Revenue Cost > 3% of Revenue

Parent Entity Typeb Number of Small Entities % of All

Small Entities Number of

Small Entities % of All

Small Entities Option 1: IM Everywhere Rural Electric Cooperative 1 12.5% 1 12.5% Investor-Owner Utility 0 0.0% 0 0.0% Municipality 2 11.8% 0 0.0% Nonutility 1 20.0% 1 20.0% Other Political Subdivision 0 0.0% 0 0.0% Total 4 12.1% 2 6.1% Option 2: IM Everywhere and EM for Facilities with DIF>125 MGD Rural Electric Cooperative 1 12.5% 1 12.5% Investor-Owner Utility 0 0.0% 0 0.0% Municipality 2 11.8% 0 0.0% Nonutility 1 20.0% 1 20.0% Other Political Subdivision 0 0.0% 0 0.0% Total 4 12.1% 2 6.1% Option 3: I&E Mortality Everywhere Rural Electric Cooperative 2 25.0% 1 12.5% Investor-Owner Utility 0 0.0% 0 0.0% Municipality 6 35.3% 4 23.5% Nonutility 1 20.0% 1 20.0% Other Political Subdivision 0 0.0% 0 0.0% Total 9 27.3% 6 18.2% Option 4: IM for Facilities with DIF>50MGD Rural Electric Cooperative 1 12.5% 1 12.5% Investor-Owner Utility 0 0.0% 0 0.0% Municipality 2 11.8% 0 0.0% Nonutility 1 20.0% 1 20.0% Other Political Subdivision 0 0.0% 0 0.0% Total 4 12.1% 2 6.1% a. The number of entities with cost-to-revenue impact exceeding 3 percent is a subset of the number of entities with such ratios exceeding 1 percent. Source: U.S. EPA analysis, 2011Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 18 

### Table 7-9: Estimated Cost-to-Revenue Impact on Small Electric Generators Entities, by Entity Type – Using Entity-Level Weightsa Cost Impact Category Cost > 1% of Revenue Cost > 3% of Revenue

Parent Entity Typeb Number of Small Entities % of All

Small Entities Number of

Small Entities % of All

Small Entities Option 1: IM Everywhere Rural Electric Cooperative 4 50.0% 0 0.0% Investor-Owner Utility 0 0.0% 0 0.0% Municipality 0 0.0% 0 0.0% Nonutility 2 40.0% 2 40.0% Other Political Subdivision 0 0.0% 0 0.0% Total 6 18.2% 2 6.1% Option 2: IM Everywhere and EM for Facilities with DIF>125 MGD Rural Electric Cooperative 4 50.0% 4 50.0% Investor-Owner Utility 0 0.0% 0 0.0% Municipality 0 0.0% 0 0.0% Nonutility 2 40.0% 2 40.0% Other Political Subdivision 0 0.0% 0 0.0% Total 6 18.2% 6 18.2% Option 3: I&E Mortality Everywhere Rural Electric Cooperative 8 100.0% 4 50.0% Investor-Owner Utility 0 0.0% 0 0.0% Municipality 11 64.7% 9 52.9% Nonutility 2 40.0% 2 40.0% Other Political Subdivision 0 0.0% 0 0.0% Total 21 63.6% 14 42.4% Option 4: IM for Facilities with DIF>50MGD Rural Electric Cooperative 4 50.0% 0 0.0% Investor-Owner Utility 0 0.0% 0 0.0% Municipality 0 0.0% 0 0.0% Nonutility 2 40.0% 2 40.0% Other Political Subdivision 0 0.0% 0 0.0% Total 6 18.2% 2 6.1% a. The number of entities with cost-to-revenue impact exceeding 3 percent is a subset of the number of entities with such ratios exceeding 1 percent. Source: U.S. EPA analysis, 2011Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 19 

### Table 7-10: Estimated Cost-to-Revenue Impact on Small Entities – Comparing Findings from the Facility-Level Weights and Entity-Level Weights Analysesa Cost Impact Category Cost > 1% of Revenue Cost > 3% of Revenue

Parent Entity Type Number of Small Entities % of All

Small Entities Number of

Small Entities % of All

Small Entities Using Facility-Level Weights Option 1: IM Everywhere 4 12.1% 2 6.1% Option 2: IM Everywhere and EM for Facilities with DIF>125 MGD 4 12.1% 2 6.1% Option 3: I&E Mortality Everywhere 9 27.3% 6 18.2% Option 4: IM for Facilities with DIF>50MGD 4 12.1% 2 6.1% Using Entity-Level Weights Option 1: IM Everywhere 6 18.2% 2 6.1% Option 2: IM Everywhere and EM for Facilities with DIF>125 MGD 6 18.2% 6 18.2% Option 3: I&E Mortality Everywhere 21 63.6% 14 42.4% Option 4: IM for Facilities with DIF>50MGD 6 18.2% 2 6.1%
a. The number of entities with cost-to-revenue impact exceeding 3 percent is a subset of the number of entities with such ratios exceeding 1 percent. Source: U.S. EPA analysis, 2011 

## Chapter 8: Unfunded Mandates Reform Act (UMRA)

Table 8-1: Government-Owned Electric Generators and Their Parent Entities Entity Type Parent Entitiesa Electric Generatorsb Municipality 35 43 State 4 9 Other Political Subdivision 3 8 Total 42 60

a.Counts of entities owning explicitly and implicitly analyzed Electric Generators; these are not weighted entity

counts. b. Counts of explicitly and implicitly analyzed Electric Generators; these are not weighted estimates. Source: U.S. EPA analysis, 2011Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 20



### Table 8-2: Compliance Costs to Government-Owned Electric Generators (Millions; $2009)

Ownership Type Number of In-scope Facilities (weighted)

a Total Weighted,

Annualized Pretax Compliance Cost Average Annual

Compliance Cost (per facility) Maximum

Annualized Facility Compliance Costb Option 1: IM Everywhere Municipality 25 $4.6 $0.2 $0.5 State 17 $6.1 $0.4 $1.0 Other Political Subdivision 2 $3.2 $1.5 $1.4

Total 44 $13.9 $0.3 $1.4 Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD Municipality 25 $29.6 $1.2 $5.6 State 17 $72.8 $4.3 $17.9 Other Political Subdivision 2 $21.7 $10.0 $9.3

Total 44 $124.1 $2.8 $17.9 Option 3: I&E Mortality Everywhere Municipality 25 $42.2 $1.7 $5.6 State 17 $78.0 $4.6 $17.9 Other Political Subdivision 2 $21.7 $10.0 $9.3

Total 44 $141.9 $3.3 $17.9 Option 4: IM for Facilities with DIF>50MGD Municipality 25 $3.8 $0.2 $0.5 State 17 $5.7 $0.3 $1.0 Other Political Subdivision 2 $3.2 $1.5 $1.4

Total 44 $12.7 $0.3 $1.4 a. Facility counts are weighted estimates and differ from the values reported inTable 8-1andTable 8-4, which are un-weighted values. This table presents sample weighted facility counts because costs were developed only for the explicitly analyzed Electric Generators facilities. See AppendixA.3: Used of Sample Weights in the Proposed Existing Facilities Rule Analysisfor discussion on explicitly and implicitly analyzed facilities and facility sample weights. b. Reflects maximum of un-weighted costs to explicitly analyzed facilities only. Source: U.S. EPA analysis, 2011Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 21 

### Table 8-3: Annualized Government Administrative Costs (Millions; $2009)

Activity Annualized Cost, Electric Generators Annualized Cost, Manufacturers Total Annualized Cost Option 1: IM Everywhere Start-Up Activities $0.02 $0.02 $0.04 First Permit Issuance Activities $0.23 $0.24 $0.47 Annual Monitoring Activities $1.18 $1.12 $2.30 Entrainment Study $1.20 $0.97 $2.17 Permit Reissuance Activities $0.18 $0.18 $0.36 Total $2.82 $2.52 $5.34 Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD Start-Up Activities $0.02 $0.02 $0.04 First Permit Issuance Activities $0.17 $0.23 $0.40 Annual Monitoring Activities $0.36 $1.07 $1.43 Entrainment Study $0.00 $0.00 $0.00 Permit Reissuance Activities $0.14 $0.17 $0.31 Total $0.69 $1.48 $2.17 Option 3: IM&EM Everywhere Start-Up Activities $0.02 $0.02 $0.04 First Permit Issuance Activities $0.16 $0.13 $0.29 Annual Monitoring Activities $0.20 $0.52 $0.72 Entrainment Study $0.00 $0.00 $0.00 Permit Reissuance Activities $0.13 $0.10 $0.23 Total $0.51 $0.77 $1.28 Option 4: IM for Facilities with DIF>50MGD Start-Up Activities $0.02 $0.02 $0.04 First Permit Issuance Activities $0.23 $0.06 $0.29 Annual Monitoring Activities $1.05 $0.31 $1.36 Entrainment Study $1.20 $0.97 $2.17 Permit Reissuance Activities $0.18 $0.05 $0.23 Total $2.68 $1.41 $4.09 a. These costs reflect the assumption that all facilities will comply in one year, and were discounted accordingly because individual components of costs were not distributed over the 5-year compliance window, as described inChapter 11, Section 1. Source: U.S. EPA analysis, 2011



### Table 8-4: Government-Owned Electric Generators and Their Parent Entities, by Size Entitiesa Electric Generatorsb Entity Type Large Small Total Large Small Total Municipality 18 17 35 26 17 43 State 4 0 4 9 0 9 Other Political Subdivision 2 1 3 7 1 7 Total 24 18 42 42 18 60 a. Counts of entities owning explicitly and implicitly analyzed Electric Generators; these are not weighted entity counts. b. Counts of explicitly and implicitly analyzed Electric Generators; these are not weighted estimates. Source: U.S. EPA analysis, 2011Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 22



### Table 8-5: Compliance Costs for Electric Generators by Ownership Type and Size (Millions; $2009)

Ownership Type Entity

Size Number of

Facilities (weighted)aTotal Annualized PreTax Compliance CostsAverage Annualized Pre-tax Compliance Cost per Facility Maximum Facility

Annualized Pre-tax Compliance Costc Option 1: IM Everywhere

Small 10 $1.5 $0.1 $0.2 Government (excluding Federal) Large 33 $12.4 $0.4 $1.4

Small 16 $7.5 $0.5 $2.6 Private Large 486 $354.6 $0.7 $7.4 All Facilitiesb 562 $398.2 $0.7 $7.4 Option 2: IM Everywhere and EM for Facilities with DIF>125 MGD

Small 10 $1.5 $0.1 $0.2 Government (excluding Federal) Large 33 $122.6 $3.7 $17.9

Small 16 $30.5 $1.9 $10.7 Private Large 486 $4,177.2 $8.6 $58.1 All Facilitiesb 562 $4,851.4 $8.6 $58.1 Option 3: I&E Mortality Everywhere

Small 10 $12.5 $1.2 $2.1 Government (excluding Federal) Large 33 $129.4 $3.9 $17.9

Small 16 $32.2 $2.1 $10.7 Private Large 486 $4,306.6 $8.9 $58.1 All Facilitiesb 562 $5,000.2 $8.9 $58.1 Option 4: IM for Facilities with DIF>50MGD

Small 10 $1.4 $0.1 $0.2 Government (excluding Federal) Large 33 $11.2 $0.3 $1.4

Small 16 $5.8 $0.4 $2.6 Private Large 486 $346.3 $0.7 $7.4 All Facilitiesb 562 $387.0 $0.7 $7.4 a. Facility counts are weighted estimates and differ from the values reported inTable 8-1andTable 8-4, which are un-weighted values. This table presents sample weighted facility counts because costs were developed only for the explicitly analyzed Electric Generators facilities. See AppendixA.3: Used of Sample Weights in the Proposed Existing Facilities Rule Analysisfor discussion on explicitly and implicitly analyzed facilities and facility sample weights. b. Facility counts and cost estimates reported for All Facilities include 17 federal government-owned facilities and costs estimated for these facilities. c. Reflects maximum of un-weighted costs to explicitly analyzed facilities only. Source: U.S. EPA analysis, 2011Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 23



### Table 8-6: Summary of UMRA Costs (Millions; $2009)

Total Annualized Cost Maximum One-Year Cost

Sector Incurring Costs Facility

Compliance Costsa Government

Administrative Costsb Total Facility Compliance Costs Government

Administrative Costs Total Option 1: IM Everywhere Electric Generators Government (excluding Federal) $13.9 $2.5 $16.5 $25.2 $4.1 $29.3 Private $362.1 N/A $362.1 $755.8 N/A $755.8 Manufacturers Government (excluding Federal) $0.0 $1.2 $1.2 $0.0 $1.6 $1.6
Private $65.3 N/A $65.3 $371.3 N/A $371.3 Option 2: IM Everywhere and EM for Facilities with DIF>125 MGD Electric Generators Government (excluding Federal) $124.1 $0.6 $124.7 $334.8 $0.8 $335.6 Private $4,207.7 N/A $4,207.7 $10,736.3 N/A $10,736.3 Manufacturers Government (excluding Federal) $0.0 $1.1 $1.1 $0.0 $1.4 $1.4
Private $139.3 N/A $139.3 $832.5 N/A $832.5 Option 3: I&E Mortality Everywhere Electric Generators Government (excluding Federal) $141.9 $0.4 $142.4 $388.9 $0.7 $389.6 Private $4,338.7 N/A $4,338.7 $11,113.4 N/A $11,113.4 Manufacturers Government (excluding Federal) $0.0 $0.4 $0.4 $0.0 $1.0 $1.0 Private $164.8 N/A $164.8 $1,438.8 N/A $1,438.8 Option 4: IM for Facilities with DIF>50MGD Electric Generators Government (excluding Federal) $12.7 $2.4 $15.1 $23.9 $4.0 $27.8
Private $352.2 N/A $352.2 $734.0 N/A $734.0 Manufacturers Government (excluding Federal) $0.00 $0.8 $0.8 $0.0 $2.5 $2.5 Private $34.8 N/A $34.8 $239.7 N/A $239.7 a. Cost values for Electric Generators are lower than those presented inTable 8-5because they reflect a distribution over the compliance window, as described in Chapter 11: Assessment of Total Social Costs, thus changing the amount discounted in each year. b. These values are slightly lower than those presented inTable 8-3because they reflect a distribution over the compliance window, as described in Chapter 11: Assessment of Total Social Costs, thus changing the amount discounted in each year. Source: U.S. EPA analysis, 2011



## Chapter 11: Assessment of Total Social Costs

Table 11-1: Summary of Annualized Costs of Compliance (Millions; $2009)

Discount Rate Option 1: IM EverywhereOption 2: IM Everywhere and EM forFacilities with DIF > 125 MGD Option 3: I&E Mortality Everywhere Option 4:IM for Facilities with DIF>50MGD 3% $365.56 $4,491.89 $4,659.23 $330.80 7% $428.42 $4,726.87 $4,886.61 $389.66 Source: U.S. EPA analysis, 2011.Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 24



### Table 11-2: Summary of Annualized Government Administrative Costs (Millions; $2009)

Discount Rate Government

Level Option 1: IM

Everywhere Option 2: IM

Everywhere and EM for Facilities with DIF > 125 MGD Option 3: I&E Mortality Everywhere Option 4: IM for Facilities with DIF>50MGD State/Territory $3.70 $1.59 $0.89 $2.79 Federal $0.03 $0.03 $0.03 $0.02 3% Totala $3.73 $1.62 $0.92 $2.79 State/Territory $4.20 $1.68 $0.87 $3.24 Federal $0.06 $0.05 $0.04 $0.04 7% Totala $4.26 $1.73 $0.91 $3.26 a. Values may not sum to the reported total to due independent rounding. Source: U.S. EPA Analysis, 2011.



### Table 11-3: Summary of Total Social Costs (Millions; $2009)

Discount Rate Cost Category Option 1: IM Everywhere Option 2: IM

Everywhere and EM for Facilities with DIF > 125

MGD Option 3: I&E

Mortality Everywhere Option 4: IM for Facilities with DIF>50MGD Compliance Cost $365. 56 $4,491.89 $4,659.23 $330.80 Gov. Admin. $3.73 $1.62 $0.92 $2.81 3% Totala $369.29 $4,493.51 $4,660.14 $333.61 Compliance Cost $428.42 $4,726.87 $4,886.61 $389.66 Gov. Admin. $4.26 $1.73 $0.91 $3.28 7% Totala $432.67 $4,728.60 $4,887.52 $392.94 a. Values may not sum to the reported total to due independent rounding. Source: U.S. EPA Analysis, 2011.Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 25 

### Table 11-4: Time Profile of Costs to Society for Option 1: IM Everywhere (Millions; $2009)

Year Compliance CostsAdministrative Costs Total 2012 $7.51 $0.48 $7.99 2013 $704.24 $4.54 $708.78 2014 $763.27 $7.13 $770.40 2015 $811.42 $7.63 $819.05 2016 $681.21 $5.35 $686.56 2017 $703.08 $3.66 $706.74 2018 $374.22 $5.34 $379.56 2019 $216.12 $4.76 $220.88 2020 $203.69 $2.63 $206.32 2021 $374.22 $5.34 $379.56 2022 $216.12 $2.63 $218.75 2023 $203.69 $2.63 $206.32 2024 $374.22 $5.34 $379.56 2025 $216.12 $2.63 $218.75 2026 $203.69 $2.63 $206.32 2027 $374.22 $5.34 $379.56 2028 $216.12 $2.63 $218.75 2029 $203.69 $2.63 $206.32 2030 $374.22 $5.34 $379.56 2031 $216.12 $2.63 $218.75 2032 $203.69 $2.63 $206.32 2033 $690.72 $5.34 $696.06 2034 $532.61 $2.63 $535.24 2035 $520.19 $2.63 $522.82 2036 $690.72 $5.34 $696.06 2037 $532.61 $2.63 $535.24 2038 $268.76 $2.63 $271.39 2039 $439.29 $5.34 $444.63 2040 $281.18 $2.63 $283.81 2041 $268.76 $2.63 $271.39 2042 $439.29 $5.34 $444.63 2043 $220.61 $2.63 $223.23 2044 $208.18 $2.63 $210.81 2045 $378.71 $5.34 $384.05 2046 $220.61 $2.63 $223.23 2047 $208.18 $2.63 $210.81 2048 $374.22 $5.34 $379.56 2049 $216.12 $2.63 $218.75 2050 $203.69 $2.63 $206.32 2051 $374.22 $5.34 $379.56 2052 $214.49 $2.63 $217.12 2053 $160.24 $1.73 $161.97 2054 $177.02 $2.20 $179.23 2055 $80.12 $0.87 $80.99 2056 $40.06 $0.43 $40.49 2057 $0.00 $0.00 $0.00 2058 $0.00 $0.00 $0.00 2059 $0.00 $0.00 $0.00 2060 $0.00 $0.00 $0.00 2061 $0.00 $0.00 $0.00 2062 $0.00 $0.00 $0.00 Present Value, 3% $9,405.79 $95.97 $9,501.76 Annualized, 3% $365.56 $3.73 $369.29 Present Value, 7% $5,912.48 $58.73 $5,971.21 Annualized, 7% $428.42 $4.26 $432.67 Source: U.S. EPA analysis, 2011.Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 26 

### Table 11-5: Time Profile of Costs to Society for Option 2: IM Everywhere and EM for Facilities with DIF > 125 MGD (Millions; $2009)

Year Compliance CostsAdministrative Costs Total 2012 $4.55 $0.48 $5.03 2013 $79.20 $1.12 $80.32 2014 $89.51 $1.36 $90.87 2015 $100.05 $1.62 $101.67 2016 $109.69 $1.86 $111.55 2017 $4,641.02 $2.10 $4,643.12 2018 $9,919.51 $1.90 $9,921.41 2019 $10,390.33 $1.91 $10,392.24 2020 $10,863.61 $1.91 $10,865.52 2021 $11,325.03 $1.92 $11,326.94 2022 $9,006.20 $1.92 $9,008.12 2023 $6,271.58 $1.77 $6,273.35 2024 $6,588.28 $1.79 $6,590.07 2025 $6,921.82 $1.80 $6,923.62 2026 $7,254.60 $1.82 $7,256.41 2027 $5,855.96 $1.83 $5,857.79 2028 $4,025.95 $1.75 $4,027.69 2029 $4,052.98 $1.75 $4,054.72 2030 $4,083.69 $1.75 $4,085.44 2031 $4,083.69 $1.75 $4,085.44 2032 $4,083.69 $1.75 $4,085.44 2033 $4,117.74 $1.75 $4,119.49 2034 $4,117.74 $1.75 $4,119.49 2035 $4,117.74 $1.75 $4,119.49 2036 $4,117.74 $1.75 $4,119.49 2037 $4,117.74 $1.75 $4,119.49 2038 $4,096.70 $1.75 $4,098.44 2039 $4,096.70 $1.75 $4,098.44 2040 $4,096.70 $1.75 $4,098.44 2041 $4,096.70 $1.75 $4,098.44 2042 $4,096.70 $1.75 $4,098.44 2043 $4,095.50 $1.75 $4,097.25 2044 $4,095.50 $1.75 $4,097.25 2045 $4,095.50 $1.75 $4,097.25 2046 $4,095.50 $1.75 $4,097.25 2047 $4,095.50 $1.75 $4,097.25 2048 $4,084.05 $1.75 $4,085.80 2049 $4,084.05 $1.75 $4,085.80 2050 $4,084.05 $1.75 $4,085.80 2051 $4,084.05 $1.75 $4,085.80 2052 $4,082.43 $1.75 $4,084.17 2053 $3,264.24 $1.04 $3,265.28 2054 $2,448.18 $0.78 $2,448.96 2055 $1,632.12 $0.52 $1,632.64 2056 $816.06 $0.26 $816.32 2057 $0.00 $0.00 $0.00 2058 $0.00 $0.00 $0.00 2059 $0.00 $0.00 $0.00 2060 $0.00 $0.00 $0.00 2061 $0.00 $0.00 $0.00 2062 $0.00 $0.00 $0.00 Present Value, 3% $115,575.27 $41.74 $115,617.01 Annualized, 3% $4,491.89 $1.62 $4,493.51 Present Value, 7% $65,234.38 $23.81 $65,258.19 Annualized, 7% $4,726.87 $1.73 $4,728.60 Source: U.S. EPA analysis, 2011.Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 27 

### Table 11-6: Time Profile of Costs to Society for Option 3: I&E Mortality Everywhere (Millions; $2009) Year Compliance Costs Administrative Costs Total 2012 $1.31 $0.48 $1.79 2013 $24.92 $0.31 $25.23 2014 $27.62 $0.38 $27.99 2015 $30.39 $0.44 $30.84 2016 $32.92 $0.50 $33.42 2017 $4,674.24 $0.56 $4,674.80 2018 $10,172.29 $0.91 $10,173.20 2019 $10,672.51 $0.92 $10,673.43 2020 $11,175.32 $0.92 $11,176.25 2021 $11,665.38 $0.93 $11,666.31 2022 $9,369.53 $0.93 $9,370.47 2023 $6,615.72 $1.24 $6,616.96 2024 $6,946.90 $1.31 $6,948.21 2025 $7,295.40 $1.38 $7,296.78 2026 $7,642.72 $1.45 $7,644.18 2027 $6,151.12 $1.52 $6,152.64 2028 $4,208.79 $1.11 $4,209.90 2029 $4,237.03 $1.11 $4,238.14 2030 $4,269.12 $1.11 $4,270.22 2031 $4,269.12 $1.11 $4,270.22 2032 $4,269.12 $1.11 $4,270.22 2033 $4,278.38 $1.11 $4,279.49 2034 $4,278.38 $1.11 $4,279.49 2035 $4,278.38 $1.11 $4,279.49 2036 $4,278.38 $1.11 $4,279.49 2037 $4,278.38 $1.11 $4,279.49 2038 $4,275.67 $1.11 $4,276.78 2039 $4,275.67 $1.11 $4,276.78 2040 $4,275.67 $1.11 $4,276.78 2041 $4,275.67 $1.11 $4,276.78 2042 $4,275.67 $1.11 $4,276.78 2043 $4,282.97 $1.11 $4,284.08 2044 $4,282.97 $1.11 $4,284.08 2045 $4,282.97 $1.11 $4,284.08 2046 $4,282.97 $1.11 $4,284.08 2047 $4,282.97 $1.11 $4,284.08 2048 $4,269.48 $1.11 $4,270.59 2049 $4,269.48 $1.11 $4,270.59 2050 $4,269.48 $1.11 $4,270.59 2051 $4,269.48 $1.11 $4,270.59 2052 $4,267.85 $1.11 $4,268.96 2053 $3,412.58 $0.55 $3,413.13 2054 $2,559.43 $0.41 $2,559.84 2055 $1,706.29 $0.27 $1,706.56 2056 $853.14 $0.14 $853.28 2057 $0.00 $0.00 $0.00 2058 $0.00 $0.00 $0.00 2059 $0.00 $0.00 $0.00 2060 $0.00 $0.00 $0.00 2061 $0.00 $0.00 $0.00 2062 $0.00 $0.00 $0.00 Present Value, 3% $119,880.81 $23.60 $119,904.41 Annualized, 3% $4,659.23 $0.92 $4,660.14 Present Value, 7% $67,438.81 $12.56 $67,451.37 Annualized, 7% $4,886.61 $0.91 $4,887.52 Source: U.S. EPA analysis, 2011.Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 28 

### Table 11-4: Time Profile of Costs to Society for Option 4: IM for Facilities with DIF>50MGD (Millions; $2009)

Year Compliance CostsAdministrative Costs Total 2012 $4.88 $0.48 $5.35 2013 $661.00 $3.86 $664.86 2014 $713.76 $6.27 $720.03 2015 $755.47 $6.60 $762.08 2016 $619.30 $4.15 $623.45 2017 $636.72 $2.29 $639.00 2018 $343.27 $4.34 $347.61 2019 $185.17 $3.75 $188.92 2020 $172.74 $1.62 $174.37 2021 $343.27 $4.34 $347.61 2022 $185.17 $1.62 $186.79 2023 $172.74 $1.62 $174.37 2024 $343.27 $4.34 $347.61 2025 $185.17 $1.62 $186.79 2026 $172.74 $1.62 $174.37 2027 $343.27 $4.34 $347.61 2028 $185.17 $1.62 $186.79 2029 $172.74 $1.62 $174.37 2030 $343.27 $4.34 $347.61 2031 $185.17 $1.62 $186.79 2032 $172.74 $1.62 $174.37 2033 $646.06 $4.34 $650.40 2034 $487.96 $1.62 $489.58 2035 $475.53 $1.62 $477.16 2036 $646.06 $4.34 $650.40 2037 $487.96 $1.62 $489.58 2038 $233.01 $1.62 $234.64 2039 $403.54 $4.34 $407.88 2040 $245.44 $1.62 $247.06 2041 $233.01 $1.62 $234.64 2042 $403.54 $4.34 $407.88 2043 $187.64 $1.62 $189.26 2044 $175.22 $1.62 $176.84 2045 $345.74 $4.34 $350.08 2046 $187.64 $1.62 $189.26 2047 $175.22 $1.62 $176.84 2048 $343.27 $4.34 $347.61 2049 $185.17 $1.62 $186.79 2050 $172.74 $1.62 $174.37 2051 $343.27 $4.34 $347.61 2052 $184.73 $1.62 $186.35 2053 $136.43 $1.06 $137.49 2054 $159.17 $1.70 $160.87 2055 $68.22 $0.53 $68.75 2056 $34.11 $0.27 $34.37 2057 $0.00 $0.00 $0.00 2058 $0.00 $0.00 $0.00 2059 $0.00 $0.00 $0.00 2060 $0.00 $0.00 $0.00 2061 $0.00 $0.00 $0.00 2062 $0.00 $0.00 $0.00 Present Value, 3% $8,511.51 $72.23 $8,583.74 Annualized, 3% $330.80 $2.81 $333.61 Present Value, 7% $5,377.63 $45.25 $5,422.89 Annualized, 7% $389.66 $3.28 $392.94 Source: U.S. EPA analysis, 2011.Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 29 

### Table 11-7: Annualized Costs of Compliance for New Generating Units (Millions; $2009)

Discount Rate Annualized Costs 3% $20.69 7% $15.45 Source: U.S. EPA analysis, 2011. 

## Chapter 12: Social Costs and Benefits of the Proposed Rule

Table 12-2: Total Benefits and Social Costs by Option (Millions; $2009)

Total Monetized Benefitsa Total Social Costsb Option 3% 7% 3% 7% Option 1 $17.63 $16.04 $369.29 $432.67 Option 2 $120.79 $92.20 $4,493.51 $4,728.60 Option 3 $125.65 $95.71 $4,660.14 $4,887.52 Option 4 $17.33 $15.76 $333.61 $392.94 a. The benefit values presented in this table are the estimated “mean” values. Additional “low” and “high” value estimates are presented in Chapter 11 of the EEBA. b. Total Social Costs include compliance costs to facilities and government administrative costs. Source: U.S. EPA analysis, 2011.



### Table 12-3: Time Profile of Benefits and Social Costs (Millions; $2009) Option 1 Option 2 Option 3 Option 4

Year Monetized

BenefitsTotal Social

Costs Monetized

BenefitsTotal Social

Costs Monetized

BenefitsTotal Social

Costs Monetized

BenefitsTotal Social

Costs 2012 $0.00 $7.99 $0.00 $5.03 $0.00 $1.79 $0.00 $5.35 2013 $0.48 $708.78 $0.03 $80.32 $0.01 $25.23 $0.48 $664.86 2014 $1.39 $770.40 $0.09 $90.87 $0.02 $27.99 $1.37 $720.03 2015 $4.55 $819.05 $0.29 $101.67 $0.08 $30.84 $4.47 $762.08 2016 $8.40 $686.56 $0.52 $111.55 $0.14 $33.42 $8.25 $623.45 2017 $12.48 $706.74 $0.76 $4,643.12 $0.21 $4,674.80 $12.26 $639.00 2018 $16.29 $379.56 $17.25 $9,921.41 $17.21 $10,173.20 $16.00 $347.61 2019 $19.70 $220.88 $34.67 $10,392.24 $35.19 $10,673.43 $19.35 $188.92 2020 $20.86 $206.32 $56.26 $10,865.52 $57.56 $11,176.25 $20.49 $174.37 2021 $21.33 $379.56 $80.22 $11,326.94 $82.40 $11,666.31 $20.96 $347.61 2022 $21.57 $218.75 $104.80 $9,008.12 $107.88 $9,370.47 $21.19 $186.79 2023 $21.59 $206.32 $119.08 $6,273.35 $122.82 $6,616.96 $21.22 $174.37 2024 $21.59 $379.56 $133.20 $6,590.07 $137.63 $6,948.21 $21.22 $347.61 2025 $21.59 $218.75 $144.72 $6,923.62 $149.94 $7,296.78 $21.22 $186.79 2026 $21.59 $206.32 $156.68 $7,256.41 $162.72 $7,644.18 $21.22 $174.37 2027 $21.59 $379.56 $168.55 $5,857.79 $175.43 $6,152.64 $21.22 $347.61 2028 $21.59 $218.75 $174.76 $4,027.69 $182.09 $4,209.90 $21.22 $186.79 2029 $21.59 $206.32 $180.39 $4,054.72 $188.12 $4,238.14 $21.22 $174.37 2030 $21.59 $379.56 $184.33 $4,085.44 $192.23 $4,270.22 $21.22 $347.61 2031 $21.59 $218.75 $185.42 $4,085.44 $193.38 $4,270.22 $21.22 $186.79 2032 $21.59 $206.32 $185.96 $4,085.44 $193.95 $4,270.22 $21.22 $174.37 2033 $21.59 $696.06 $186.18 $4,119.49 $194.18 $4,279.49 $21.22 $650.40 2034 $21.59 $535.24 $186.18 $4,119.49 $194.18 $4,279.49 $21.22 $489.58 2035 $21.59 $522.82 $186.18 $4,119.49 $194.18 $4,279.49 $21.22 $477.16 2036 $21.59 $696.06 $186.18 $4,119.49 $194.18 $4,279.49 $21.22 $650.40 2037 $21.59 $535.24 $186.18 $4,119.49 $194.18 $4,279.49 $21.22 $489.58 2038 $21.59 $271.39 $186.18 $4,098.44 $194.18 $4,276.78 $21.22 $234.64 2039 $21.59 $444.63 $186.18 $4,098.44 $194.18 $4,276.78 $21.22 $407.88 2040 $21.59 $283.81 $186.18 $4,098.44 $194.18 $4,276.78 $21.22 $247.06 2041 $21.59 $271.39 $186.18 $4,098.44 $194.18 $4,276.78 $21.22 $234.64 2042 $21.59 $444.63 $186.18 $4,098.44 $194.18 $4,276.78 $21.22 $407.88 2043 $21.59 $223.23 $186.18 $4,097.25 $194.18 $4,284.08 $21.22 $189.26Abt Associates Inc., April 4, 2011 Cost and Economic Impact Analysis Using Alternative IPM Baseline Information 30



### Table 12-3: Time Profile of Benefits and Social Costs (Millions; $2009) Option 1 Option 2 Option 3 Option 4

Year Monetized

BenefitsTotal Social

Costs Monetized

BenefitsTotal Social

Costs Monetized

BenefitsTotal Social

Costs Monetized

BenefitsTotal Social

Costs 2044 $21.59 $210.81 $186.18 $4,097.25 $194.18 $4,284.08 $21.22 $176.84 2045 $21.59 $384.05 $186.18 $4,097.25 $194.18 $4,284.08 $21.22 $350.08 2046 $21.59 $223.23 $186.18 $4,097.25 $194.18 $4,284.08 $21.22 $189.26 2047 $21.59 $210.81 $186.18 $4,097.25 $194.18 $4,284.08 $21.22 $176.84 2048 $21.59 $379.56 $186.18 $4,085.80 $194.18 $4,270.59 $21.22 $347.61 2049 $21.59 $218.75 $186.18 $4,085.80 $194.18 $4,270.59 $21.22 $186.79 2050 $21.59 $206.32 $186.18 $4,085.80 $194.18 $4,270.59 $21.22 $174.37 2051 $21.59 $379.56 $186.18 $4,085.80 $194.18 $4,270.59 $21.22 $347.61 2052 $21.59 $217.12 $186.18 $4,084.17 $194.18 $4,268.96 $21.22 $186.35 2053 $21.59 $161.97 $186.18 $3,265.28 $194.18 $3,413.13 $21.22 $137.49 2054 $21.59 $179.23 $186.18 $2,448.96 $194.18 $2,559.84 $21.22 $160.87 2055 $21.59 $80.99 $186.18 $1,632.64 $194.18 $1,706.56 $21.22 $68.75 2056 $21.59 $40.49 $186.18 $816.32 $194.18 $853.28 $21.22 $34.37 2057 $19.39 $0.00 $160.24 $0.00 $167.09 $0.00 $19.06 $0.00 2058 $17.20 $0.00 $135.35 $0.00 $141.09 $0.00 $16.90 $0.00 2059 $4.49 $0.00 $68.61 $0.00 $71.71 $0.00 $4.42 $0.00 2060 $2.29 $0.00 $42.67 $0.00 $44.62 $0.00 $2.26 $0.00 2061 $1.15 $0.00 $21.86 $0.00 $22.86 $0.00 $1.13 $0.00 2062 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 PV 3% $453.68 $9,501.76 $3,108.23 $115,617.01 $3,232.89 $119,904.41 $445.83 $8,583.74 Annualized at 3% $17.63 $369.29 $120.79 $4,493.51 $125.65 $4,660.14 $17.33 $333.61 PV 7% $221.34 $5,971.21 $1,272.59 $65,258.19 $1,320.89 $67,451.37 $217.50 $5,422.89 Annualized at 7% $16.04 $432.67 $92.20 $4,728.60 $95.71 $4,887.52 $15.76 $392.94 Source: U.S. EPA analysis, 2011